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 March 18, 2025

Samuel Chau
Chief Executive Officer
World Media & Entertainment Universal Inc.
66 rue Jean-Jacques Rousseau
75001 Paris, France

 Re: World Media & Entertainment Universal Inc.
 Draft Registration Statement on Form F-4
 Submitted February 19, 2025
 CIK No. 0002053456
Dear Samuel Chau:

 We have reviewed your draft registration statement and have the following
comment(s).

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-4 submitted February 19, 2025
Cover Page

1. We note that aWME will make a cash payment equal to $1.25 per share to
non-
 redeeming shareholders of Black Spade II. Please revise to quantify the
total dollar
 amount that could be rewarded to such shareholders.
2. We note your disclosure that aWME will qualify as a controlled company.
Please
 revise to combine this paragraph with the disclosure regarding the AMTD
entities that
 is included later on the cover page. Specifically, where you first state
that aWME will
 be a controlled company, please identify the controlling shareholder or
shareholders
 and provide their percentage of ownership after the completion of the
business
 combination.
 March 18, 2025
Page 2

QUESTIONS AND ANSWERS ABOUT THE BUSINESS COMBINATION AND THE
EXTRAORDINARY GENERAL MEETING
Q: What equity stake will Black Spade II Shareholders and aWME Shareholders
have in
aWME after the Business Combination?, page 16

3. Please provide disclosure, in a footnote or otherwise, accompanying your
redemption
 scenarios that shows AMTD Group Inc.'s controlling interest in the
combined
 company.
Potential sources of dilution, page 36

4. Please revise your prospectus to include a dilution table that complies
with all of the
 requirements outlined in Item 1604(c) of Regulation S-K.
Summary of the Proxy Statement/Prospectus
Sources and Uses of Funds for the Business Combination, page 38

5. Please include the cash payment that aWME intends to make to
non-redeeming
 shareholders of Black Spade II in your table. If the precise amount is
not currently
 known, please provide good faith estimates.
Compensation Received by the Sponsor and its affiliates, page 50

6. In a tabular format, please provide the terms and amount of the
compensation received
 or to be received by the SPAC Sponsor, its affiliates, and promoters in
connection
 with the business combination or any related financing transaction, the
amount of
 securities issued or to be issued by aWME to the SPAC Sponsor, its
affiliates, and
 promoters and the price paid or to be paid for such securities in
connection with the
 business combination or any related financing transaction. Outside of
the table, please
 provide the extent to which that compensation and securities issuance
has resulted or
 may result in a material dilution of the equity interests of
non-redeeming shareholders.
 Refer to Item 1604(b)(4) of Regulation S-K.
RISK FACTORS, page 75

7. We note that the only material financial and valuation analyses
undertaken as part of
 the business combination were prepared by the Black Spade II board.
Please add risk
 factor disclosure that addresses the risks that reliance on the
valuation analyses poses
 to investors. Provide appropriate cross references wherever applicable
to your
 discussion on the interests that Black Spade II's directors and officers
have on the
 completion of a business combination.
THE BUSINESS COMBINATION AGREEMENT, page 134

8. Disclose in this section an explanation of any material differences in
the rights of
 Black Spade II and aWME security holders as compared with security
holders of the
 combined company as a result of the business combination. Specifically,
disclose the
 differences in the rights of holders of the combined company Class A and
Class B
 Ordinary Shares. Refer to Item 1604(b)(5) of Regulation S-K.
 March 18, 2025
Page 3
PROPOSAL 1 - THE BUSINESS COMBINATION PROPOSAL, page 145

9. State whether or not a majority of the directors (or members of a similar
governing
 body) of Black Spade II have retained an unaffiliated representative to
act solely on
 behalf of unaffiliated security holders for purposes of negotiating terms
of the
 business combination and/or preparing a report concerning the approval of
the
 business combination. Refer to Item 1606(d) of Regulation S-K.
INFORMATION ABOUT BLACK SPADE II, page 165

10. Please revise your disclosure here and wherever applicable to
specifically identify the
 controlling persons of the SPAC sponsor. Disclose, as of the most recent
practicable
 date, the persons who have direct and indirect material interests in the
SPAC sponsor,
 as well as the nature and amount of their interests. Refer to Item
1603(a)(7).
11. Briefly describe the fiduciary duties of each officer and director of the
special purpose
 acquisition company to other companies to which they have fiduciary
duties. Please
 refer to Item 1603(c) of Regulation S-K.
aWME's Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Discussion of Segment Operations
Year Ended December 31, 2022 Compared to Year Ended December 31, 2023, page 218

12. We note your disclosure that the revenue from the strategic investment
segment
 increased in 2023 partly due to the termination of certain derivative
contract in 2023.
 Please tell us in sufficient detail what the transaction entailed and how
you accounted
 for the revenue. Please revise your notes to the financial statements to
disclose the
 related revenue recognition policy as required.
Unaudited Pro Forma Condensed Combined Financial Information, page 224

13. We note that the historical financial statements of Black Spade II are
prepared based
 on the U.S. GAAP while the historical financial statements of aWME and
the pro
 forma financial statements appear prepared based on the IFRS as issued by
the IASB.
 Please tell us your consideration for presenting the adjustments to give
effect to the
 differences between the U.S. GAAP and IFRS for the purposes of the
unaudited pro
 forma condensed combined financial information.
14. Your disclosure on page 136 indicates that following the closing of the
business
 combination, earnout shares may be issued to AMTD Digital, AMTD IDEA
Group,
 and AMTD Group Inc. upon occurrence of certain triggering events. Please
tell us
 what consideration you gave to accounting for the arrangement within your
pro forma
 financial statements. As part of your response, please provide us with
your analysis
 and cite the authoritative guidance you relied upon in determining your
accounting
 treatment.
Compensation of Directors and Executive Officers, page 244

15. Please update your executive compensation for the year ended December 31,
2024.
 March 18, 2025
Page 4
TAX CONSIDERATIONS, page 246

16. Please revise to provide the federal income tax consequences of the
business
 combination to (i) Black Spade II, (ii) aWME, (iii) aWME security
holders, and (iv)
 Black Spade II security holders. Refer to Item 1605(b)(6) of Regulation
S-K.
World Media and Entertainment Universal Inc.
Notes to the Combined Financial Statements for the Years Ended December 31,
2022 and
2023 and Six Months Ended June 30, 2023 and 2024
2. Application of International Financial Reporting Standards
Revenue recognition, page F-40

17. We note your disclosure that hotel operation services income are
recognized over time
 by reference to the progress towards complete satisfaction of the
relevant performance
 obligations, as the customer simultaneously receives and consumes the
benefits
 provided by the Group's performance as the Group performs. Please revise
your
 disclosure of the revenue recognition policy to comply with the
disclosure
 requirements of IFRS 15, including paragraphs 119, 124, and 126, as
applicable.
18. We note you disclose on page F-57 that the Group entered into movie
income right
 agreements with production houses, and it is entitled to certain
percentage of the
 variable profit to be derived from the release movies. Please clarify
which segment
 recorded the related revenue in the reported periods and disclose the
applicable
 revenue recognition policy or advise.
5. Revenue and Other Income, page F-48

19. We note your disclosure of the gain of $24,757,000 related to the
disposal of equity
 interests in certain subsidiaries on page F-49. Please disclose in
sufficient detail what
 the transaction related to and tell us your consideration for presenting
it as a
 discontinued operation. Refer to IFRS 5.32.
General

20. With a view toward disclosure, please tell us whether your sponsor is, is
controlled
 by, has any members who are, or has substantial ties with, a non-U.S.
person. If so,
 please revise your filing to include risk factor disclosure that
addresses how this fact
 could impact your ability to complete your initial business combination.
For instance,
 discuss the risk to investors that you may not be able to complete an
initial business
 combination with a target company should the transaction be subject to
review by a
 U.S. government entity, such as the Committee on Foreign Investment in
the United
 States (CFIUS), or ultimately prohibited. Disclose that as a result, the
pool of potential
 targets with which you could complete an initial business combination may
be
 limited. Further, disclose that the time necessary for government review
of the
 transaction or a decision to prohibit the transaction could prevent you
from
 completing an initial business combination and require you to liquidate.
Disclose the
 consequences of liquidation to investors, such as the losses of the
investment
 opportunity in a target company, any price appreciation in the combined
company,
 and the warrants, which would expire worthless.
21. Disclose, in a tabular format to the extent practicable, the material
terms of any
 March 18, 2025
Page 5

 agreement, arrangement, or understanding regarding restrictions on
whether and when
 the SPAC sponsor and its affiliates may sell securities of the special
purpose
 acquisition company, including the date(s) on which the agreement,
arrangement, or
 understanding may expire. Refer to Item 1603(a)(9) of Regulation S-K.
22. Please tell us, with a view toward disclosure, whether you have received
notice from
 the underwriters or any other firm engaged in connection with the SPAC
s initial
 public offering about ceasing involvement in your transaction and how
that may
 impact your deal, including the deferred underwriting compensation owed
for the
 SPAC s initial public offering.
23. Please provide the information required by General Instruction I.2(f) of
Form F-4.
24. Please clarify whether or not the Black Spade II board reviewed any
financial
 projections of aWME prepared by any of the parties named herein in
connection with
 the business combination.
25. Please provide the Intellectual Property License Agreement with AMTD
Group Inc.
 as an exhibit to your registration statement or tell us why you are not
required to do
 so.
26. Please tell us if the majority of aWME's operations are in China,
including Hong
 Kong and Macau.
 Please contact Stephany Yang at 202-551-3167 or Hugh West at
202-551-3872 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Bradley Ecker at 202-551-4985 or Erin Purnell at 202-551-3454 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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