SEC Comment Letter for Aperture AC (APUR) — Apr 29, 2026
Aperture AC
Date: April 29, 2026 · CIK: 0002093524 · Accession: 0000000000-26-004400
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-291583
Letter
Re: Aperture AC Amendment No. 3 to Form S-1 filed April 23, 2026 File No. 333-291583 Dear Calvin Kung:
April 29, 2026
Calvin Kung Chief Executive Officer Aperture AC 835 Wilshire Blvd. 5th Floor, Los Angeles, CA, 90017
We have conducted a limited review of your registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments.
Amendment No. 3 to Form S-1 Cover Page
1. Reference is made to the second paragraph and the fourth sentence of the last paragraph on page 69. Please clarify the nature of the "certain circumstances" where the per share redemption price could be below $10 per share. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
Please contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please April 29, 2026 Page 2
contact Todd Schiffman at 202-551-3491 or Christian Windsor at 202-551-3419 with any other questions.
Sincerely,
Division of Corporation
Finance
Office of Real Estate &
Construction
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> April 29, 2026 Calvin Kung Chief Executive Officer Aperture AC 835 Wilshire Blvd. 5th Floor, Los Angeles, CA, 90017 Re: Aperture AC Amendment No. 3 to Form S-1 filed April 23, 2026 File No. 333-291583 Dear Calvin Kung: We have conducted a limited review of your registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Amendment No. 3 to Form S-1 Cover Page 1. Reference is made to the second paragraph and the fourth sentence of the last paragraph on page 69. Please clarify the nature of the "certain circumstances" where the per share redemption price could be below $10 per share. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Please April 29, 2026 Page 2 contact Todd Schiffman at 202-551-3491 or Christian Windsor at 202-551-3419 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction </TEXT> </DOCUMENT>