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CORRESP
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 Aperture AC

 835 Wilshire Blvd. 5th Floor,

 Los Angeles, CA, 90017

 VIA EDGAR

 May 6, 2026

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 Washington, D.C. 20549

 Attn: Eric McPhee

 Jennifer Monick

 Todd Schiffman

 Christian Windsor

 Re: Aperture AC

 S-1/A filed April 23, 2026

 File No. 333-291583

 Ladies and Gentleman:

 Aperture AC (the " Company ")
hereby transmits its response to the comment letter received from the staff (the " Staff ") of the U.S. Securities and
Exchange Commission (the " Commission ") on April 29, 2026 relating to the Amendment No.3 to the Registration Statement
on Form S-1, filed by the Company with the Commission on April 23, 2026.

 For the Staff's convenience, we have repeated
below the Staff's comment in bold and have followed each comment with the Company's response. Disclosure changes made in response
to the Staff's comments have been made in the Amendment No. 4 to the Registration Statement on Form S-1 (the " Registration
Statement ") which is being submitted to the Commission contemporaneously with the submission of this letter.

 Amended Registration Statement No. 3 on
Form S-1, Submitted April 23, 2026

 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.

 Response:

 The Company advises the Staff that the
Company has increased the funds to be deposited in the trust account, such that the pro rata redemption price will approximately $10.025
per public share (regardless of whether or not the underwriters exercise their over-allotment option), without taking into account any
interest or other income earned on such funds.

 In response to Staff's
comment, the Company has revised the second paragraph of the cover page and the fourth sentence of the last paragraph on page 69 of
the Registration Statement to add the following reference to the risk factor that provides additional discussion as to the nature of
certain circumstances where the per share redemption price could be below $10.025 per share (additions are [ bracketed, bolded
and underlined ] ):

 Cover Page:

 We expect the pro rata redemption price
to be approximately $10.025 per public share (regardless of whether or not the underwriters exercise their over-allotment option),
without taking into account any interest or other income earned on such funds, although the per share redemption price may be less in
certain circumstances. We cannot assure you that we will in fact be able to distribute such amounts as a result of claims of creditors,
which may take priority over the claims of our public shareholders. See " Summary - The Offering - Redemption rights for
public shareholders upon completion of our initial business combination" on page 26, "Summary - The
Offering - Redemption of public shares and distribution and liquidation if no initial business
combination " on page 31, and "Summary - The Offering - Indemnity by the sponsor in the event
of liquidation without a business combination on page 37" for more information . [See also " - If
third parties bring claims against us, the proceeds held in the trust account could be reduced and the per-share redemption amount
received by shareholders may be less than $10.025 per share " and other risk factors described in this " Risk Factors "
section.]

 Page 69:

 We expect that the pro rata redemption
price in any redemption will be approximately $10.025 per public share, without taking into account any interest or other income earned
on such funds (less any withdrawals of interest to pay our income taxes, if any), although the per share redemption price may be less
in certain circumstances. As a result, public shareholders who purchase units in this offering can anticipate receiving at least $10.025
per ordinary share (without taking into account interest or income earned on the amounts held in the trust account, less any permitted
withdrawals from accrued interest on such account) at the time of redemption for each share that they choose to redeem. [See " - If
third parties bring claims against us, the proceeds held in the trust account could be reduced and the per-share redemption amount
received by shareholders may be less than $10.025 per share " and other risk factors described in this " Risk Factors "
section] .

 * * *

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 We thank you for your review
of the foregoing and the Registration Statement. Should you have any questions or require any additional information, please do not hesitate
to contact our legal counsel, Jessica Yuan, Esq., of Ellenoff Grossman & Schole LLP, at jyuan@egsllp.com or by telephone at (212)
370-1300.

 Very truly yours,

 Aperture AC

 By:
 /s/ Calvin Kung

 Name:
 Calvin Kung

 Title:
 Chief Executive Officer

 cc: Jessica Yuan, Esq.

 Ellenoff Grossman & Schole LLP

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