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SEC Company Response from Aperture AC (APUR) — May 12, 2026

Aperture AC
Date: May 12, 2026 · CIK: 0002093524 · Accession: 0001213900-26-055143

Offering / Registration Process

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File numbers found in text: 333-291583

Date
May 12, 2026
Author
/s/ Calvin Kung
Form
CORRESP
Company
Aperture AC

Letter

APERTURE AC

835 Wilshire Blvd. 5 th Floor

Los Angeles, CA 90017

May 12, 2026

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, DC 20549

Re: Aperture AC

Registration Statement on Form S-1

Filed November 17, 2025, as amended

File No. 333-291583

Ladies and Gentleman:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Aperture AC hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 5:00 p.m. ET on May 14, 2026, or as soon as thereafter practicable.

Very truly yours,
/s/ Calvin Kung

Show Raw Text
CORRESP
 1
 filename1.htm

 APERTURE AC

 835 Wilshire Blvd. 5 th Floor

 Los Angeles, CA 90017

 May 12, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, DC 20549

 Re:
 Aperture AC

 Registration Statement on Form S-1

 Filed November 17, 2025, as amended

 File No. 333-291583

 Ladies and Gentleman:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Aperture AC hereby requests acceleration of effectiveness of the above referenced Registration
Statement so that it will become effective at 5:00 p.m. ET on May 14, 2026, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Calvin Kung

 Calvin Kung

 Chief Executive Officer

 cc: Ellenoff
Grossman & Schole LLP