SecProbe.io

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 August 11, 2025

Mattia Tomba
Co-Chief Executive Officer
Alchemy Investments Acquisition Corp 1
850 Library Avenue, Suite 204-F
Newark, DE 19711

 Re: Alchemy Investments Acquisition Corp 1
 Preliminary Proxy Statement on Schedule 14A
 Filed August 4, 2025
Dear Mattia Tomba:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Real Estate &
Construction
cc: Julia Aryeh
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 August 7, 2025

Mattia Tomba
Co-Chief Executive Officer
Alchemy Investments Acquisition Corp 1
850 Library Avenue, Suite 204-F
Newark, DE 19711

 Re: Alchemy Investments Acquisition Corp 1
 Preliminary Proxy Statement on Schedule 14A
 Filed August 4, 2025
 File No. 001-41699
Dear Mattia Tomba:

 We have reviewed your filing and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe
the comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A
Risk Factors, page 24

1. We note that you are seeking to extend your termination date to
September 9, 2026, a
 date which is 40 months from your initial public offering. We also note
that you are
 currently listed on Nasdaq and that Nasdaq Rule 5815 was amended
effective October
 7, 2024 to provide for the immediate suspension and delisting upon
issuance of a
 delisting determination letter for failure to meet the requirement in
Nasdaq Rule IM
 5101-2(b) to complete one or more business combinations within 36 months
of the
 date of effectiveness of its IPO registration statement. Please include
risk factor
 disclosure regarding the risk of being delisted from Nasdaq, including
that your
 securities will face immediate suspension and delisting action once you
receive a
 delisting determination letter from Nasdaq after the 36-month window
ends on May
 9,2026. Please disclose the risks of non-compliance with this rule,
including that
 under the new framework, Nasdaq may only reverse the determination if it
finds it
 made a factual error applying the applicable rule. In addition, please
also disclose the
 consequences of any such suspension or delisting, including that your
stock may be
 determined to be a penny stock and the consequences of that designation,
that you
 August 7, 2025
Page 2

 may no longer be attractive as a merger partner if you are no longer
listed on an
 exchange, any potential impact on your ability to complete an initial
business
 combination, any impact on the market for your securities including
demand and
 overall liquidity for your securities, and any impact on securities
holders due to your
 securities no longer being considered covered securities.
 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.

 Please contact Pearlyne Paulemon at 202-551-8714 or Pam Howell at
202-551-3357
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Julia Aryeh
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

Alchemy Investments Acquisition Corp 1

850 Library Avenue, Suite 204-F

Newark, DE 19711

May 2, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:
Ameen Hamady and Benjamin Holt

 Re: Alchemy Investments Acquisition Corp 1

Registration Statement on Form S-1

File No. 333-268659

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended, Alchemy Investments Acquisition Corp 1 (the “Company”) hereby requests
acceleration of the effective date of the above referenced Registration Statement to 4:00 p.m., Eastern Time, on May 4, 2023, or
as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Kirkland & Ellis LLP, request
by telephone that such Registration Statement be declared effective.

Please
contact Tamar Donikyan, of Kirkland & Ellis LLP, special counsel to the Company, at (212) 909-3421, as soon as the
Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

  Sincerely,

  /s/
Mattia Tomba

  Mattia Tomba

  Co-Chief
Executive Officer

CORRESP
1
filename1.htm

May 2, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention: Benjamin Holt and Pam Howell

Re: Alchemy Investments Acquisition Corp 1

  Registration Statement on Form S-1

  Filed December 2, 2022

  File No. 333-268659

Dear Mr. Holt and Ms. Howell:

Pursuant to Rule 461 under the Securities Act of
1933, as amended (the “Act”), the undersigned hereby joins in the request of Alchemy Investments Acquisition Corp 1 that the
effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. Eastern
Time on May 4, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations
under the Act, the undersigned wishes to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated
to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable
to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and
will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

* * *

[Signature Page Follows]

    Very truly yours,

    CANTOR FITZGERALD & CO.

    By:
    /s/ David Batalion

    Name:
     David Batalion

    Title:
    Managing Director, Investment Banking

[Signature Page to UW
Acceleration Request]

United States securities and exchange commission logo
April 28, 2023
Mattia Tomba
Co-Chief Executive Officer
Alchemy Investments Acquisition Corp 1
850 Library Avenue, Suite 204-F
Newark, DE 19711
Re:Alchemy Investments Acquisition Corp 1
Amendment No. 1 to Registration Statement on Form S-1
Filed April 5, 2023
File No. 333-268659
Dear Mattia Tomba:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 comment, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed April 5, 2023
Risk Factors, page 33
1.Please include a risk factor that describes the potential material effect on your
shareholders of the stock buyback excise tax enacted as part of the Inflation Reduction
Act in August 2022.  If applicable, include in your disclosure that the excise tax could
reduce the trust account funds available to pay redemptions or that are available to the
combined company following a de-SPAC.  Describe the risks of the excise tax applying to
redemptions in connection with:
•liquidations that are not implemented to fall within the meaning of “complete
liquidation” in Section 331 of the Internal Revenue Code,
•extensions, depending on the timing of the extension relative to when the SPAC
completes a de-SPAC or liquidates, and

 FirstName LastNameMattia Tomba
 Comapany NameAlchemy Investments Acquisition Corp 1
 April 28, 2023 Page 2
 FirstName LastName
Mattia Tomba
Alchemy Investments Acquisition Corp 1
April 28, 2023
Page 2
•de-SPACs, depending on the structure of the de-SPAC transaction.

Also describe, if applicable, the risk that if existing SPAC investors elect to redeem their
shares such that their redemptions would subject the SPAC to the stock buyback excise
tax, the remaining shareholders that did not elect to redeem may economically bear the
impact of the excise tax.
            You may contact Ameen Hamady at 202-551-3891 or Jennifer Monick at 202-551-3295
if you have questions regarding comments on the financial statements and related matters.
Please contact Benjamin Holt at 202-551-6614 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Tamar Donikyan, Esq.

CORRESP
1
filename1.htm

Alchemy Investments Acquisition Corp 1

850 Library Avenue, Suite 204-F

Newark, DE 19711

April 28, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ameen Hamady, Jennifer Monick, Benjamin Holt, Brigitte
Lippmann

Re: Alchemy Investments Acquisition Corp 1

Amendment No. 1 to Registration Statement
on Form S-1

Filed April 5, 2023

File No. 333-268659

Ladies and Gentlemen:

This letter sets forth responses of Alchemy Investments
Acquisition Corp 1 (the “Company”) to the comments of the staff of the Division of Corporation Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) set forth in your letter dated April 28, 2023,
with respect to the above-referenced Registration Statement on Form S-1 (the “Registration Statement”).

The text of the Staff’s comment have been
included in this letter for your convenience.

In addition, the Company has revised the Registration
Statement in response to the Staff’s comment and the Company is concurrently with this letter publicly filing the Registration
Statement which reflects these revisions and clarifies certain other information. References to page numbers in the Company’s
responses to the comments below correspond to the page number in the Registration Statement, as so amended. Unless otherwise indicated,
capitalized terms used herein have the meanings assigned to them in the Registration Statement.

Amendment No. 1 to Registration Statement on Form S-1
filed April 5, 2023

Risk Factors, page 33

 1. Staff’s comment: Please include a risk factor that
                                            describes the potential material effect on your shareholders of the stock buyback excise
                                            tax enacted as part of the Inflation Reduction Act in August 2022. If applicable, include
                                            in your disclosure that the excise tax could reduce the trust account funds available to
                                            pay redemptions or that are available to the combined company following a de-SPAC. Describe
                                            the risks of the excise tax applying to redemptions in connection with:

● liquidations
that are not implemented to fall within the meaning of “complete liquidation” in Section 331 of the Internal Revenue
Code,

● extensions,
depending on the timing of the extension relative to when the SPAC completes a de-SPAC or liquidates, and

● de-SPACs,
depending on the structure of the de-SPAC transaction.

Also describe, if applicable, the risk that if existing
SPAC investors elect to redeem their shares such that their redemptions would subject the SPAC to the stock buyback excise tax, the remaining
shareholders that did not elect to redeem may economically bear the impact of the excise tax.

Response: The
Company acknowledges the Staff’s comment and has added a risk factor regarding the excise tax on pages 32 and 55 of the amended
Registration Statement.

    2

We hope that the foregoing has been responsive
to the Staff’s comments. If you have any questions related to this letter, please contact Tamar Donikyan at (212) 909-3421 of Kirkland &
Ellis LLP.

    Sincerely,

    /s/ Mattia Tomba

    Mattia Tomba

    Co-Chief Executive Officer

Via E-mail:

 cc: Tamar Donikyan

                                            Kirkland & Ellis LLP

    3

CORRESP
1
filename1.htm

Alchemy Investments Acquisition Corp 1

850 Library Avenue, Suite 204-F

Newark, DE 19711

December 2, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ameen Hamady, Jennifer Monick, Benjamin Holt, Pam Howell

Re: Alchemy Investments Acquisition Corp 1

Draft Registration Statement on Form S-1

Submitted December 29, 2021

CIK No. 0001901336

Ladies and Gentlemen:

This letter sets forth responses of Alchemy Investments
Acquisition Corp 1 (the “Company”) to the comments of the staff of the Division of Corporation Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) set forth in your letter dated January 25, 2022,
with respect to the above-referenced Registration Statement on Form S-1 (the “Registration Statement”).

The text of the Staff’s comments have been
included in this letter for your convenience, and we have numbered the paragraphs below to correspond to the numbers in the Staff’s
letter. For your convenience, we have also set forth the Company’s responses to each of the numbered comments immediately below
each numbered comment.

In addition, the Company has revised the Registration
Statement in response to the Staff’s comments and the Company is concurrently with this letter publicly filing the Registration
Statement which reflects these revisions and clarifies certain other information. References to page numbers in the Company’s responses
to the comments below correspond to the page number in the Registration Statement, as so amended. Unless otherwise indicated, capitalized
terms used herein have the meanings assigned to them in the Registration Statement.

Draft Registration Statement on Form S-1 submitted December 29,
2021

Prospectus Cover Page, page i

 1. Staff’s comment: We note the disclosure that you may seek shareholder approval to amend the amended and restated memorandum
and articles of incorporation to extend the time period available to complete an initial business combination.
You then state that "public shareholders will be offered the opportunity to vote on or redeem their shares in connection with any
such extension." Please explain why shareholders will not be offered the opportunity to vote on and redeem their shares in connection
with such extension.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on the cover page to reflect that shareholders will be offered the opportunity
to vote on and redeem their shares in connection with an extension.

 2. Staff’s comment: We note the disclosure on page 120 that holders of class B ordinary shares are the only shareholders
entitled to vote for the appointment or removal of directors. Please revise the cover page to clearly disclose these disparate voting
rights. Please also reconcile the disclosure on page 120 with the disclosure on page 18, which states that class A and class B ordinary
shares vote together as a class, except as required by law.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on the cover page and throughout the prospectus to reflect that, except as required
by law, class A and class B ordinary shares will vote together as a single class on all matters including the election of directors.

Principal Shareholders, page 112

 3. Staff’s comment: Please disclose the control person(s) for your sponsor, DeepTech Capital LLC. In addition, we note
that you have attributed portions of the shares held by your sponsor to the various officers and directors. Please revise to include the
beneficial ownership of the entire amount held by your sponsor to the person(s) who controls your sponsor. See Instruction 2 to Item 403
and Rule 13d-3.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages  119 through 120 accordingly.

General

 4. Staff’s comment: We note your disclosure on pages 42 and 100 regarding competition. Please expand your disclosure
to address competition from other SPACs.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages  47 through 48 and 107 accordingly.

 5. Staff’s comment: We note your disclosure on pages 67 and 81 regarding the potential need to raise additional funds.
Please expand your disclosure to describe the impact of additional financing on public shareholders.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 74 and 89.

    2

We hope
that the foregoing has been responsive to the Staff’s comments. If you have any questions related to this letter, please contact
Tamar Donikyan at (212) 909-3421 of Kirkland & Ellis LLP.

    Sincerely,

    /s/ Mattia Tomba

    Mattia Tomba

    Co-Chief Executive Officer

Via E-mail:

 cc: Tamar Donikyan

Kirkland & Ellis LLP

    3

United States securities and exchange commission logo
January 25, 2022
Mattia Tomba
Co-Chief Executive Officer
VAM Acquisition Corp.
1 Via San Raffaele
20121 Milano MI
Italy
Re:VAM Acquisition Corp.
Draft Registration Statement on Form S-1
Submitted December 29, 2021
CIK No. 0001901336
Dear Mr. Tomba:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 submitted December 29, 2021
Prospectus Cover Page, page i
1.We note the disclosure that you may seek shareholder approval to amend the amended and
restated memorandum and articles of incorporation to extend the time period available to
complete an initial business combination.  You then state that "public shareholders will be
offered the opportunity to vote on or redeem their shares in connection with any such
extension."  Please explain why shareholders will not be offered the opportunity to vote
on and redeem their shares in connection with such extension.

 FirstName LastNameMattia Tomba
 Comapany NameVAM Acquisition Corp.
 January 25, 2022 Page 2
 FirstName LastName
Mattia Tomba
VAM Acquisition Corp.
January 25, 2022
Page 2
2.We note the disclosure on page 120 that holders of class B ordinary shares are the only
shareholders entitled to vote for the appointment or removal of directors.  Please revise the
cover page to clearly disclose these disparate voting rights.  Please also reconcile the
disclosure on page 120 with the disclosure on page 18, which states that class A and class
B ordinary shares vote together as a class, except as required by law.
Principal Shareholders, page 112
3.Please disclose the control person(s) for your sponsor, DeepTech Capital LLC.  In
addition, we note that you have attributed portions of the shares held by your sponsor to
the various officers and directors.  Please revise to include the beneficial ownership of the
entire amount held by your sponsor to the person(s) who controls your sponsor.  See
Instruction 2 to Item 403 and Rule 13d-3.
General
4.We note your disclosure on pages 42 and 100 regarding competition.  Please expand your
disclosure to address competition from other SPACs.
5.We note your disclosure on pages 67 and 81 regarding the potential need to raise
additional funds.  Please expand your disclosure to describe the impact of additional
financing on public shareholders.
            You may contact Ameen Hamady at 202-551-3891 or Jennifer Monick at 202-551-3295
if you have questions regarding comments on the financial statements and related matters.
Please contact Benjamin Holt at 202-551-6614 or Pam Howell at 202-551-3357 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Alejandro A. Gordano, Esq.