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United States securities and exchange commission logo





                             October 14, 2022

       Yong (David) Yan
       Chief Executive Officer
       AlphaVest Acquisition Corp.
       420 Lexington Ave, Suite 2446
       New York, NY 10170

                                                        Re: AlphaVest
Acquisition Corp.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted September
20, 2022
                                                            CIK No. 0001937891

       Dear Yong (David) Yan:

             We have reviewed your amended 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.

       Amended Draft Registration Statement on Form S-1

       General

   1.                                                   We note your revised
disclosure in response to prior comment 2 that the the enforcement
                                                        of judgments obtained
in U.S. courts or foreign courts based on the civil liability
                                                        provisions of the U.S.
federal securities laws would be extremely difficult. Please explain
                                                        clearly the reasons for
such difficulties including the lack of reciprocity and treaties.
       Cover Page

   2.                                                   We note your response
to comment 4 and we re-issue it in part. Please revise the
                                                        disclosure to address
how recent statements and regulatory actions by China   s
                                                        government, such as
those related to data security or anti-monopoly concerns, has or may
 Yong (David) Yan
AlphaVest Acquisition Corp.
October 14, 2022
Page 2
      impact the company   s ability to conduct its business, accept foreign
investments, or list on
      a U.S. or other foreign exchange.
Summary, page 1

3.    Refer to prior comment 9. Please include cross-references to the more
detailed discussion
      of each of the China related risks in the prospectus.
       You may contact Frank Knapp at 202-551-3805 or Kristina Marrone at
202-551-3429 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or David Link at 202-551-3356 with any
other questions.



                                                            Sincerely,
FirstName LastNameYong (David) Yan
                                                            Division of
Corporation Finance
Comapany NameAlphaVest Acquisition Corp.
                                                            Office of Real
Estate & Construction
October 14, 2022 Page 2
cc:       Michael J. Blankenship
FirstName LastName
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