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                              July 1, 2021

       Manish Jhunjhunwala
       Chief Executive Officer
       WinVest Acquisition Corp.
       125 Cambridgepark Drive, Suite 301
       Cambridge, Massachusetts 02140

                                                        Re: WinVest Acquisition
Corp.
                                                            Draft Registration
Statement on Form S-1
                                                            Filed June 3, 2021
                                                            File No. 377-04960

       Dear Mr. Jhunjhunwala:

              We have reviewed your 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Draft Registration Statement on Form S-1 Filed June 3, 2021

       General

   1.                                                   Please revise the
forepart of the prospectus to describe in greater detail how Trefis is
                                                        affiliated with your
sponsor. Clarify whether Trefis would count toward the requirement
                                                        that your target
business have an aggregate fair market value of at least 80% of the value
                                                        of the trust account.
   2.                                                   We note the statement
on page 6 that investors will have "the same voting and redemption
                                                        rights with respect to
any merger with Trefis" as are applicable to the initial business
                                                        combination. Please
clarify the circumstances, if any, when an acquisition of Trefis could
                                                        occur at a different
time from the initial business combination, as well as how the other
                                                        features of your
offering, such as the 24 months time limit, would apply.
 Manish Jhunjhunwala
WinVest Acquisition Corp.
July 1, 2021
Page 2
3.    Please revise to provide risk factor and other disclosure as appropriate
to clarify in
      qualitative and quantitative terms the economic conflicts associated with
the founder
      shares. For example, because the founder shares were acquired for less
than $.01 a share,
      it appears that public investors could lose more than half the value of
their initial $10 per
      share investment based on trading prices when the sponsor would still be
able to recoup its
      investment and make a substantial profit.
        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.

        You may contact Peter McPhun at (202)551-3581 or Kristina Marrone at
(202)551-
3429 if you have questions regarding comments on the financial statements and
related
matters. Please contact Janice Adeloye at (202)551-3034 or James Lopez at
(202)551-3536 with
any other questions.



                                                            Sincerely,
FirstName LastNameManish Jhunjhunwala
                                                            Division of
Corporation Finance
Comapany NameWinVest Acquisition Corp.
                                                            Office of Real
Estate & Construction
July 1, 2021 Page 2
cc:       Matthew L. Fry
FirstName LastName