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                              October 14, 2022

       Behrooz Abdi
       Chief Executive Officer
       ACE Convergence Acquisition Corp.
       1013 Centre Road, Suite 403S
       Wilmington, DE 19805

                                                        Re: ACE Convergence
Acquisition Corp.
                                                            Post-Effective
Amendment No. 5 to Form S-4
                                                            Filed October 5,
2022
                                                            File No. 333-261055

       Dear Behrooz Abdi:

              We have reviewed your post-effective amendment 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.

       Post-Effective Amendment No. 5 to Form S-4

       General

   1.                                                   We note your disclosure
that Jefferies has "waived its entitlement to any fees solely with
                                                        respect to the proposed
Business Combination." Please revise to disclose what fees, if any,
                                                        Jefferies remains
entitled to under any agreements with any of the parties to the business
                                                        combination.
   2.                                                   Please provide us with
any correspondence between Jefferies and the other parties
                                                        involved with the
business combination relating to the firm's resignation.
   3.                                                   Please provide us with
the engagement letter between the company and Jefferies.
   4.                                                   Please update the
registration statement to reflect the results of your October 11, 2022
                                                        extraordinary general
meeting.
 Behrooz Abdi
ACE Convergence Acquisition Corp.
October 14, 2022
Page 2
5.       Please revise the "Recent Developments" section to quantify the fees
paid or due to each
         of Citi and Jefferies that have been waived or forfeited.
        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 Evan Ewing at 202-551-5920 or Anne Parker at 202-551-3611
with any
questions.



FirstName LastNameBehrooz Abdi                               Sincerely,
Comapany NameACE Convergence Acquisition Corp.
                                                             Division of
Corporation Finance
October 14, 2022 Page 2                                      Office of
Manufacturing
FirstName LastName