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                               April 26, 2022

       Sanjay Patel
       Chief Executive Officer and Director
       Apollo Strategic Growth Capital
       9 West 57th Street 43rd Floor
       New York, NY 10019

                                                        Re: Apollo Strategic
Growth Capital
                                                            Amendment No. 3 to
Registration Statement on Form S-4
                                                            Filed April 19,
2022
                                                            File No. 333-261820

       Dear Mr. Patel:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our April
6, 2022 letter.

       Amendment No. 3 to Registration Statement on Form S-4

       Selected Definitions, page 2

   1.                                                   Please revise to define
the term, "Amex Exit Conditions," here.
       Summary of Risk Factors, page 50

   2.                                                   We note your disclosure
throughout the filing that because you are deemed to be
                                                           controlled    by
American Express under the BHC Act, you are and will be subject to
                                                        supervision,
examination and regulation by the Federal Reserve. Please revise your cover
                                                        page and disclosure
here to describe related risks, including without limitation, the risks to
                                                        the Company and
shareholders related to the Amex Exit Conditions.
 Sanjay Patel
Apollo Strategic Growth Capital
April 26, 2022
Page 2
Business of GBT
Recent Performance and COVID-19 Update, page 282

3.    Your revised disclosure in response to prior comment 4 states that you
delivered $3.7
      billion new wins value in 2021, which represents new sales in terms of
the average annual
      spend expected to be served under the contract over its term. As this
appears to be
      projection information, tell us how you considered the guidance provided
in Item
      10(b) of Regulation S-K. In addition, consistent with our prior comment,
provide
      disclosure explaining why this information is useful to investors and
addressing estimates
      or assumptions underlying this metric and its calculation.
Exhibits

4.    Please re-file a complete copy of Exhibit 10.29. It appears that certain
schedules and
      exhibits have been omitted.
        You may contact Wei Lu, Staff Accountant, at 202-551-3725 or Ethan
Horowitz,
Accounting Branch Chief, at 202-551-3311 if you have questions regarding
comments on the
financial statements and related matters. Please contact Irene
Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Loan Lauren Nguyen, Legal Branch Chief, at
202-551-3642 with
any other questions.



                                                           Sincerely,
FirstName LastNameSanjay Patel
                                                           Division of
Corporation Finance
Comapany NameApollo Strategic Growth Capital
                                                           Office of Energy &
Transportation
April 26, 2022 Page 2
cc:       Ross A. Fieldston, Esq.
FirstName LastName