United States securities and exchange commission logo





                           October 25, 2022

       Leonardo Santos
       Chief Executive Officer
       Semantix, Inc.
       Avenida Eus  bio Matoso, 1375, 10   andar
       S  o Paulo, S  o Paulo, Brazil, 05423-180

                                                        Re: Semantix, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed October 11,
2022
                                                            File No. 333-267040

       Dear Leonardo Santos:

              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 our comment, we may have additional comments.

       Amendment No.1 to F-1

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Liquidity and Capital Resources, page 141

   1.                                                   We note that the
company's projected revenues for 2022 were $58 million, as set forth in
                                                        the unaudited
prospective financial information management prepared and provided to the
                                                        Board of Directors of
Alpha Capital Holdco Company in connection with the evaluation
                                                        of the Business
Combination. We also note that your actual revenues for the Six Months
                                                        Ended June 30, 2022
were approximately $16.4 million. It appears that you will miss your
                                                        2022 revenue
projection. Please update your disclosure in Liquidity and Capital
                                                        Resources, and
elsewhere, to provide updated information about the company   s financial
                                                        position and further
risks to the business operations and liquidity in light of these
                                                        circumstances.
 Leonardo Santos
Semantix, Inc.
October 25, 2022
Page 2

      Please contact Matthew Crispino, Staff Attorney, at (202) 551-3456 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.



                                                         Sincerely,
FirstName LastNameLeonardo Santos
                                                         Division of
Corporation Finance
Comapany NameSemantix, Inc.
                                                         Office of Technology
October 25, 2022 Page 2
cc:       Filipe B. Areno
FirstName LastName