United States securities and exchange commission logo August 10, 2022 Gary Teplis Chief Executive Officer Altitude Acquisition Corp 400 Perimeter Center Terrace, Suite 151 Atlanta, GA 30346 Re: Altitude Acquisition Corp. Form 10-K for the year ended December 31, 2021 Filed March 29, 2022 File No. 001-39772 Dear Mr. Teplis: We have reviewed your filing 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the year ended December 31, 2021 Item 15. Exhibits, Financial Statement Schedules, page 61 1. Please amend your filing to revise Exhibits 31.1 and 31.2 to include the internal control over financial reporting language in the introductory portion of paragraph 4 and pargraph 4(b) of the Section 302 certification. General 2. With a view toward disclosure, please tell us whether your sponsor is, is controlled by, or has substantial ties with a non-U.S. person. If so, please revise your disclosure in future filings to include disclosure that addresses how this fact could impact your ability to complete your initial business combination. For instance, discuss the risk to investors that you may not be able to complete an initial business combination with a U.S. target company should the transaction be subject to review by a U.S. government entity, such as the Committee on Foreign Investment in the United States (CFIUS), or ultimately Gary Teplis Altitude Acquisition Corp August 10, 2022 Page 2 prohibited. Disclose that as a result, the pool of potential targets with which you could complete an initial business combination may be limited. Further, disclose that the time necessary for government review of the transaction or a decision to prohibit the transaction could prevent you from completing an initial business combination and require you to liquidate. Disclose the consequences of liquidation to investors, such as the losses of the investment opportunity in a target company, any price appreciation in the combined company, and the warrants, which would expire worthless. Please include an example of your intended disclosure in your response. 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. You may contact Ameen Hamady at 202-551-3891 or Kristi Marrone at 202-551-3429 if you have any questions. FirstName LastNameGary Teplis Sincerely, Comapany NameAltitude Acquisition Corp Division of Corporation Finance August 10, 2022 Page 2 Office of Real Estate & Construction FirstName LastName