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                           April 28, 2022

       Robert Wessman
       Executive Chairman
       Alvotech Lux Holdings S.A.S.
       9, Rue de Bitbourg
       L-1273 Luxembourg
       Grand Duchy of Luxembourg

                                                        Re: Alvotech Lux
Holdings S.A.S.
                                                            Amendment No. 4 to
Registration Statement on Form F-4
                                                            Filed April 19,
2022
                                                            File No. 333-261773

       Dear Mr. Wessman:

             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
12, 2022 letter.

       Amendment No. 4 to Registration Statement on Form F-4

       Risk Factors
       Prior to the consummation of the Business Combination, and even
after..., page 55

   1.                                                   We note your disclosure
that you have entered into three new financing arrangements in
                                                        connection with the
Business Combination, including your loan agreement with Alvogen,
                                                        your debt facility with
Sculptor and your Standby Equity Purchase Agreement (SEPA)
                                                        with Yorkville. We also
note that you have revised the minimum cash requirement to
                                                        include cash proceeds
from the trust account (after redemptions), together with the
                                                        proceeds of the PIPE
Financing "and the aggregate proceeds in excess of $90,000,000
                                                        (representing financing
advanced, or expected to be advanced, to Alvotech by certain of
 Robert Wessman
Alvotech Lux Holdings S.A.S.
April 28, 2022
Page 2
      its existing shareholders) of any debt financing funded or available to
be funded to
      Alvotech from prior to the Closing (and, for the avoidance of doubt,
after December 7,
      2021), at or following the closing." With respect to these new financing
arrangements,
      please revise your disclosure throughout the registration statement as
follows:

             Please revise your discussion of the minimum cash requirement as
noted above to
           specify how the financing arrangements with Alvogen, Sculptor and
Yorkville may
           contribute to meeting this requirement.
             Please revise your disclosure, as appropriate, to disclose whether
and to what extent
           any of these new financing arrangements may be a possible source of
dilution
           shareholders who elect not to redeem their shares in connection with
the business
           combination. To the extent that any of the arrangements may be a
significant source
           of dilution, please provide disclosure of the impact of that
significant source of
           dilution at each of the redemption levels detailed in your
sensitivity analysis,
           including any needed assumptions.
             Please revise your Questions and Answers about the Business
Combination section
           starting on page 7 to include a discussion of new financing you are
obtaining in
           connection with the Business Combination, including the PIPE
financing as well as
           the loan agreement with Alvogen, the debt facility with Sculptor and
the SEPA with
           Yorkville.
             Please revise the Background of the Business Combination section
beginning on page
           149 to include a discussion of the negotiations of these various
agreements including
           background on when and why it was decided to pursue these additional
financing
           arrangements.
             Please revise the Certain Agreements related to the Business
Combination to include
           a summary of the material terms of each of these agreements,
including, where
           applicable, a description of any consideration provided in exchange
for the
           agreement.
             Please file the binding term sheet for the debt facility agreement
with Sculptor as well
           as the SEPA with Yorkville as exhibits or provide an analysis
supporting your
           determination that the agreements are not required to be filed.

        You may contact Franklin Wyman at 202-551-3660 or Vanessa Robertson at
202-551-
3649 if you have questions regarding comments on the financial statements and
related
matters. Please contact Jessica Ansart at 202-551-4511 or Jeffrey Gabor at
202-551-2544 with
any other questions.



                                                             Sincerely,
FirstName LastNameRobert Wessman
Comapany NameAlvotech Lux Holdings S.A.S.                    Division of
Corporation Finance
April 28, 2022 Page 2                                        Office of Life
Sciences
cc:
FirstName Nicolas Dumont
          LastName