United States securities and exchange commission logo





                           February 15, 2022

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

                                                        Re: ACE Convergence
Acquisition Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-4
                                                            Filed February 1,
2022
                                                            File No. 333-261055

       Dear Mr. Abdi:

             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
December 10, 2021 letter.

       Amendment No. 1 to Registration Statement on Form S-4 Filed February 1,
2022

       Questions and Answers for Shareholders of ACE, page 11

   1.                                                   We note your response
to prior comments 1 and 2. Please provide similar disclosure in
                                                        the Q&A section.
       ACE's Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Liquidity and Capital Resources, page 226

   2.                                                   We have reviewed your
response to prior comment 23. You continue to disclose on page
                                                        227 that you had
$90,000 in borrowings under the working capital facility as of December
                                                        31, 2020. As noted on
pages F-4, F-16 and F-24, it appears that you actually had no
                                                        outstanding borrowings
under the working capital facility as of December 31, 2020.
 Behrooz Abdi
ACE Convergence Acquisition Corp.
February 15, 2022
Page 2
         Please revise your disclosure and ensure that the amounts presented
throughout the filing
         agree to the amounts presented on the face of the financial
statements.
Index to Financial Statements, page F-1

3.       Please note the updating requirements of Rule 8-08 of Regulation S-X.
Please similarly
         update your financial information throughout the filing.
       You may contact Jeff Gordon at 202-551-3866 or John Cash at 202-551-3768
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Erin Donahue at 202-551-6001 or Anne Parker at 202-551-3611 with any other
questions.



FirstName LastNameBehrooz Abdi                                Sincerely,
Comapany NameACE Convergence Acquisition Corp.
                                                              Division of
Corporation Finance
February 15, 2022 Page 2                                      Office of
Manufacturing
FirstName LastName