United States securities and exchange commission logo July 13, 2023 Sanjay Patel Chief Executive Officer Apollo Strategic Growth Capital II 9 West 57th Street, 42nd Floor New York, NY 10019 Re: Apollo Strategic Growth Capital II Form 10-K/A for the Fiscal Year Ending December 31, 2022 Filed April 5, 2023 File No. 001-40018 Dear Sanjay Patel: We have reviewed your filing 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 the comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K/A for the Fiscal Year Ending December 31, 2022 General 1. 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 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 Sanjay Patel Apollo Strategic Growth Capital II July 13, 2023 Page 2 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 Babette Cooper at 202-551-3396 or Wilson Lee at 202-551-3468 with any questions. FirstName LastNameSanjay Patel Sincerely, Comapany NameApollo Strategic Growth Capital II Division of Corporation Finance July 13, 2023 Page 2 Office of Real Estate & Construction FirstName LastName