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                          December 1, 2021

       Ruben Minski
       Chief Executive Officer
       Procaps Group, S.A.
       9 rue de Bitbourg, L-1273
       Luxembourg
       Grand Duchy of Luxembourg
       R.C.S. Luxembourg: B253360

                                                        Re: Procaps Group, S.A.
                                                            Registration
Statement on Form F-1
                                                            Filed November 24,
2021
                                                            File No. 333-261366

       Dear Mr. Minski:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Ada D.
Sarmento at 202-551-3798 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Flora R. Perez, Esq.