SEC Company Response from GD Culture Group Ltd (GDC) (CIK 0001641398) (GDC) — Jul 7, 2015

GD Culture Group Ltd (GDC) (CIK 0001641398)
Date: July 7, 2015 · CIK: 0001641398 · Accession: 0001213900-15-004981

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File numbers found in text: 333-204995

Date

July 7, 2015

Author

Chief

Form

CORRESP

Company

GD Culture Group Ltd (GDC) (CIK 0001641398)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Re: JM Global Holding Company Registration Statement on Form S-1 Filed June 16, 2015, as amended File No. 333-204995

Dear Mr. Reynolds:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, JM Global Holding Company (the “Registrant”) hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EST on Thursday, July 9, 2015, or as soon as thereafter practicable.

Please note that we acknowledge the following:

● should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

● the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

● the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very
truly yours,
/s/
Tim Richerson

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CORRESP
1
filename1.htm

JM
Global Holding Company

1615
South Congress Avenue

Suite 103

Delray Beach, FL 33445

    July
    7, 2015

VIA
EDGAR

J.
Nolan McWilliams

Attorney-Advisor

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    JM Global
Holding Company

Registration
Statement on Form S-1

Filed
June 16, 2015, as amended

File
No. 333-204995

Dear
Mr. Reynolds:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, JM Global Holding Company (the “Registrant”) hereby requests
acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EST
on Thursday, July 9, 2015, or as soon as thereafter practicable.

Please
note that we acknowledge the following:

    ●
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
    declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
    relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
    the Commission or any person under the federal securities laws of the United States.

    Very
truly yours,

    /s/
    Tim Richerson

    Tim
    Richerson

    Chief
    Executive Officer

    cc:
    Ellenoff
    Grossman & Schole LLP

    Graubard
    Miller

SecProbe.io