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SEC Company Response from GD Culture Group Ltd (GDC) (CIK 0001641398) (GDC) — Jul 9, 2015

GD Culture Group Ltd (GDC) (CIK 0001641398)
Date: July 9, 2015 · CIK: 0001641398 · Accession: 0001213900-15-005074

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File numbers found in text: 333-204995

Date
June 16, 2015
Author
Richerson
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. McWilliams:

This letter supersedes our previous letter to you, dated July 7, 2015, requesting acceleration of effectiveness of the above referenced Registration Statement. 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 Monday, July 13, 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

Show Raw Text
CORRESP
1
filename1.htm

JM
Global Holding Company

1615
South Congress Avenue

Suite 103

Delray Beach, FL 33445

    July
    9, 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. McWilliams:

This
letter supersedes our previous letter to you, dated July 7, 2015, requesting acceleration of effectiveness of the above referenced
Registration Statement. 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 Monday, July 13, 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

cc:  Ellenoff
                                         Grossman & Schole LLP

    Graubard
                                         Miller