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JM Global Holding Company

1615 South Congress Avenue, Suite 103

Delray Beach, FL 33445

December 1, 2017

VIA EDGAR

U.S. Securities and Exchange Commission

Office of Manufacturing and Construction

100 F Street, N.E.

Mail Stop 4631

Washington, DC 20549

Attn: Pamela A. Long, Assistant Director

 Re: JM Global Holding Company

Preliminary Merger Proxy Statement on Schedule
14A

Filed October 11, 2017

File No. 1-37513

Dear Ms. Long:

JM Global Holding Company
(the “Company”, “JM Global,” “we”, “us” or “our”)
hereby transmits its response to the letter received by us from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”), dated November 7, 2017 regarding our Preliminary Merger Proxy Statement
on Schedule 14A (the “Proxy Statement”) previously filed on October 11, 2017. A marked version of the Proxy
Statement is enclosed herewith reflecting all changes to the Proxy Statement made in Amendment No. 1 to the Proxy Statement filed
with the Commission (“Amendment No. 1”).

General

 1. We note that you have not filed a Form S-4 for the issuance of shares to the Sellers in the Share Exchange under the Securities
Act. Please tell us what exemption from Securities Act registration you are relying upon and the facts supporting your use of the
exemption.

Response: Pursuant to the Staff’s request,
the Company respectfully advises the Staff that its proposed issuance of Company common stock to Sellers in connection with the
proposed Business Combination is exempt from registration under the Securities Act of 1933, as amended (the “Securities Act”),
pursuant to Section 4(a)(2) thereof and Regulation S promulgated thereunder.

The Company determined, based in part on the manner of
the issuance and the nature and limited number of recipients of the common stock to be issued in connection with the proposed
Business Combination (14 Sellers), that the proposed issuance of Company common stock under the Share Exchange Agreement does
not involve a “public offering” within the meaning of Section 4(a)(2) of the Securities Act. Negotiations with the
Sellers with respect to the Share Exchange Agreement were conducted privately outside of the United States. The Sellers have also
represented to the Company that each have sufficient knowledge and experience in financial and business matters that he or she
is capable of evaluating the merits and risks of the prospective investment in the Company common stock.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 1, 2017

Page 2  of 11

In addition, based on representations provided by
Sellers to the Company, the Company has concluded that, for each Seller, the conditions to the safe harbor under Rule 903 of Regulation
S for non-“U.S. persons” (as defined in Rule 902 of Regulation S) are satisfied for each Seller. Negotiations with
the Sellers were conducted outside of the United States in an “offshore transaction” (as defined in Rule 902 of Regulation
S). No “directed selling efforts” (as defined in Rule 902 of Regulation S) were conducted in connection with the signing
of the Share Exchange Agreement.

For the reasons stated above, the issuance of Company
common stock to the Sellers in connection with the proposed Business Combination is exempt from registration under the Securities
Act pursuant to Section 4(a)(2) thereof and Regulation S promulgated thereunder.

Letter to investors

 2. On the second page of this letter, where you disclose that public stockholders may elect to redeem shares even if they vote
in favor of the transaction, please clarify, if true, that public stockholders must vote either for or against the transaction
in order to exercise redemption rights. Please make similar clarifying disclosure on page 14 under “As long as I vote on
the Business Combination Proposal . . .” and elsewhere that similar disclosure appears.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on the second page of its letter to investors and page 14 of Amendment No. 1 to
clarify that public stockholders must vote either for or against the transaction in order to exercise redemption rights.

Summary Term Sheet, page 1

 3. To the extent practicable, and if material, please quantify in the bullet point on page 4 any out of pocket expenses incurred
in connection with activities on your behalf for which your sponsor, executive officers, directors, or any of their affiliates
will be reimbursed at the business combination’s closing.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 5, 13, 28, 54, 64, 68 and 105 of Amendment No. 1 to clarify that, although
our sponsor, executive officers, directors, or any of their affiliates will be reimbursed for out-of-pocket expenses incurred in
connection with activities relating to the business combination, no out-of-pocket expenses have been incurred to date.

 4. In the third full bullet point on page 2, and elsewhere containing similar disclosure, please clarify whether the public
shares held by your sponsor are included in the 31.2% interest to be retained by initial stockholders and affiliates after the
transaction. We note that you exclude the sponsor’s public shares from the 7.1% to be retained by public stockholders, based
on the assumptions you cite.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 2, 10, 24, 60, 83 and 106 of Amendment No. 1 to clarify that the public
shares held by our sponsor are included in the interest to be retained by initial stockholders and affiliates after the transaction.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 1, 2017

Page 3   of 11

How will JM Global’s Sponsor, directors and officers
vote?, page 12

 5. Please clarify and reconcile disclosure in this Q&A and elsewhere in the proxy statement that the Sponsor may redeem
up to an aggregate of 2,350,000 shares on the same terms as the public shares with disclosure on page 14 under “Do I have
redemption rights?” and elsewhere that the Sponsor has agreed to waive redemption rights.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 12 of Amendment No. 1 to clarify and reconcile the above-referenced disclosure.

Opinion of Highline Research Advisors LLC . . . , page
23

 6. Disclosure describing the opinion in this paragraph is not consistent with the opinion you have filed as Annex B to the
proxy statement. That opinion relates to the fairness, from a financial point of view, to the holders of the common stock of the
company. It does not address fairness to JM Global or the fair market value of CaymanCo in relation to the amount of funds held
in the trust. Please reconcile this and other disclosures in the proxy statement accordingly.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 23 of Amendment No. 1 to clarify that opinion opines that the Share Exchange
Agreement is fair, from a financial point of view, to the holders of the common stock of the Company.

Selected Unaudited Pro Forma Condensed Combined Financial
Information, page 32

 7. In the table on page 33, there are line items for net income for both redemption scenarios for the six months ended June
30, 2017 and the year ended December 31, 2016. However, these line items are blank. Please advise or revise.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 33 of Amendment No. 1 to include net income for both redemption scenarios.

We will incur significant transaction and transition costs
in connection with the Business Combination…., page 53

 8. You discuss among other things that if JM Global and Sunlong do not consummate the business combination, each party will
be required to pay its own fees and expenses, and JM Global likely will not have sufficient cash available to pay its fees and
expenses unless and until it completes a subsequent business combination transaction. Considering that a failure to effect a business
combination by January 29, 2018 is cited on page 139 as a condition that raises substantial doubt about your ability to continue
as a going concern, please revise this risk factor to address the fact that JM Global has historically been deemed a going concern.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 52-53 of Amendment No. 1 to describe the Company’s ability to continue
as a going concern.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 1, 2017

Page 4  of 11

Although we expect our common stock and warrants will
remain listed on NASDAQ after the Business Combination…, page 57

 9. Please continue to update disclosure relating to your plan of compliance submitted to NASDAQ on September 28, 2017.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 57 of Amendment No. 1 to provide an update as to NASDAQ’s acceptance
of our plan of compliance.

Unaudited Pro Forma Condensed Combined Financial Information,
page 67

 10. On page 68 you explain that one of the pro forma presentations assumes maximum redemptions of 100% of outstanding public
common stock plus redemptions of 100% of redeemable outstanding common shares held by the sponsor, which amounts to 3,386,888 shares
of the remaining redeemable common stock as of June 30, 2017. You disclose in a risk factor on pages 65-66, however, that because
your net tangible assets must be at least $5,000,001, “holders of no more than 499,274 shares of the 4,036,888 public shares
as of September 30, 2017 can redeem their public shares in connection with the Business Combination if the Business Combination
were consummated as of that date. As a result, we may be able to consummate the Business Combination even though holders of a majority
of our public shares have chosen to redeem their shares.” Considering that 963,112 shares were already redeemed at the extension
meeting on July 27, 2017, please explain how no more than 499,274 shares can constitute “a majority” of your redeemed
public shares. Explain how the maximum redemptions presentation is consistent with or makes sense based on the notion that redemption
is limited to only 499,274 shares.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on page 65 of Amendment No. 1, as follows:

This condition effectively
requires that holders of no more than 3,501,324 shares of the 4,036,888 public shares as of September 30, 2017 (including up to
2,350,000 or the 3,000,000 public shares held by our Sponsor) redeem their public shares in connection with the Business Combination
if the Business Combination were consummated as of that date. As a result, we may be able to consummate the Business Combination
even though holders of a majority of our public shares have chosen to redeem their shares.

The Share Exchange Agreement, page 82; Governing Law and
Dispute Resolution, page 87

 11. Notwithstanding the inclusion of disclaimers on pages 81 and 87, the representations, warranties and covenants in the exchange
agreement filed with this proxy statement constitute public disclosure for purposes of the federal securities laws, and JM Global
Holding Company or JM Global is responsible for considering whether additional specific disclosures of material information about
material contractual provisions of the share exchange agreement are required to make the statements included in the proxy statement
not misleading. Please include disclosure acknowledging that if specific material facts exist that contradict the representations,
warranties, or covenants in the share exchange agreement, you have provided corrective disclosure in the proxy statement. Furthermore,
if subsequent information concerning the subject matter of the representations, warranties, and covenants in the share exchange
agreement may or may not be fully reflected in JM Global’s public disclosures, please clarify that JM Global’s public
disclosures will include any material information necessary to provide JM Global’s stockholders a materially complete understanding
of the share exchange agreement disclosures.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 82 and 89 of Amendment No. 1 to clarify that, notwithstanding the disclaimers
on such pages, JM Global will provide corrective disclosures in the proxy statement if specific material facts exist that contradict
the representations, warranties, or covenants in the share exchange agreement, and its public disclosures will include any material
information necessary to provide JM Global’s stockholders a materially complete understanding of the Share Exchange Agreement
disclosures.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 1, 2017

Page 5  of 11

Background of the Business Combination, page 90

 12. Please revise the background to discuss the delivery of the fairness opinion that you have included as Annex B to the proxy
statement.

Response: In response to
the Staff’s comment, the Company has revised its disclosure on page 95 of Amendment No. 1 to discuss the delivery of the
fairness opinion to the Company’s board of directors.

Fairness Opinion of Highland
Research Advisors, page 98

 13. Please provide us with copies of any outlines, summaries, reports, projections, or board books prepared and furnished by
Highland Research Advisors to the JM Global’s board of directors.

Response: We are providing
to the Staff under separate cover, pursuant to Rule 418 under the Securities Act, copies of the materials requested, which include
materials provided to JM Global’s board in connection with the proposed transaction, including board presentations and the
final fairness opinion prepared by JM Global’s financial advisor, Highline Research Advisors.

Sunlong Selected Companies
Analysis, page 100

 14. Explain the meaning of “LTM” and “OCF.”

Response: In response to
the Staff’s comment, the Company has revised its disclosure on page 100 of Amendment No. 1 to define “LTM” as
“Latest Twelve Months” and “OCF” as “Operating Cash Flow.”

Miscellaneous, page 102

 15. Disclosure that Highland Research Advisors is providing and has in the past provided investment banking services to JM Global
or its affiliates is inconsistent with disclosure two paragraphs above that Highland Research Advisors had not been engaged by
or worked with JM Global before being engaged for the purpose of rendering this fairness opinion. Please reconcile the disclosures.

Response: In response to
the Staff’s comment, the Company has revised its disclosure on page 102 of Amendment No. 1 to clarify that Highline had not
been engaged by, or provided investment banking services to, JM Global (or any other participant to the transaction) before being
engaged to render its fairness opinion.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 1, 2017

Page 6  of 11

U.S. Federal Income Tax
Considerations to U.S. JM Global Stockholders, page 109

 16. Delete the word “generally” in the second and fourth paragraphs because the word may imply that stockholders
cannot rely on the disclosure. Revise elsewhere wherever similar disclosure appears in the proxy statement. Alternatively, describe
the basis for any uncertainty of the United States federal income tax consequences for stockholders.

Response: In response to
the Staff’s comment, the Company has revised its disclosure on pages 109-112 of Amendment No. 1 to delete the word “generally”
and provide additional clarifying disclosure.

Director Election Proposals,
page 118; Management after the Business Combination, page 171

 17. Identify the seventh director nominated by your board of directors to serve