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JM
Global Holding Company

1615
South Congress Avenue, Suite 103

Delray
Beach, FL 33445

December
19, 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

Revised
Preliminary Merger Proxy Statement on Schedule 14A

Filed
December 1, 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 December 14, 2017 regarding our Revised
Preliminary Merger Proxy Statement on Schedule 14A (the “Proxy Statement”) previously filed on December 1,
2017. A marked version of the Proxy Statement is enclosed herewith reflecting all changes to the Proxy Statement made in Amendment
No. 2 to the Proxy Statement filed with the Commission (“Amendment No. 2”).

Selected
Unaudited Pro Forma Condensed Combined Financial Information, page 33

 1. We
                                         have read your response to comment 7 in our November 7, 2017 letter. You indicated that
                                         you have revised the table to provide net income for both redemption scenarios. However,
                                         we note this information was provided only for the nine months ended September 30, 2017.
                                         Please further revise to include net income for both redemption scenarios for the year
                                         ended December 31, 2016.

Response:
In response to the Staff’s comment, the Company has revised its disclosure on page 32 of Amendment No. 2 to include net
income for both redemption scenarios for the year ended December 31, 2016.

Certain
Company Projected Financial Information, page 103

 2. Refer
                                         to comment 13 in our November 7, 2017 letter. It is unclear why the tabular presentations
                                         on page 103 differ from the "Financial Projections — Sunlong" which you
                                         provided us. Please advise, and, as appropriate, revise the disclosure.

Response:
The Company wishes to clarify that the projections in “Financial Projections – Sunlong” provided
separately to Staff represented forecast information regarding Sunlong’s operations on a consolidated basis, while
prior tabular presentations on page 104 of the Proxy Statement erroneously only covered projections for the Shengrong
division of Sunlong’s operations and excluded projections relating to TJComex. In response to the Staff’s
comment, the Company has revised the tabular presentations on page 103 of Amendment No. 2 to conform to the forecasts
in “Financial Projections – Sunlong” that were separately provided.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 19, 2017

Page 2  of
4

Director
Election Proposals, page 118; Information about Directors Expected to be Appointed to the Board Upon the Closing of the Business
Combination, page 177

 3. In
                                         the biographical paragraphs of Ms. Hui Zhu, Ms. Yaqing Hu, and Mr. Chenchen Zhang, describe
                                         briefly their business experience during the past five years. See Item 7(b) of Schedule
                                         14A and Item 401(e)(1) of Regulation S-K.

Response:
In response to the Staff’s comment, the Company has revised its disclosure on page 175 of Amendment No. 2 to: (i) include
in Ms. Hui Zhu’s biography her business experience for the past five years. (ii) clarify that Ms. Yaqing Hu obtained her
bachelor’s degree in 2014 and her master’s degree in 2015, and (iii) clarify that Mr. Chenchen Zhang obtained his
bachelor’s degree in 2012 and his master’s degree in 2014. Given that they are recent graduates, neither Ms. Yaqing
Hu nor Mr. Chenchen Zhang has five years’ worth of business experience.

Sunlong
Management's Discussion and Analysis, Results of Operations, page 160

 4. We
                                         have read your response to comment 20 in our November 7, 2017 letter and note the related
                                         revisions related on pages 161-168 regarding your trading and other business. Please
                                         address the following:

 ● Explain
                                         to us why or how the products Acid Hydrolysis Titanium Dioxide and Petroleum FCC Catalyst
                                         each accounted for the same amount of trading and other revenues and cost of revenues
                                         for the year ended December 31, 2016, as shown on pages 166 and 168.

 ● Regarding
                                         the two significant customers at both September 30, 2017 (page 162) and December 31,
                                         2016 (page 167), please confirm, if true, that these customers are not related parties.
                                         Disclose whether they are related to each other and, if so, how.

 ● As
                                         previously requested, please revise to explain why the gross margin declined from 51%
                                         as of December 31, 2016 to 34.2% as of September 30, 2017.

Response:
In response to the Staff’s comment:

 (i) the
                                         Company respectfully advises the Staff that the reason for the same amount of trading
                                         and other revenues and cost of revenues for the year ended December 31, 2016 for the
                                         products Acid Hydrolysis Titanium Dioxide and Petroleum FCC Catalyst was that Sunlong
                                         sold the same amount of quantity of these products while the unit selling price and unit
                                         cost remained the same. These are the prices that Sunlong was able to negotiate with
                                         its customers and vendors for its trading business. In addition, these products perform a similar function as decorative building materials. As a result, these
two products would have a very similar pricing and we purchased these products from the same vendors and sold them to two customers
who were related to each other. Thus, these products has the same amount of trading and other revenues and cost of revenues for
the year ended December 31, 2016.

 (ii) The
                                         Company has revised its disclosure on pages 159 and 164 of Amendment No. 2 to provide
                                         additional disclosures that these two customers are unrelated third parties to Sunlong
                                         but they are related to each other.

 (iii) The
                                         Company has revised its disclosure on page 161 of Amendment No. 2 to explain why the
                                         gross margin declined from 51% as of December 31, 2016 to 34.2% as of September 30, 2017.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 19, 2017

Page 3  of 4

 5. We
                                         have read your response to comment 22 in our November 7, 2017 letter. While the risk
                                         factor has in fact been removed, disclosure remains on pages 20 and 140-141 regarding
                                         TJComex's licenses to build electronic commodity exchange platforms. Please revise.

Response:
In response to the Staff’s comment, the Company has removed its disclosure on pages 20, 137 and 138 of Amendment No. 2
with regard to TJComex’s licenses to build electronic commodity exchange platforms.

Liquidity
and Capital Resources, page 173

 6. We
                                         have read your response to comment 25 in our November 7, 2017 letter and the related
                                         revision on page 173. You have indicated that payment terms are 30 days after receipt
                                         of goods but that no collections have been made subsequent to September 30, 2017. Please
                                         tell us why the two customers that comprise a combined 99% of your trading and other
                                         revenue through September 30, 2017 and apparently represented by $18.7 million of the
                                         $21.1 million accounts receivable balance at that date have not been able to pay what
                                         is due. We note that since $11.6 million of the $20.0 million in trading and other revenue
                                         through the nine months ended September 30, 2017 was booked prior to July 1, 2017, most
                                         of the receivables are over five months old. Based on the inability of your customers
                                         to repay the receivable based on the contractual repayment terms, we are not able to
                                         conclude that the September 30, 2017 allowance balance complies with US GAAP nor that
                                         revenue was appropriately recorded since it is not clear that collectability was reasonably
                                         assured (from your revenue recognition policy on page 170). Please advise.

Response:
In response to the Staff’s comment, the Company has revised its disclosure on page 170 of Amendment No. 2 to explain why
Sunlong believes its September 30, 2017 allowance balance complies with U.S. GAAP. The Company respectfully advises the Staff
that at the time Sunlong recognized its revenue, it had persuasive evidence that an arrangement existed, delivery had occurred,
the price was fixed or determinable, and the ability to collect was reasonably assured. Sunlong has determined that it has adequate
allowance balance as of September 30, 2017 because it reaffirmed with its customers in November 2017 that its customers would
start making progressive payment from December 2017 to July 2018. Should these customers not making progressive payment by December
31, 2017, Sunlong will reassess its potential losses to determine if the bad debt allowance on Sunlong’s accounts receivable
is adequate as of December 31, 2017.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

December 19, 2017

Page 4 of 4

Beneficial
Ownership of Securities, page 191

 7. In
                                         the table on page 192, please include all of your executive officers and directors. We
                                         note that you have omitted Mr. Xiaoyan Shen, the chief financial officer and secretary
                                         identified on page 177.

Response:
In response to the Staff’s comment, the Company has added Ms. Xiaoyan Shen, our chief financial officer and secretary, to
the beneficial ownership table on page 189 of Amendment No. 2.

 8. Please
                                         tell us, and revise if appropriate, whether the shares in the table include the shares
                                         that the sponsor sold to Messrs. Tim Richerson and Peter Nathanial in October 2017. Please
                                         add also a footnote to clarify, if true, that the amounts in the table do not include
                                         the shares that the sponsor intends to sell to Messrs. Kurt Jetta and Arthur B. Drogue
                                         if the transaction is consummated as disclosed under "Certain Relationships and
                                         Related Party Transactions" on page 193.

Response:
In response to the Staff’s comment, the Company hereby confirms that the shares in the table include the shares that the
sponsor sold to Messrs. Richerson and Nathanial in October 2017. The Company has added a footnote on page 189 of Amendment No.
2 to clarify that the amounts in the table exclude the shares that the sponsor intends to sell to Messrs. Jetta and Drogue if
the Business Combination is consummated.

We
thank the Staff for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail
to our counsel, Stuart Neuhauser at sneuhauser@egsllp.com or by telephone at (212) 370-1300.

    Very
    truly yours,

    /s/
    Tim Richerson

    Tim
    Richerson, Chief Executive Officer

    cc:
    Douglas
        Ellenoff, Esq.

        Stuart
        Neuhauser, Esq.

        Ellenoff Grossman & Schole LLP