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JM Global Holding Company

1615 South Congress Avenue, Suite 103

Delray Beach, FL 33445

    January 10, 2018

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 20, 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 29, 2017 regarding our Revised Preliminary Merger Proxy
Statement on Schedule 14A (the “Proxy Statement”) previously filed on December 20, 2017. A marked version of
the Proxy Statement is enclosed herewith reflecting all changes to the Proxy Statement made in Amendment No. 3 to the Proxy Statement
filed with the Commission (“Amendment No. 3”).

Amendment No. 2 to the Preliminary Proxy Statement filed
December 20, 2017 Sunlong

Management’s Discussion and Analysis, page 156

Results of Operations, page 157

 1. You state on page 159: “Our trading of industrial waste materials are dependent to the progress of the end users whom
used our solid waste recycling equipment and when they are able to sell those industrial waste materials to our suppliers to process
the waste.” Please clarify this sentence given it appears that China Sunlong’s suppliers sell waste materials to China Sunlong
and then China Sunlong sells those waste materials to the two significant business “end users” who are related to each
other, but then those end users sell the waste materials back to the suppliers. Assuming this sequence is correct, explain to us
why the two related end users do not instead purchase the waste materials directly from the suppliers, since your suppliers directly
drop ship the waste materials to them. In this regard, it is not clear what value, if any, China Sunlong has provided to the related
end users and therefore how it has earned or appropriately recognized revenues. It is also not clear whether there is a legitimate
business purpose for the two related end users to pay a 34% premium (equivalent to the gross margin recorded on these transactions
through September 30, 2017) to only process these transactions through China Sunlong. Please disclose in the filing whether management
believes that this trading business model is sustainable and the basis for that assessment.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

January 10, 2018

Page 2 of 7

Response: In response
to the Staff’s comment, the Company wishes to clarify that the business sequence of the sentence, “Our trading of industrial
waste materials are dependent to the progress of the end users whom used our solid waste recycling equipment and when they are
able to sell those industrial waste materials to our suppliers to process the waste” is incorrect. The two significant customers
who purchased the processed solid waste materials are in the construction, decorative and paint materials industries. They did
not sell any waste materials back to our solid waste recycling equipment suppliers. The end users (i.e. mine operators) who used
our solid waste recycling equipment are in the mining, metal and clean technology industries. They are the ones who sold the waste
materials to our suppliers who process the waste materials, not recycling equipment. We purchased the processed industrial waste
materials from such suppliers and sold to our customers who turned the processed industrial waste materials into a variety of materials
used for decoration such as plastic wood, interior wall decorative panels, and stone plastic limitation wood floorings. Our two
significant customers have no connections to our industrial waste material suppliers or the end users who used our solid waste
recycling equipment. Thus, these two significant customers have to purchase the processed solid waste materials through us.

The Company has revised its
disclosure on pages 159 and 164 of Amendment No. 3 to clarify the roles of the suppliers and customers of our industrial
waste materials and the end users of our solid waste recycling equipment. We have also provided a description of our waste
material trading business model and how Sunlong connects its customers and sets its prices as follows:

“We
started our industrial waste materials trading business due to the opportunity that existed in the marketplace, as the end users
of our solid waste recycling equipment, also referred to as our equipment end users, while in the process of using our solid waste
recycling equipment to clean and extract waste from mines and job sites, may also extract and separate certain valuable metals
from other industrial waste materials. We recognize that there is a market for these metals and waste materials and as a result,
we connect our equipment end users who sell the byproduct of materials they produce to our industrial waste materials suppliers,
who have the capability of processing such solid waste materials into powder and directly ship such products to our industrial
waste materials customers. This type of trading business is related to our solid waste recycling systems and equipment business
because the end users of our solid waste recycling equipment only use our equipment to extract the valuable metals and chemicals
for their needs. These end users do not need the residual materials generated as a byproduct of extraction and considered to be
industrial waste materials. As a result, we believe our industrial waste material trading business is sustainable as long as our
solid waste recycling system and equipment business is sustainable. We strongly believe our solid waste recycling system and equipment
business is sustainable because of upcoming favorable energy conservation and emission reduction target-setting policies mandated
by the PRC government. Notwithstanding the foregoing, this is a new line of our business that is still in the development stage.
We did not generate any industrial waste materials trading revenues during the fourth quarter of 2017.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

January 10, 2018

Page 3 of 7

During the
nine months ended September 30, 2017, trading increase of some industrial waste materials from Acid Hydrolysis Titanium Dioxide,
Petroleum FCC Catalyst, Ilmenite Tailings, Copper Smelting Tailings was offset by the trading decrease in Ultrafine Grinding Silicon
Powder, as compared to the same period in 2016. Our trading of industrial waste materials are dependent on the progress of our
recycling equipment end users and when they are able to sell those industrial waste materials to our suppliers of industrial waste
materials to process the waste. During the nine months ended September 30, 2017, as we continued to generate our equipment revenues,
our equipment end users used our equipment to extract the valuable metals and chemicals for their needs, but they did not need
the waste materials that were generated as a byproduct of such extraction. Our access to these resources has allowed us to trade
the aforementioned industrial waste materials as compared to the same period in 2016.

Approximately
2 to 3 weeks prior to shipment, our suppliers of industrial waste materials will physically process the industrial waste materials
at the locations of the equipment end users. These end users are located in different provinces of China, such as Hubei, Sichuan,
Jiangsu, and Zhejiang. After our industrial waste material suppliers have processed the industrial waste materials per our specifications,
they will drop ship the materials by truck, which takes approximately 1 to 5 days, directly to our industrial waste materials customers
in the city of Wuhan, Hubei province, for our inspection, before being inspected and accepted by our customers.

During the
nine months ended September 30, 2017, two customers accounted for 49.7% and 49.0% of our trading and others revenues as compared
to 48.9% and 45.8% during the nine months ended September 30, 2016. These two customers are in the construction, decorative and
paint materials industry, who attended the “Titanium Dioxide Acid Waste Separation and Recovery Technology” seminar
that we hosted in March 2016. These two customers are unrelated third parties to us but they are related to each other. They are
able to manufacture these processed industrial waste materials and turn them into variety of materials used for decoration such
as plastic wood, interior wall decorative panels, stone plastic limitation wood floorings. The decoration materials made from these
processed industrial waste materials are much cheaper than using other environmentally friendly raw materials, and generally have
better qualities. We evaluate prices of similar raw materials for construction and then set a price with these two customers. We
believe our customers might be able to obtain government support and grant for using these industrial waste materials products.”

We have enclosed herewith as
Exhibit A one set of transaction contracts with two of our suppliers and two of our customers of our industrial waste
materials for your reference to give you a better understanding of our business model.

In addition, the Company has
revised its disclosure on pages 159 and page 164 of Amendment No. 3 to explain that it is our belief that this trading business
model is sustainable and the basis for that assessment as follows:

“These end users do not
need the residual materials generated as a byproduct of extraction, and considered as industrial waste materials. As a result,
we believe our trading of industrial waste material business is sustainable as long as our solid waste recycling system and equipment
business is sustainable. We strongly believe our solid waste recycling system and equipment business is sustainable because of
upcoming favorable energy conservation and emission reduction target-setting policies mandated by the PRC government.”

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

January 10, 2018

Page 4 of 7

 2. We have read the revision on page 161 related to the third bullet of comment 4 in our letter
dated December 14, 2017. You have disclosed that you earned consulting revenue during the year ended December 31, 2016 with “minimal
cost” associated with that revenue. Please explain why or how such revenue was able to be recorded with “minimal cost.”

Response: In response
to the Staff’s comment, Sunlong has rendered technical supporting and consulting services on certain solid waste recycling
technology to a customer over a two months period. Sunlong’s revenue was recognized over the service period on a straight-line
basis. The costs associated with such revenue are the salaries of Sunlong’s research and development employees with minimal
cost.

Liquidity and Capital Resources,
page 170

 3. Regarding the latest revision to the accounts receivable discussion on page 170, the responses
provided in your letters raise a concern that China Sunlong’s September 30, 2017 allowance for doubtful accounts accounting policy
was not applied in a complete and objective manner as required by ASC 310-10-35-4 through 35-11. The responses focus on unsupported
and subjective assumptions while failing to fully address the primary objective and verifiable evidence that was known when the
September 30, 2017 financial statements were filed on December 1, 2017. For example, when the September 30, 2017 financial statements
were filed, management knew that the two affiliated customers that generated substantially all of your 2017 trading revenue had
not paid any of the $18.7 million of receivables associated with those revenues, irrespective of the applicable 30 day payment
terms. Further, management knew that approximately $11 million of that balance was over five months old and that the significant
delinquency cannot reasonably be attributed to the two customers’ longer “operating cycles” given that these same customers
were apparently able to pay substantially all of the $837,332 they owed on the July 1, 2016 — December 31, 2016 trading sales
transactions by December 31, 2016. Also, management was aware that they had very little experience negotiating these trading transactions
prior to 2017. We further note that despite our prior request, management was not able to specifically explain why the customers
have not been able to pay what they owe. In addition, there does not appear to be any objective and verifiable evidence supporting
an assumption that the two customers currently have the financial resources to pay what they owe. ASC 310-10-35-8 requires that
management consider such known evidence that existed up through the date the financial statements were actually issued. Please
revise the China Sunlong financial statements to establish an allowance for doubtful accounts balance that reasonably reflects
the known, adverse and objective evidence surrounding the collectibility of these receivables. Alternatively, provide us with English
translation versions of the underlying contracts and a chronological summary of all discussions between China Sunlong and the two
customers concerning the causes and status of these delinquent accounts so that we can better understand whether there is a rational
and objective basis for the zero allowance balance at September 30, 2017. In assessing the materiality of this issue, we note that
the delinquent receivables approximate 30% of 2017 total assets and 50% of 2017 total revenue. Further, we note that per page 93,
the China Sunlong purchase that shareholders are voting on was valued using a multiple of projected 2017 revenue.

Pamela A. Long, Assistant Director

U.S. Securities and Exchange Commission

January 10, 2018

Page 5 of 7

Response: In response
to the Staff’s comment, Sunlong has revised its September 30, 2017 financial statements to establish an allowance for doubtful
accounts balance that reasonably reflects the known, adverse and objective evidence surrounding the collectibility of these receivables,
and encloses as Exhibit B herewith its calculations for such allowance. In addition, the Company has revised its
disclosure on pages 170 and 171 of Amendment No. 3 to update the subsequent collection amount and to include discussion on Sunlong’s
methodology on its allowance policy as follows:

“As of September
30, 2017, Sunlong had approximately $21.0 million of accounts receivables from Sunlong’s customers, of which
approximately $18.7 million were accounts receivable from Sunlong’s trading operations. Sunlong’s turnover ratio
currently is at approximately 2.4 times per year. Since Sunlong just developed the trading operations, Sunlong has extended
credit to its customers to gain market share. Sunlong’s existing payment terms on these customers are due in 30 days
after receipt of the goods. As these customers are in the construction, decorative and paint materials industry, the
construction period and its operating cycles usually take longer, which has also resulted in it taking a longer period of
time for Sunlong to receive their payments. We received approximately $3.7 million in accounts receivables from these
customers subsequent to September 30, 2017. Sunlong has collected all of its first quarter 2017 revenue from its trading of
industrial waste materials business in January 2018, which took approximately 9 months to receive its accounts receivable.
Sunlong is in the process of revaluating its credit terms to its customers to determine if longer credit terms are needed due
to the nature of the construction, decorative and paint materials industry.

In the meantime, after Sunlong
has considered a