CORRESP Filing
PMGC Holdings Inc.
Date: Nov. 25, 2025 · CIK: 0001840563 · Accession: 0001213900-25-114960
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File numbers found in text: 333-290428
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CORRESP
1
filename1.htm
November 26, 2025
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
One Station Place
100 F Street N.E.
Washington, D.C. 20549-7010
Re: PMGC
Holdings Inc.
Registration
Statement on Form S-1, as amended (No. 333-290428)
Ladies and Gentlemen:
The
undersigned registrant hereby requests that the effectiveness of the above-captioned Registration Statement on Form S-1 filed with the
U.S. Securities and Exchange Commission (the "Commission") on November 26, 2025, be accelerated so that it will be made effective
at 9:00 a.m. Eastern Daylight Time on December 1, 2025, or as soon thereafter as practicable, pursuant to Rule 461(a) of the Securities
Act of 1933, as amended (the "Act").
The
undersigned registrant hereby acknowledges that (i) should the Commission or the staff of the Commission ("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; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective,
does not relieve the undersigned registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing;
and (iii) the undersigned 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.
The undersigned registrant
is aware of its obligations under the Act.
Yours faithfully,
PMGC HOLDINGS INC.
By:
/s/ Graydon Bensler
Name: Graydon Bensler
Title: Chief Executive Officer