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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

Date
November 26, 2025
Author
Graydon Bensler
Form
CORRESP
Company
PMGC Holdings Inc.

Letter

Re: PMGC Holdings Inc.

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

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

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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