SecProbe.io

November 15, 2024
Say Leong Lim
Chief Executive Officer
Globalink Investment Inc.
200 Continental Drive, Suite 401
Newark, Delaware 19713
Re:Globalink Investment Inc.
Preliminary Proxy Statement on Schedule 14A
Filed November 8, 2024
File No. 001-41122
Dear Say Leong Lim:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Preliminary Proxy Statement filed November 8, 2024
The Extension Amendment Proposal
We note that you are seeking to extend your termination date to June 9, 2025, a date
which is 42 months from your initial public offering. We also note that you are
currently listed on Nasdaq and that Nasdaq Rule 5815 was amended effective October
7, 2024 to provide for the immediate suspension and delisting upon issuance of a
delisting determination letter for failure to meet the requirement in Nasdaq Rule IM
5101-2(b) to complete one or more business combinations within 36 months of the
date of effectiveness of its IPO registration statement. Please revise to state clearly
that your securities will face immediate suspension and delisting action once you
receive a delisting determination letter from Nasdaq after the 36-month window ends
on December 6, 2024. Please disclose the risks of non-compliance with this rule,
including that under the new framework, Nasdaq may only reverse the determination
if it finds it made a factual error applying the applicable rule. In addition, please also
disclose the consequences of any such suspension or delisting, including that your
stock may be determined to be a penny stock and the consequences of that
designation, that you may no longer be attractive as a merger partner if you are no 1.

November 15, 2024
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longer listed on an exchange, any potential impact on your ability to complete an
initial business combination, any impact on the market for your securities including
demand and overall liquidity for your securities, and any impact on securities holders
due to your securities no longer being considered “covered securities.”
General
2.With a view toward disclosure, please tell us whether your sponsor is, is controlled
by, has any members who are, or has substantial ties with, a non-U.S. person. Also
revise your filing to include risk disclosure that addresses how this fact could impact
your ability to complete your initial business combination. For instance, discuss the
risk to investors that you may not be able to complete an initial business combination
with a target company should the transaction be subject to review by a U.S.
government entity, such as the Committee on Foreign Investment in the United States
(CFIUS), or ultimately prohibited. Disclose that as a result, the pool of potential
targets with which you could complete an initial business combination may be
limited. Further, disclose that the time necessary for government review of the
transaction or a decision to prohibit the transaction could prevent you from
completing an initial business combination and require you to liquidate. Disclose the
consequences of liquidation to investors, such as the losses of the investment
opportunity in a target company, any price appreciation in the combined company,
and the warrants, which would expire worthless.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Mary Beth Breslin at 202-551-3625 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Guillaume de Sampigny