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August 30, 2023
Nathan Givoni
Chief Executive Officer
Gelteq Limited
Level 4
100 Albert Road
South Melbourne VIC, 3025
Australia
Re:Gelteq Limited
Amendment No. 5 to Registration Statement on Form F-1
Filed August 3, 2023
File No. 333-267169
Dear Nathan Givoni:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our March 27, 2023 letter.
Amendment No. 5 to Form F-1 filed August 3, 2023
Prospectus Summary
Overview, page 2
1.We note the newly added statement on pages 2, 64 and Alt-1 that your second patent
family has received a "favorable international preliminary report on patentability in the
international phase from the European Patent Office". Please revise this disclosure to
clarify the impact this preliminary report has on the application process and make clear
that approval is not assured, if true.

 FirstName LastNameNathan Givoni
 Comapany NameGelteq Limited
 August 30, 2023 Page 2
 FirstName LastNameNathan Givoni
Gelteq Limited
August 30, 2023
Page 2
Risk Factors, page 14
2.Given the significance of your intangible assets to your financial statements, please
provide a risk factor disclosure that addresses the possibility that you may incur
impairment charges related to your intangible assets.  At a minimum your risk factor
should address the following items:

•The percentage of intangible assets compared to your total assets;
•How often you assess your intangible assets for impairment;
•The judgments and uncertainties encompassed in the estimates and projections used
to determine the fair value of your intangible assets;
•How changes to those estimates or projections could impact your financial
statements; and
•How often you assess the useful life of your intangible assets and how changes to the
useful life could impact your financial statements.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Periods ended March 31, 2023 and 2022, page 53
3.We note that during the nine months ended March 31,2023, revenue from contracts with
customers was AUD$79,844 which related to the delivery of products to customers which
was previously recognized as deferred revenue.  Please revise to discuss the significant
components of your revenues, including a breakdown within each of your five core
vertical markets (pets, sports, pharmaceutical, over-the-counter and nutraceutical).
Critical Accounting Estimates and Judgements, page 60
4.Given that the Trade Secrets account comprises over 97% of your total assets in your
updated financial statements, please provide a disclosure that clearly identifies the factors
you considered in determining that the June 13, 2021 transactions were not required to be
accounted for as reverse acquisitions pursuant to IFRS 3. At a minimum, discuss each of
the factors in IFRS 3.B15. In discussing the relative voting rights criteria, please address
the disclosure on page F-97 that appears to show that a majority voting interest was
exchanged in the transactions. If the Nutrigel and/or Sport Supplements owners as a group
received the largest portion of the voting rights in the combined entity then that fact
should be clearly disclosed. Explain how you concluded that the former owners of
Nutrigel and Sport Supplements did not have the ability to elect or appoint a majority of
the members of the governing body of the combined entity. Explain how you concluded
that the former owners and managers of Nutrigel and Sport Supplements did not dominate
the management of the combined entity. Your disclosure must clearly identify the
individuals that controlled each entity both before and after the transaction. If there are
different allowable ways under IFRS to account for these transactions then please provide
a disclosure to that effect.

 FirstName LastNameNathan Givoni
 Comapany NameGelteq Limited
 August 30, 2023 Page 3
 FirstName LastName
Nathan Givoni
Gelteq Limited
August 30, 2023
Page 3
Business
Intellectual Property, page 77
5.Given the significance of your trade secrets, please revise to disclose how you acquired
the trade secrets, including how much the sellers paid to develop this intellectual property
and the time period that the intellectual property was developed.
Interim Financial Statements
Note 13. Borrowings, page F-24
6.We note that you recognized a gain on extinguishment of debt in the amount of
AUD$222,681 as a result of extending the term for an additional 12 months.  Please tell us
how you concluded that this extension constituted a substantial modification under IFRS
9, including your quantitative analysis under IFRS 9.B3.3.6.
General
7.We note that you entered into a letter of engagement with R.F. Lafferty & Co., Inc. on
April 25, 2023. Please provide us with supplemental copies of all written communications,
as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on
your behalf, have presented or expect to present to potential investors in reliance on
Section 5(d) of the Securities Act, whether or not you retained, or intend to retain, copies
of those communications.
            You may contact Eric Atallah at 202-551-3663 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Laura Crotty at 202-551-7614 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Richard I. Anslow, Esq.