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Correspondence 0001213900-24-081528 from Gelteq Ltd (GELS)

Gelteq Ltd
Date: Sept. 24, 2024 · CIK: 0001920092 · Accession: 0001213900-24-081528

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File numbers found in text: 333-280804

Date
September 24, 2024
Author
/s/ Nathan Givoni
Form
CORRESP
Company
Gelteq Ltd

Letter

VIA EDGAR Division of Corporation Finance Office of Life Sciences Re: Gelteq Limited Amendment No. 1 to Registration Statement on Form F-1 Filed September 12, 2024 File No. 333-280804

Dear Mr. Atallah:

Gelteq Limited (the “Company,” “we,” “our” or “us”) hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on September 20, 2024, regarding the Amendment No. 1 to Registration Statement on Form F-1 filed with the Commission on September 12, 2024.

For the Staff’s convenience, we have repeated below the Staff’s comment in bold, and have followed the comment with the Company’s response.

Amendment No. 1 to Registration Statement on Form F-1 filed September 12, 2024

General

1. 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.

Response: We respectfully advise the Staff that as of the date of this letter, neither the Company nor any of its authorized representatives has presented or expects to present potential investors in reliance on Section 5(d) of the Securities Act. However, in the event the Company does so, we will provide all such written communication to the Staff under separate cover.

* * * *

We thank the Staff for its review of the foregoing. If you have any further comments or questions, please feel free to contact our counsel, Richard I. Anslow, at ranslow@egsllp.com or by telephone at (212) 370-1300.

Sincerely,
/s/ Nathan Givoni

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CORRESP
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Gelteq Limited

Level 4

100 Albert Road

South Melbourne VIC, 3025

Australia

VIA EDGAR

September 24, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, NE

Washington, D.C. 20549

    Attn:
    Eric Atallah

    Kevins Vaughn

    Tamika Sheppard

    Laura Crotty

    Re:
    Gelteq Limited

    Amendment No. 1 to Registration Statement on Form F-1

    Filed September 12, 2024

    File No. 333-280804

Dear Mr. Atallah:

Gelteq Limited (the “Company,”
“we,” “our” or “us”) hereby transmits its response to the comment letter received from the staff
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on September 20,
2024, regarding the Amendment No. 1 to Registration Statement on Form F-1 filed with the Commission on September 12, 2024.

For the Staff’s convenience,
we have repeated below the Staff’s comment in bold, and have followed the comment with the Company’s response.

Amendment No. 1 to Registration Statement on Form F-1 filed September
12, 2024

General

    1.
    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.

Response: We respectfully advise
the Staff that as of the date of this letter, neither the Company nor any of its authorized representatives has presented or expects to
present potential investors in reliance on Section 5(d) of the Securities Act. However, in the event the Company does so, we will provide
all such written communication to the Staff under separate cover.

* * * *

We thank the Staff for its
review of the foregoing. If you have any further comments or questions, please feel free to contact our counsel, Richard I. Anslow, at
ranslow@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/ Nathan Givoni

    Nathan Givoni, Chief Executive Officer

    Gelteq Limited

    cc:
    Richard I Anslow, Esq.

    Ellenoff Grossman & Schole LLP