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February 23, 2023
Png Bee Hin
Chief Executive Officer
IMMRSIV Inc.
1004, Toa Payoh North #04-12
318995
Republic of Singapore
Re:IMMRSIV Inc.
Amendment No. 1 to Registration Statement on Form F-1
Filed February 10, 2023
File No. 333-269055
Dear Png Bee Hin:
            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.
Amendment 2 to Form F-1
Cover Page
1.We note the addition of a selling shareholder offering.  Please revise the registration
statement to contain separate prospectuses for the underwritten primary offering and the
at-the-market resale offering.  Also, tell us why you have included the resale offering in
this registration statement when the offering will not commence until after the closing of
the underwritten offering.
Risk Factors, page 13
2.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a

 FirstName LastNamePng Bee Hin
 Comapany NameIMMRSIV Inc.
 February 23, 2023 Page 2
 FirstName LastName
Png Bee Hin
IMMRSIV Inc.
February 23, 2023
Page 2
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock-run up,
may be unrelated to your actual or expected operating performance and financial
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock
Consolidated Financial Statements, page F-1
3.Provide audited financial statements that are as of a date not older than 12 months at the
time of filing and upon the effectiveness of the registration statement pursuant to Item
8.A.4 of Form 20-F or provide the appropriate representations in an exhibit. Refer to
Instruction 2 to Item 8.A.4.
Item 7. Recent Sales of Unregistered Securities, page II-1
4.Please revise to include the transaction in which the selling shareholders acquired the
shares being offered for resale, or advise.  Refer to Item 701 of Regulation S-K.
            You may contact Joseph Kempf, Senior Staff Accountant, at (202) 551-3352 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Matthew Crispino,
Staff Attorney, at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Meng Ding