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    SIDLEY
    AUSTIN

    39/F,
    TWO INT’L FINANCE CENTRE

    CENTRAL, HONG KONG

    +852
    2509 7888

    +852
    2509 3110 FAX

    AMERICA
    ● ASIA PACIFIC ● EUROPE

    Meng
    Ding

    To
    Call Writer Directly

    +852
    2509 7858

    meng.ding@sidley.com

December
29, 2022

Joseph
Kempf

Robert
Littlepage

Austin
Pattan

Matthew
Crispino

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    IMMRSIV
    Inc.

    Amendment
    No.4 to Draft Registration Statement on Form F-1

    Submitted
    November 30, 2022

    CIK
    No. 0001936574

Dear
Mr. Kempf, Mr. Littlepage, Mr. Pattan and Mr. Crispino,

On
behalf of our client, IMMRSIV Inc. (the “Company”), a foreign private issuer incorporated under the laws of
the Cayman Islands, we are submitting to the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) this letter setting forth the Company’s responses to the comments contained in the
Staff’s letter dated December 7, 2022 regarding the Company’s amendment No.4 to draft registration statement on Form F-1
confidentially submitted on November 30, 2022 (the “Amendment No.4 to the Draft Registration Statement”) relating
to a proposed initial public offering of the Company’s Class A Ordinary Shares in the United States. Concurrently with the submission
of this letter, the Company is publicly filing its revised draft registration statement on Form F-1 (the “Amendment No.5
to the Draft Registration Statement”) via EDGAR to the Commission for review in accordance with the procedures of the Commission.

The
Company has responded to the Staff’s comment by providing a confirmation as requested. The Staff’s comment is repeated below
in bold and followed by the Company’s response. Terms used but not otherwise defined herein have the meanings set forth in the
Amendment No.5 to the Draft Registration Statement.

Partners
| Constance Choy H.M., Desmond Ang C.K., (Christopher) Cheng C.H., Meng Ding, (Sherlyn) Lau S.Y., David K. Lee, Linh Hue Lieu,

Olivia Ngan S.M., (Raymond) Oh C.H., Yuet Ming Tham, (Friven) Yeoh K.H., Claudia Yu K.W., Yan Zhang

Registered Foreign Lawyers | Gordon H. I. Davidson (England and Wales)*, Steven C Hsu (New York)*, (Carrie) Li J. (New York)*,
G. Matthew Sheridan (New York)*,

Effie Vasilopoulos (New South Wales)*, (Renee) Xiong Y. (New York)*, (Oliver) Zhong Q. (New York)*

Consultants | Hon Au Yeung, Huberta Chow X.L., Dominic D. James, Patrick Liu L., (Winnie) Mak T.M., Dominic Sze C.K.,

Douglas
Tsang C.L., (Eva) Tsui Y.W., Dominic Tsun W.L., Alan Wong C.K., Felicity Wong K.Y., Holly Yeung S.M., Iris Yuen L.S.

*
Partner of Sidley Austin Holding LLP (a Delaware Limited Liability Partnership)

° Foreign Legal Consultant / Legal Counsel

Page 2

Amendment
No.5 to the Draft Registration Statement

General

    1.
    We
    note your responses to comments 1 and 2, as well as your previous related responses. While we do not have any further comments at
    this time regarding your responses, please confirm your understanding that our decision not to issue additional comments should not
    be interpreted to mean that we either agree or disagree with your responses, including any conclusions you have made, positions you
    have taken and practices you have engaged in or may engage in with respect to this matter, including in regards to any NFTs that
    you may develop or mint in the future or that you may support or facilitate the minting or trading of in the future.

The
Company confirms its understanding that your decision not to issue additional comments should not be interpreted to mean that you either
agree or disagree with the Company’s responses, including any conclusions the Company has made, positions it has taken and practices
it has engaged in or may engage in with respect to this matter, including in regards to any NFTs that the Company may develop or mint
in the future or that it may support or facilitate the minting or trading of in the future.

***

If
you have any questions regarding the public filing of Amendment No.5 to the Draft Registration Statement, please contact me at meng.ding@sidley.com,
+852 2509 7858 (work) or +852 6461 4000 (cell).

Thank
you for your time and attention.

    Very
    truly yours,

    /s/
    Meng Ding

    Meng
    Ding

Enclosure

    c.c.
    Png
    Bee Hin, Chairman of the Board and Chief Executive Officer

    Raymond
    Oh, Partner, Sidley Austin

    Ahmed
    Mohidin, Partner, Paris, Kreit & Chiu CPA LLP

    Fang
    Liu, Esq., Partner, VCL Law LLP