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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

 February
10,  2023

CONFIDENTIAL

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.

    Registration
    Statement on Form F-1

    Filed
    December 29, 2022

    File
    No. 333-269055

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 January 18, 2023 regarding the Company’s Registration Statement on Form F-1 publicly filed on December
29, 2022 (the “Registration Statement on Form F-1”) 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 submitting its revised
registration statement on Form F-1 (the “Amendment No.1 to the Registration Statement”) via EDGAR to the Commission
for review in accordance with the procedures of the Commission.

The
Company has responded to all of the Staff’s comments by revising the Registration Statement on Form F-1 to address the comments,
and by providing an explanation if the Company has not so revised the Registration Statement on Form F-1. The Staff’s comments
are 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.1 to the 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.1 to the Registration Statement

Prospectus
Summary

Summary
of Risk Factors, page 5

    1.
    Please
    disclose in the prospectus summary that a major contract expired with your most significant customer, the Ministry of Defence of
    the Singapore government, which resulted in a significant decrease in revenue during the first half of 2022. We note that the agencies
    of the Ministry of Defence of the Singapore government contributed 93.6% and 90.9% of total revenue in 2020 and 2021, respectively,
    but this decreased to 17.7% for the six months ended June 30, 2022. Disclose the status of your attempt to renew your major contract
    with the Singapore government, including the estimated timeframe of the renewal as well as the current stage of your negotiations.

    In
    response to the Staff’s comment, the Company has revised the referenced disclosure on pages 5, 13, 81 and 82 of the
    Amendment No. 1 to the Registration Statement.

Management’s
Discussion and Analysis

Liquidity
and Capital Resources

Operating
Activities, page 57

    2.
    Please
    revise the discussion of liquidity and capital resources to clearly address the approximate $1.5 million of Pre-IPO investment provided
    by third parties. Disclose the material terms and conditions of this financing here and in the notes to the financial statements,
    as appropriate.

In
response to the Staff’s comment, the Company has revised the referenced disclosure on pages 57 and F-39 of the Amendment No. 1
to the Registration Statement.

Financial
Statements

Unaudited
Interim Condensed Consolidated Statement of Cash Flows, page F-34

    3.
    We
    note from the trade and other payables disclosure on page F-39 that an IPO investor loaned approximately $1.5 million to LDR Pte.
    Ltd. in exchange for an unsecured, noninterest bearing, convertible obligation that is “subject to share conversion upon the
    successful completion of the IPO exercise”. Tell us why this obligation appears as source of cash from operating activities
    in LDR Pte. Ltd.’s Statement of Cash Flows for the six months ended June 30, 2022 rather than as a financing cash flows activity.
    Otherwise, please revise.

In
response to the Staff’s comment, the Company has revised the referenced disclosure on pages 12, 43, 57, and F-34 of the Amendment
No. 1 to the Registration Statement.

***

Page 3

If
you have any questions regarding the Amendment No.1 to the 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

    Ahmed
    Mohidin, Partner, Kreit & Chiu CPA LLP

    Fang
    Liu, Esq., Partner, VCL Law LLP