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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

 March
1,  2023

CONFIDENTIAL

Joseph
Kempf

Robert
Littlepage

Matthew
Crispino

Jan
Woo

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. 1 to Registration Statement on Form F-1

    Filed
    February 10, 2023

    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 February 23, 2023 regarding the Company’s Amendment No. 1 to the Registration Statement on Form F-1
publicly filed on February 10, 2023 (the “Amendment No. 1 to 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.2 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 Amendment No. 1 to 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.2 to the Registration Statement.

Partners
| Constance Choy H.M., Desmond Ang C.K., (Stephanie) Chan C. M., (Christopher) Cheng C.H., Meng Ding, Dominic D. James, (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)*, (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., Patrick Liu L., (Winnie) Mak T.M., Dominic Sze C.K.,

Douglas Tsang C.L., (Eva) Tsui Y.W, 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.2 to the Registration Statement

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.

    In
response to the Staff’s comment, the Company has revised the registration statement to contain separate prospectuses for the underwritten
primary offering and the at-the-market resale offering.

    The
    Company believes that including the resale offering in the registration statement provides important information about the Company
    in a single document, which allows potential investors who may be interested in both the primary offering and the resale offering
    to make informed investment decisions. This approach provides flexibility to selling shareholders to sell their shares immediately
    after the closing or wait until a favorable market condition develops, while saving the extra cost of filing a separate resale registration
    statement.

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 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.

    In response to the Staff’s comment, the Company has
    revised the referenced disclosure on pages 5 and 32 of the Amendment No. 2 to the Registration Statement.

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.

     In
                                            response to the Staff’s comment, the Company has included a Request for Waiver and
                                            Representation under Item 8.A.4 of Form 20-F as Exhibit 99.2 to the Amendment No. 2 to the
                                            Registration Statement.

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.

    In
response to the Staff’s comment, the Company has revised the referenced disclosure on page II-1 of the Amendment No. 2 to the Registration
Statement.

***

Page
3

If
you have any questions regarding the Amendment No.2 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