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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

September
18, 2023

CONFIDENTIAL

Joseph
Kempf

Kathryn
Jacobson

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. 3 to Registration Statement on Form
    F-1

    Filed September 1, 2023

    File No. 333-269055

Dear
Mr. Kempf, Ms. Jacobson, Mr. Crispino and Ms. Woo,

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 September 15, 2023 regarding the Company’s Amendment No. 3 to the Registration Statement on Form F-1
publicly filed on September 1, 2023 (the “Amendment No. 3 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. 4 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. 3 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. 4 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,

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. 3 to Form F-1 filed September 1, 2023

Prospectus
Summary, page 1

    1.
    Please
        revise your statement that a substantial part of your revenue is generated from providing eLearning content and consultancy services
        to the Ministry of Defence of the Singapore Government. Clarify that you did not generate significant revenue from the agencies
        of the Ministry of Defence of the Singapore government in 2022 and 2023 due to the expiration of a major contract in 2021.

    In
    response to the Staff’s comment, the Company has revised the referenced disclosure on page 1 of the Amendment No. 4 to the
    Registration Statement.

Recent
Development, page 5

    2.
    We
        note your disclosure regarding several purchase orders for your XR services, which resulted in a revenue increase and reduced
        losses for the six months ended June 30, 2023 as compared to the same period in 2022. To the extent available, please disclose
        your revenues and losses for the six months ended June 30, 2023 compared to the prior year period.

    In
response to the Staff’s comment, the Company has revised the referenced disclosure on page 5
of the Amendment No. 4 to the Registration Statement.

Risk
Factors

We
derived a significant portion of revenue from providing services..., page 13

    3.
    You
    disclose that 54.9% of your revenues in 2022 was derived from providing XR services to a financial institution and that you expect
    continued revenue from this customer in 2023. Given that you appear to be substantially reliant on this revenue source, please identify
    the customer. Further, provide the basis for your statement that you “expect to derive a substantial amount of revenue from...a
    local telecommunication service provider.” Clarify whether the purchase order from the customer is cancellable and quantify
    the amount of the purchase order to the extent material.

In
response to the Staff’s comment, the Company has revised the referenced disclosure on pages 13 and 82
of the Amendment No. 4 to the Registration Statement.

Consolidated
Statements of Profit or Loss and Other Comprehensive Income (Loss), page F-4

    4.
    Please
    present your expenses using a classification based on either their nature or their function, but not both. Refer to paragraphs 99-105
    of IAS 1.

In
response to the Staff’s comment, the Company has revised the referenced disclosure on pages 10,
42, 54, F-4 and F-21 of the Amendment No. 4 to the Registration Statement.

Notes
to the Consolidated Financial Statements

6.
Trade and other Receivables, page F-17

    5.
    Please
    report Prepayments as a separate line item, instead of being included as a component of Trade and other Receivables. Refer to Rule
    5-02(3) and (7) of Regulation SX.

In
response to the Staff’s comment, the Company has revised the referenced disclosure on pages 11, 43, F-3 and F-17 of the
Amendment No. 4 to the Registration Statement.

25.
Subsequent event, page F-27

    6.
    Please
    disclose the date when the financial statements were authorized for issue and who gave that authorization. Refer to paragraphs 17-18
    of IAS 10.

In
response to the Staff’s comment, the Company has revised the referenced disclosure on page F-27
of the Amendment No. 4 to the Registration Statement.

***

Page
3

If
you have any questions regarding the Amendment No. 4 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, Paris,
  Kreit & Chiu CPA LLP

  Fang Liu, Esq., Partner,
  VCL Law LLP