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United States securities and exchange commission logo
April 26, 2023
Dana Green
Chief Executive Officer
GlobalTech Corp
3550 Barron Way, Suite 13a
Reno, NV 89511
Re:GlobalTech Corp
Amendment No.1 to Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 000-56482
Dear Dana Green:
            We have reviewed your filing and April 4, 2023 response to our comments 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 9, 2023 letter.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 April 26, 2023 Page 2
 FirstName LastName
Dana Green
GlobalTech Corp
April 26, 2023
Page 2
Amendment No. 1 to Annual Report on Form 10-K
Description of Business
General Information
Form and Year of Organization, page 4
1.We note your response to prior comment 1.  As previously requested, please reconcile the
ownership structure disclosed in WorldCall Telecom Limited’s September 30, 2022
Quarterly Report to the corporate structure presented in your filing.  That is, provide us
with your computation of the percentage of shares held by Worldcall Services (Private)
Limited and Ferret Consulting F.Z.C., and reconcile these amounts to the ownership
structure disclosed by WorldCall Telecom Limited.  You indicate that the local disclosure
required by WorldCall Telecom Limited does not include Convertible Preference Shares.
However, we note from your disclosure on page F-32 that the total number of Convertible
Preference Shares issued by WorldCall Telecom Limited was only 52,500 and these
shares were issued to Oman Telecommunications Company.  Explain why your disclosure
indicates that you own more than 50% of WorldCall Telecom Limited, while WorldCall
Telecom Limited’s disclosure indicates your subsidiaries own less than 50% of WorldCall
Telecom Limited, in aggregate.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Updates on plans:, page 49
2.Provide more detail with whom you are finalizing "arrangements" to provide a public
blockchain network in Pakistan.
3.With respect to your planned Public Blockchain Network, we note that you plan to deploy
your network as a “Blockchain-as-a-service”. Please provide more detail as to how your
“Blockchain-as-a-service” will function.  In this regard, explain how you will market this
service to the "education, logistics and financial services" sectors.  Provide examples of
how you envision the commercialization of your network materializing.
4.To the extent that you plan to develop your network on an established blockchain, please
revise your disclosure to identify which blockchain network you are planning to utilize
and include a discussion of the impact of transaction fees.
5.We note that your Public Blockchain Network will be “integrated into payment platforms,
providing transaction access through existing financial and banking institutions” and that
“monetization will result from a percentage charge on financial transactions executed on
the platform.” With a view towards expanded disclosure, please explain how your
proposed network will be integrated into payment platforms at existing financial and
banking institutions.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 April 26, 2023 Page 3
 FirstName LastName
Dana Green
GlobalTech Corp
April 26, 2023
Page 3
6.We note that you intend to utilize smart contracts for your target services. Please include
risk factor disclosure regarding the risk of coding errors or security vulnerabilities within
the smart contracts and provide a more complete discussion regarding smart contract
functionality and limits.
7.Please disclose whether your planned Public Blockchain Network will utilize any native
crypto asset(s) and, to the extent it does, whether you plan to issue any crypto assets to be
used in connection with the payment of services. Additionally, please disclose whether
your planned Public Blockchain Network and, to the extent you will utilize them, crypto
assets will be available in the U.S. or to U.S. persons.
Liquidity and Capital Resources
Cash flows from operating, investing, and financing Activities, page 51
8.You indicate that you held cash and cash equivalents of $3,120,572 and $3,670,589 as of
December 31, 2022 and 2021, respectively, and this balance is a source of funding to
satisfy your cash requirements over the next 12 months and beyond.  Please revise to
clarify that these amounts include restricted cash that is not available for immediate
ordinary business use.
Consolidated Statement of Cash Flows for the Years Ended December 31, 2022 and 2021, page
F-6
9.We note that cash flows from long-term loans and other assets are classified as operating
activities and cash flows used in the issuance of long-term loan are classified as investing
activities.  Please explain the nature of these items and tell us why the classification is
appropriate based on the guidance in ASC 230-10-45.  In addition, please explain why the
issuance of the long-term loan in 2021 is represented as a cash outflow.  In this regard, tell
us whether this line item should be described as the repayment of a long-term loan.
Notes to Consolidated Financial Statements
Note 2. Basis of Preparation of Consolidated Financial Statements
Business Combinations, page F-11
10.We note the disclosure included in response to prior comment 13.  Per ASC 805-10-45-2,
the assets and liabilities of EBI, as the accounting acquiree, should be recognized and
measured in accordance with the guidance in ASC 805 applicable to business
combinations.  As previously requested, please provide the disclosures in ASC 805-20-50
and ASC 805-30-50 related to the acquisition of EBI, the accounting acquiree.  That is,
also disclose the amounts recognized as of the acquisition date for each major class of
assets acquired and liabilities assumed, the acquisition-date fair value of the total
consideration transferred, and a qualitative description of the factors that make up the
goodwill recognized.  Refer to the example in ASC 805-10-55-37.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 April 26, 2023 Page 4
 FirstName LastName
Dana Green
GlobalTech Corp
April 26, 2023
Page 4
11.We note your response to prior comment 14.  Please clarify how you determined the
acquisition-date fair value of the WHI shares effectively transferred.  That is, your
response indicates that you used the book value of WHI, but you also indicate that you
used the valuation techniques of discounted cash flow and replacement cost methods.  Tell
us how the trading price of WorldCall Telecom Limited stock was considered in your
valuation, considering that it appears that WHI’s assets primarily consist of its
investments in WorldCall Telecom Limited through its ownership in Worldcall Services
(Private) Limited and Ferret Consulting F.Z.C.
Note 3. Acquisitions, page F-15
12.In response to prior comment 17, you state that “WTL was not acquired before the
acquisition of its parent.”  However, your response then explains that WTL’s parent was
not acquired until November 30, 2021, which is after the acquisition date of WTL
on October 18, 2017.  Therefore, it does appear that your financial statements reflect the
acquisition of WTL before the acquisition of its parents.  Tell us why this presentation is
appropriate.  Considering that your historical financial statements should reflect the
continuation of WHI, the legal acquirer, pursuant to ASC 805-40-45-1, explain why your
financial statements do not reflect WSL and Ferret Consulting investments in WTL
starting on November 30, 2021, the date WHI acquired WSL and Ferret Consulting.
Alternatively, tell us whether WSL is the predecessor entity upon the acquisitions of WSL
and Ferret Consulting and what consideration was given to presenting the predecessor
audited financial statements through November 29, 2021.
13.We note the revised disclosure in response to prior comment 18.  As previously requested,
please separately disclose each of the major classes of liabilities assumed for each of the
acquisitions.  Refer to ASC 805-20-50-1(c).
14.We note your response to prior comment 19.  As previously requested, revise to disclose
the qualitative factors that make up the goodwill.  Refer to ASC 805-30-50-1(a).
15.We note your revised disclosure in response to prior comment 20 explaining why the
Ferrett Consulting acquisition resulted in a bargain purchase gain.  Tell us how your
valuation methodologies of the assets acquired included strategic placement of Worldcall
Fiber Network, skilled workforce, synergies, favorable market conditions, and the asset’s
potential.  Explain why you believe the sellers of Ferret Consulting agreed to a purchase
price lower the fair value of its net assets that primarily included long-term loans and
long-term and short-term investments.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 April 26, 2023 Page 5
 FirstName LastName
Dana Green
GlobalTech Corp
April 26, 2023
Page 5
16.We note that WHI issued 100,000 of its shares to Ferret Consulting and 100,000 of its
shares to WSL on November 30, 2021 as consideration for each of these business
combinations.  In response to prior comment 21, you indicate that you “determined the
fair value of shares based upon the valuation of combined entities using multiple valuation
techniques such as the present value of cash flow and replacement cost etc.”  and the per
share fair value of the WHI shares issued for these acquisitions was different because the
valuation of combined entities was different.  Please tell us the specific valuation
methodology used to determine the fair value of the WHI shares issued as consideration
for the business combinations.  Provide a qualitative and quantitative explanation of the
inputs to your valuation methodology, including the specific estimates and assumptions.
Please explain how the “valuation of the combined entities” is an input to the valuation of
the WHI shares issued for these acquisitions.  That is, the consideration transferred in a
business combination should be measured at fair value the equity interests issued by the
acquirer.  Refer to ASC 805-30-30-7.
Note 20. Net Revenue, page F-33
17.You indicate in response to prior comment 24 that the connection and membership fee
entitles the customer to access the cable TV and internet services provided by the
company and it is separately identifiable within the context of the contract.  It does not
appear that this activity relates to the transfer of a promised good or service to the
customer that is capable of being distinct.  Refer to ASC 606-10-25-19 and 25-20.  As
such, it appears that this advance payment should be combined with the video or data
delivery service and recognized as revenue when those future services are provided.
Please revise.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Melissa Walsh, Senior Staff Accountant, at (202) 551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters.  Please contact Kyle Wiley, Staff
Attorney, at (202) 344-5791 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Sean Neahusan