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United States securities and exchange commission logo
May 30, 2023
Dana Green
Chief Executive Officer
GlobalTech Corp
3550 Barron Way, Suite 13a
Reno, NV 89511
Re:GlobalTech Corp
Form 10-K for the Fiscal Year Ended December 31, 2022
Form 10-Q for the Quarterly Period Ended March 31, 2023
File No. 000-56482
Dear Dana Green:
            We have reviewed your filing 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
April 26, 2023 letter.
Form 10-Q for the quarterly period ended March 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Update on plans:, page 38
1.Please revise your disclosure to clarify what services are included in the "full bouquet of
banking services."
2.We note your response to prior comment 3; however, you have not included any
discussion of the costs incurred to date to develop your blockchain network and the costs
expected to be incurred in future periods to commercialize the network.  Please revise
accordingly.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 May 30, 2023 Page 2
 FirstName LastName
Dana Green
GlobalTech Corp
May 30, 2023
Page 2
3.We note your response to prior comment 6 and reissue it. We note that you intend to
utilize smart contracts for your target services. In future filings, 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.
Controls and Procedures, page 42
4.Please revise to disclose the conclusion of your principal executive and principal financial
officer regarding the effectiveness of your disclosure controls and procedures as of the end
of the period covered by the report.  Refer to Item 307 of Regulation S-K.
Form 10-K for the fiscal year ended December 31, 2022
Description of Business
General Information
Form and Year of Organization, page 4
5.We note your response to prior comment 1.  As previously requested, please reconcile the
ownership structure disclosed in WorldCall Public’s financials to the corporate structure
presented in your filing.  Also reconcile to the disclosures in the notes to financials on
page F-9 and on page 9 of your Form 10-Q for the quarterly period ended March 31, 2023
indicating you owned 55.2% and 59.3%, respectively, of WorldCall Telecom Limited.
You also disclose that WorldCALL Private and FZC own 14.7% and 40.5%, respectively,
of WorldCALL Telecom Limited.  Provide us with your complete computation of the
ownership structure of WorldCall Telecom Limited.  We note the current conversion ratio
of the Convertible Preference Shares provided in your response.  However, your
disclosure on page F-32 indicates these shares were issued to Oman Telecommunications
Company.  Considering that WorldCALL Private holds 854,914,152 shares and FZC
holds 313,128,042 shares, respectively, of WorldCall Telecom Limited, it appears based
on our computation that WorldCALL Private and FZC appear to only own 15.8% and
5.8%, respectively, of WorldCALL Telecom Limited.
Consolidated Statement of Cash Flows for the Years Ended December 31, 2022 and 2021, page
F-6
6.Your response to prior comment 9 indicates that the cash flows used for the issuance of
long-term loan in 2021 relates to loans to employees and advances to vendors for the
provision of goods and services and it should have been classified as an operating
activity.  Please revise to restate the statement of cash flow for the year ended December
31, 2021.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 May 30, 2023 Page 3
 FirstName LastName
Dana Green
GlobalTech Corp
May 30, 2023
Page 3
Notes to Consolidated Financial Statements
Note 2. Basis of Preparation of Consolidated Financial Statements
Business Combinations, page F-11
7.In response to prior comment 11, you indicate that the trading price of WTL stock was not
used to determine the fair value of the WHI shares effectively transferred because the
replacement cost of WTL’s fiber network is substantially higher than the market
capitalization of WTL.  It does not appear that your valuation complies with the guidance
in ASC 820-10-35.  That is, the fair value measurement should assume that the transaction
takes place either in the principal market for the asset or liability or, in the absence of a
principal market, in the most advantageous market for the asset or liability.  In addition,
the valuation technique should maximize the use of relevant observable inputs and
minimize the use of unobservable inputs.  Please revise to consider the trading price of
WTL stock in your valuation.  In this regard, you indicate in your response that the value
of WHI is largely driven by the value of its investments in WTL.
8.We note the disclosure added on page 11 of your Form 10-Q for the quarterly period
ended March 31, 2023 in response to prior comment 10.  Please revise to account for the
excess of the fair value of the consideration effectively transferred over the fair value of
EBI’s net asset as goodwill.  Refer to the example in ASC 805-40-55-12.  In addition, as
previously requested, include a qualitative description of the factors that make up the
goodwill recognized.
Note 3. Acquisitions, page F-15
9.We reissue prior comment 12, as it is not clear how ASC 810-10-45-10 supports the basis
for your financial reporting of the acquisitions and the response did not sufficiently
address our concerns.  In your April 4, 2023 response to 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 of 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.

 FirstName LastNameDana Green
 Comapany NameGlobalTech Corp
 May 30, 2023 Page 4
 FirstName LastName
Dana Green
GlobalTech Corp
May 30, 2023
Page 4
10.We note your response to prior comment 16 indicating that you included the fair value of
the assets and liabilities acquired in the business combination in your valuation of the
consideration transferred.  As previously noted, the consideration transferred in a business
combination should be measured at fair value of the equity interests issued by the
acquirer.  Please revise your valuation of the fair value of the WHI shares issued as
consideration for the business combinations.  Refer to ASC 805-30-30-7.  Also note that
there is no basis for the valuation of the shares to be different for acquisitions occurring on
the same date.
11.For the Ferrett Consulting acquisition, as previously requested in comment 20 of our letter
dated February 9, 2023 and considering the explanation provided in response to prior
comment 15, please revise your description of the reasons why the transaction resulted in
a bargain purchase gain.
            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