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United States securities and exchange commission logo
December 14, 2023
Stephen Jian Zhu
Chief Executive Officer
Able View Global Inc.
Floor 16, Dushi Headquarters Building
No. 168, Middle Xizang Road
Shanghai, 200001
People’s Republic of China
Re:Able View Global Inc.
Registration Statement on Form F-1
Filed November 17, 2023
File No. 333-275626
Dear Stephen Jian Zhu:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1, Filed November 17, 2023
Cover Page
1.For each of the shares being registered for resale, disclose the price that the selling
securityholders paid for such shares.
2.We note the significant number of redemptions of your Class B Ordinary Shares in
connection with your business combination and that the shares being registered for resale
will constitute a considerable percentage of your public float. We also note that all of the
shares being registered for resale were purchased by the selling securityholders for prices
considerably below the current market price of the Class B Ordinary Shares. Highlight the
significant negative impact sales of shares on this registration statement could have on the
public trading price of the Class B Ordinary Share.

 FirstName LastNameStephen Jian Zhu
 Comapany NameAble View Global Inc.
 December 14, 2023 Page 2
 FirstName LastNameStephen Jian Zhu
Able View Global Inc.
December 14, 2023
Page 2
3.We note your disclosure about the legal and operational risks associated with being based
in or having the majority of the company’s operations in China. Please provide cross-
references to your detailed discussion of these risks, similar to the disclosure included in
your registration statement on Form F-4, filed June 26, 2023.
Summary, page 1
4.We note that in your Form F-4 registration statement, filed June 26, 2023, you included
disclosure describing the legal and operational risks associated with being based in or
having the majority of the company’s operations in China. Please include similar
disclosure in this registration statement, including but not limited to, disclosure on
required permissions and permits to operate your business in mainland China and PRC
regulations on transferring cash to and from your China based subsidiaries.
Risk Factors
Risks Related to Able View's Business and Industry
Our ability to raise capital in the future may be limited, and our failure to raise capital when
needed could prevent us from growing., page 28
5.Please expand your discussion here to reflect the fact that this offering involves the
potential sale of a substantial portion of shares for resale and discuss how such sales could
impact the market price of the company’s common stock. Your discussion should
highlight the fact that Misters Wenming Mu, Jing Tang and Jun Wang, beneficial owners
of over 25% of your outstanding shares, will be able to sell all of their shares for so long
as the registration statement of which this prospectus forms a part is available for use.
Risks Related to Ownership of Able View's Securities
Future sales or perceived sales of substantial amounts of our securities in the public market could
have a material adverse effect on..., page 49
6.Please amend this risk factor, or include an additional risk factor, to highlight the negative
pressure potential sales of shares pursuant to this registration statement could have on the
public trading price of the Class B Ordinary Shares. To illustrate this risk, disclose the
purchase price of the securities being registered for resale and the percentage that these
shares currently represent of the total number of shares outstanding. Also disclose that
even though the current trading price is below the SPAC IPO price, the private investors
have an incentive to sell because they will still profit on sales because of the lower price
that they purchased their shares than the public investors.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
74
7.We note that the projected revenues for 2023 were $267.6 million, as set forth in the
unaudited prospective financial information management prepared and provided to the
Board, the company’s financial advisors and HMAC in connection with the evaluation of

 FirstName LastNameStephen Jian Zhu
 Comapany NameAble View Global Inc.
 December 14, 2023 Page 3
 FirstName LastNameStephen Jian Zhu
Able View Global Inc.
December 14, 2023
Page 3
the Business Combination. We also note that your actual revenues for the Six Months
Ended June 30, 2023, was approximately $81.6 million. It appears that you will miss your
2023 revenue projection. Please update your disclosure in Liquidity and Capital
Resources, and elsewhere, to provide updated information about the company’s financial
position and further risks to the business operations and liquidity in light of these
circumstances.
Liquidity and Capital Resources, page 87
8.In light of the significant number of redemptions and the unlikelihood that the company
will receive significant proceeds from exercises of the warrants because of the disparity
between the exercise price of the warrants and the current trading price of the Class B
Ordinary Shares, expand your discussion of capital resources to address any changes in
the company’s liquidity position since the business combination. If the company is likely
to have to seek additional capital, discuss the effect of this offering on the company’s
ability to raise additional capital.
General
9.Revise your prospectus to disclose the price that each selling securityholder paid for the
shares being registered for resale. Highlight any differences in the current trading price,
the prices that the selling securityholders acquired their shares, and the price that the
public securityholders acquired their shares. Disclose that while the selling
securityholders may experience a positive rate of return based on the current trading price,
the public securityholders may not experience a similar rate of return on the securities
they purchased due to differences in the purchase prices and the current trading price.
Please also disclose the potential profit the selling securityholders will earn based on the
current trading price. Lastly, please include appropriate risk factor disclosure.
10.Please revise to update your disclosures throughout the filing and address areas that
appear to need updating or that present inconsistencies. Non-exclusive examples of areas
where disclosure should be updated are as follows:
•You state on page 49 that "[f]uture" sales of your securities may cause the market
price of your securities to be adversely affected. This statement should be updated
given that this prospectus is facilitating those sales.
•You state on page 71 that Mr. Zhu is "expected" to become Chairman of the Pubco
Board immediately after closing. Please update this disclosure if Mr. Zhu has indeed
become the Chairman of the Pubco Board.
            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.

 FirstName LastNameStephen Jian Zhu
 Comapany NameAble View Global Inc.
 December 14, 2023 Page 4
 FirstName LastName
Stephen Jian Zhu
Able View Global Inc.
December 14, 2023
Page 4
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Elizabeth Chen