SecProbe.io

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                                                            December 3, 2024

Gary R. Garrabrant
Chairman and Chief Executive Officer
Captivision Inc.
298-42 Chung-buk Chungang-ro Chung-buk
Pyeong-taek, Gyounggi, Republic of Korea, 17800

       Re: Captivision Inc.
           Schedule 13D Filed by Gary R. Garrabrant
           Filed August 6, 2024
           File No. 005-94238
Dear Gary R. Garrabrant:

       We have conducted a limited review of the above-captioned filing and
have the
following comments.

        Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comments apply to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.

       After reviewing any amendment to the filing and any information provided
in
response to these comments, we may have additional comments.

Schedule 13D Filed August 6, 2024
General

1.     We note that the event reported as requiring the filing of the Schedule
13D was May
       29, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a
Schedule 13D
       within five business days after the date beneficial ownership of more
than five percent
       of a class of equity securities specified in Rule 13d-1(i)(1) was
acquired. Based on the
       May 29, 2024 event date, the Schedule 13D submitted on August 6, 2024
was not
       timely filed. Please advise us why the Schedule 13D was not filed within
the required
       five business days after the date of the acquisition.
2.     We note that the event reported as requiring the filing of the Schedule
13D was May
       29, 2024. Please advise us why you believe May 29, 2024 to be the
correct date given
       your role as owner and managing member of JGG SPAC Holdings LLC, which
serves
       as the managing member of Jaguar Global Growth Partners I, LLC, as
disclosed
       in the amendment to Schedule 13D filed by Jaguar Global Growth Partners
I, LLC on
 December 3, 2024
Page 2

       August 6, 2024. Based on the disclosure in that amendment, it appears
that you
       already had beneficial ownership over the Ordinary Shares reported in
your Schedule
       13D prior to May 29, 2024.
        We remind you that the filing person is responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.

      Please direct any questions to Brian Soares at 202-551-3690 or Nicholas
Panos at
202-551-3266.

                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Mergers &
Acquisitions
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