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August 18, 2023
Wai Yiu Yau
Chief Executive Officer
Globavend Holdings Ltd
Office 1401, Level 14, 197 St Georges Tce,
Perth, WA 6000,
Australia
Re:Globavend Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted August 4, 2023
CIK No. 0001978527
Dear Wai Yiu Yau:
            We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted August 4, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 60
1.In response to prior comment 3, you disclosed the amounts of the foreign exchange gains
for the years ended September 30, 2021 and 2022.  We re-issue the comment.  Please
revise your discussion, to the extent material to an understanding of your results of
operations, to quantify for each period presented the impact that foreign currency
movement had on specific line items of revenue and expenses. Refer to Item 5.A.3. of
Form 20-F.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 August 18, 2023 Page 2
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
August 18, 2023
Page 2
Cash Flow
Operating Activities, page 66
2.We note the additional disclosure added in response to prior comment 7.  We re-issue the
comment. Please revise your discussion of operating cash flow to discuss the underlying
drivers for the material changes of the components of the operating cash flows between
periods. Refer to SEC Release No. 33-8350, Section IV for guidance.
Our Competitive Strengths, page 70
3.We note your response to prior comment 8. You indicate that you purchased shipping
solution software in 2019 that was modified internally to meet the company's internal
need. However, your disclosure on page 71 indicates that your software is "self-
developed" and you "have internally developed [your] own proprietary all-in-one shipping
solution." Please revise this disclosure to indicate that you purchased software and
internally modified such software.
Our Strategies, page 72
4.We note your response to prior comment 9 and reissue it in part. You state here that you
plan to further expand your "logistics network and business presence in Australia and
New Zealand" and at page 24 that you "intend to hire additional staff in Hong Kong and
Australia to facilitate [your] expansion plans."  Please further discuss your plans to expand
your business in Hong Kong and New Zealand.
MANAGEMENT
Employment Agreements and Indemnification Agreements, page 94
5.We note your response to prior comment 10, including your having filed, at Exhibit
10.2, the employment agreement entered with Mr. Wai Yiu Yau, your Chief Executive
Officer. Please update your disclosure in this section to reflect the agreement with Mr.
Wai Yiu Yau and describe its material terms.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 August 18, 2023 Page 3
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
August 18, 2023
Page 3
            You may contact Steve Lo, Staff Accountant, at (202) 551-3394 or Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding comments on the
financial statements and related matters. Please contact Liz Packebusch, Staff Attorney, at (202)
551-8749 or Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Virginia Tam