SecProbe.io

CORRESP
1
filename1.htm

September 29, 2023

Via
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Attention:

    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:

    Globavend
    Holdings Ltd (CIK No. 0001978527)

    Registration
    Statement on Form F-1

    Amended
    on September 29, 2023

    File
    No. 333-274166

Ladies
and Gentlemen:

On
behalf of our client, Globavend Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
we submit to the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s request for waiver and representation under Item 8.A.4 of Form 20-F. Concurrently with
the submission of this letter, the Company is filing its amendment no.2 to the Registration Statement on Form F-1 (the “Registration
Statement”) and certain exhibits via EDGAR to the Commission.

K&L
GATES, SOLICITORS

44th
Floor Edinburgh Tower The Landmark 15 Queen’s Road Central Hong Kong

高蓋茨律師事務所
香港中環皇后大道中15號 置地廣場公爵大廈44樓

T
+852 2230 3500 F +852 2511 9515 klgates.com

    Partners

    Neil
    CAMPBELL
    甘寶靈

    William
    Z. HO
    何志淵

    Virginia
    M.L. TAM
    譚敏亮

    Sook
    Young YEU

    呂淑榮

    Michael
    K.S. CHAN
    陳國淳

    Jay
    J. LEE
    李再浩

    Choo
    Lye TAN
    陳珠萊

    Eugene
    Y.C. YEUNG

    楊睿知

    Sacha
    M. CHEONG
    文錦明

    Iris
    M.K. LEUNG
    梁美琪

    Vincent
    S.K. TSO
    曹紹基

    Jay
    C. CHIU
    邱志藩

    Scott
    D. PETERMAN
    畢德民

    Christopher
    TUNG
    董彥華

    Paul
    R. HASWELL
    何
    威

    Carolyn
    H.L. SNG
    孫慧蓮

    Frank
    VOON
    溫匯源

    Registered
    Foreign Lawyer (PRC)

    Registered
    Foreign Lawyer (California (USA))

    Amigo
    L. XIE
    謝
    嵐

    Roberta
    A. CHANG
    張
    安

Financial
Statements

Item
8.A.4 of Form 20-F requires that in the case of a company’s initial public offering, the registration statement on Form F-1 shall
contain audited financial statements as of a date not older than 12 months from the date of the filing. Nevertheless, Instruction 2 to
Item 8.A.4 of Form 20-F provides that “[a] company may comply with only the 15-month requirement in this item if the company is
able to represent that it is not required to comply with the 12-month requirement in any other jurisdiction outside the United States
and that complying with the 12-month requirement is impracticable or involves undue hardship.”

The
Company has included in the Registration Statement its audited consolidated financial statements, prepared in accordance with accounting
principles generally accepted in the United States of America, as of and for the years ended September 30, 2022 and 2021, and unaudited
interim condensed consolidated financial statements as of March 31, 2023 and for the six months ended March 31, 2023 and 2022. The Company
has included as Exhibit 99.8 to the Registration Statement Amendment No.1, a letter in which the Company makes the representations to
the Commission required by Instruction 2 to Item 8.A.4 of Form 20-F, which states that: (i) the Company is not currently a public reporting
company in any jurisdiction; (ii) the Company is not required by any jurisdiction outside the United States to comply with the 12-month
updating requirement; (iii) full compliance with Item 8.A.4 of Form 20-F at present is impracticable and involves undue hardship for
the Company; (iv) the Company does not anticipate that its audited financial statements for the fiscal year ended September 30, 2023
will be available until February 1, 2024; and (v) in no event will the Company seek effectiveness of the Registration Statement if its
audited financial statements are older than 15 months at the time of the Company’s initial public offering.

    Very
    truly yours,

    /s/
    Virginia Tam

    Name:
    Virginia
    Tam

    Title:

    Partner