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December 18, 2023
Kenneth Teck Chuan Tan
Chief Executive Officer
BeLive Holdings
29 Media Circle
Mediapolis 09-06
Singapore 138565
Re:BeLive Holdings
Amendment No.2 to Draft Registration Statement on Form F-1
Submitted December 4, 2023
CIK No. 0001982448
Dear Kenneth Teck Chuan Tan:
            We have reviewed your amended draft registration statement and have the following
comments.
            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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our October 13,
2023 letter.
Draft Registration Statement filed December 4, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operation, page
43
1.We note your response to prior comment 1 and reissue in part. Because you identify your
customer's ability to increase their own customer base as a key performance metric, please
revise to quantify increases and discuss historical trends in your customers' customer
bases for the periods presented. To the extent such data is not tracked, please clarify how
management uses increases in your customers' customer bases as a key performance
metric in the evaluation of your business.

 FirstName LastNameKenneth Teck Chuan Tan
 Comapany NameBeLive Holdings
 December 18, 2023 Page 2
 FirstName LastNameKenneth Teck Chuan Tan
BeLive Holdings
December 18, 2023
Page 2
Liquidity and Capital Resources, page 49
2.We note your revised disclosure indicates that none of the net assets of your subsidiary in
Singapore were restricted net assets as such net assets do not form part of the dividends (if
any) to be distributed to its respective shareholders. Clarify if you can currently distribute
the net assets of your Singapore subsidiary to the parent company through dividends or
other means. If not, it does not appear that they should be described as unrestricted. Please
revise your disclosure to describe the specific restrictions with respect to your ability to
distribute the net assets to the parent company.
Consolidated Financial Statements for the Years Ended December 31, 2022 and 2021
Notes to the Consolidated Financial Statements
2. Summary of Significant Accounting Policies
(q) Revenue Recognition, page F-28
3.Clarify how you determine it is probable that you will collect the consideration to which
you are entitled and it is appropriate to recognize revenue. Refer to paragraph 9(e) of
IFRS 15. Further, based on your response to prior comment 6, it appears that there may
have been significant changes in your customers’ ability to pay. Clarify why it is
appropriate to continue to recognize revenue for any customers who are in default, rather
than recognize a liability until it is probable that you will collect the consideration. Refer
to paragraph 13 of IFRS 15.
Consolidated Financial Statements for the Six Months Ended June 30, 2023 and 2022
12. Trade and Other Receivables, page F-78
4.Your response to prior comment 6 indicates that the entire balance that was greater than
90 days past due as of December 31, 2022 remains uncollected through the current date
and has been fully reserved. Clarify your disclosures to describe how you took into
account this default rate in determining your loss allowance for your remaining
receivables. Clarify whether your remaining receivables include sales to the same
customers that are included in the fully reserved balances and, if so, why it is appropriate
that these balances are not fully reserved. Please also disclose your trade receivables by
aging category as of the end of the most recent reporting period and the associated loss
allowance for each category. Clarify how you determined your expected credit loss for
each category taking into consideration your historical default rates and past due status.
            Please contact Laura Veator at 202-551-3716 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters. Please
contact Lauren Pierce at 202-551-3887 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,

 FirstName LastNameKenneth Teck Chuan Tan
 Comapany NameBeLive Holdings
 December 18, 2023 Page 3
 FirstName LastName
Kenneth Teck Chuan Tan
BeLive Holdings
December 18, 2023
Page 3
Division of Corporation Finance
Office of Technology
cc:       Henry Schlueter