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CORRESP
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SCHLUETER
& ASSOCIATES, P.C.

5655
South Yosemite Street, Suite 350

Greenwood
Village, Colorado 80111

Telephone:
1-303 292-3883

Facsimile:
1-303 296-8880

hfs@schlueterintl.com

August
27, 2024

VIA
EDGAR

Registration
Statement

U.S.
Securities and Exchange Commission

100
F. Street, N.E.

Washington,
DC 20549

    Re:
    BeLive
    Holdings

    Amendment
    No. 1 to Registration Statement on Form F-1

    Filed
    on August 15, 2024

    File
    No. 333-280739

Dear
Ms. Veator:

We
represent BeLive Holdings (“Registrant” and “Company”) as U.S. counsel. We are submitting herewith Amendment
No.2 to the Registration Statement on Form F-1 (the “Registration Statement”) which is being filed via EDGAR simultaneously
with this transmittal letter.

The
purpose of this letter is to respond to the comment letter dated August 23, 2024, from the Division of Corporation Finance, Office of
Energy & Transportation (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission” or
“SEC”) relating to the above-referenced Registration Statement. For your convenience, the comment has been reproduced below,
followed by the Registrant’s response.

Amendment
No. 1 to Registration Statement on Form F-1

General

 1. To
                                            the extent that the resale offering will not take place until the ordinary shares are listed
                                            on Nasdaq, please make this clear on the public offering prospectus cover page. As currently
                                            drafted, it appears that the primary and resale offering are part of the same firm commitment
                                            offering and will be conducted simultaneously. In addition, please remove the statement on
                                            the resale prospectus cover page stating that prior to the offering there has been no public
                                            market for the ordinary shares, as at the time shares are sold in the resale offering the
                                            primary offering will be complete and there will already be a public market for the shares.

Response:

Disclosure
revised to clarify that the resale offering is not part of the firm commitment public offering and will not take place until the ordinary
shares are listed on Nasdaq.

See
Prospectus Cover page and Resale Prospectus Cover page.

On
behalf of the Company, we appreciate your attention to this matter. If you have any questions or wish to discuss any matters with respect
to this filing, please do not hesitate to contact me at (303) 868-3382 (email: hfs@schlueterintl.com) or my colleague Celia Velletri
at (303) 907-4842 (email: cv@schlueterintl.com). Regarding accounting matters, you may contact Chia Lei Kuan of Onestop Assurance PAC
at +65 9499 3768 (email: leikuanchia@one-stop-ca.com) in respect of any accounting issues.

Thanks
in advance for your cooperation in connection with this matter.

    Sincerely,

    /s/ Henry
    F. Schlueter

    cc:
    BeLive Holdings

    R.F. Lafferty & Co., Inc.

    Lucosky Brookman LLP

    Onestop Assurance PAC