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CORRESP
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BeLive
Holdings

26A
Ann Siang Rad

#03-00

Singapore
069706

Telephone:
+(65) 9090 5788

January
21, 2025

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
DC 20549

    Attention:
    Lauren
    Pierce

    Matthew
    Derby

    Re:

    BeLive
    Holdings Registration Statement on Form F-1 (File No. 333-280739)

    CIK
    No. 1982448

    Request
    for Waiver and Representation under Item 8.A.4 of Form 20-F

Ladies
and Gentlemen:

The
undersigned, BeLive Holdings, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
is submitting this letter to the U.S. Securities and Exchange Commission (the “Commission”) in connection with registration
statement on Form F-1 (File No: 333-280739) filed with the Commission on the date hereof (as amended, the “Registration Statement”),
relating to a proposed initial public offering and listing in the United States of the Company’s ordinary shares.

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, as of and for the fiscal years ended December 31, 2023, and 2022, and unaudited consolidated
interim financial statements as of and for the six-month periods ended June 30, 2024, and 2023.

The
Company respectfully requests that the Commission waive the requirement of Item 8.A.4 of Form 20-F, which states that in the case of
a company’s initial public offering, the registration statement on Form F-1 must contain audited financial statements of a date
not older than 12 months from the date of filing (the “12-Month Requirement”). See also Division of Corporation
Finance, Financial Reporting Manual, Section 6220.3.

The
Company is submitting this waiver request pursuant to Instruction 2 to Item 8.A.4 of Form 20-F, which provides that the Commission will
waive the 12-Month Requirement “in cases where the company is able to represent adequately to us that it is not required to comply
with this requirement in any other jurisdiction outside the United States and that complying with this requirement is impracticable or
involves undue hardship.” See also the 2004 release entitled International Reporting and Disclosure Issues in the Division
of Corporation Finance (available on the Commission’s website at www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm)
by the staff of the Division of Corporation Finance of the Commission at Section III.B.c, in which the staff notes that:

“...
the instruction indicates that the staff will waive the 12-month requirement where it is not applicable in the registrant’s other
filing jurisdictions and is impracticable or involves undue hardship. As a result, we expect that the vast majority of IPOs will be subject
only to the 15-month rule. The only times that we anticipate audited financial statements will be filed under the 12-month rule are when
the registrant must comply with the rule in another jurisdiction, or when those audited financial statements are otherwise readily available.”

In
connection with this waiver request, the Company represents to the Commission that:

 1. The
                                            Company is not currently a public reporting company in any jurisdiction.

 2. The
                                            Company is not required by any jurisdiction outside the United States to prepare financial
                                            statements audited under any generally accepted auditing standards for any interim period.

 3. Full
                                            compliance with Item 8.A.4 of Form 20-F at present is impracticable and involves undue hardship
                                            for the Company.

 4. The
                                            Company does not anticipate that its audited financial statements for the fiscal year ended
                                            December 31, 2024, will be available before April 30, 2025.

 5. 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.

The
Company will file this letter as an exhibit to the Registration Statement pursuant to Instruction 2 to Item 8.A.4 of Form 20-F.

Very
truly yours,

  /s/
                                        Kenneth Teck Chuan Tan

Name:  Kenneth Teck Chuan
Tan

Title: Chief Executive
Officer (principal Executive Officer)