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Correspondence 0001493152-25-008156 from BeLive Holdings (BLIV)

BeLive Holdings
Date: Feb. 25, 2025 · CIK: 0001982448 · Accession: 0001493152-25-008156

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File numbers found in text: 333-280739

Date
Feb. 25, 2025
Author
/s/ Henry
Form
CORRESP
Company
BeLive Holdings

Letter

VIA EDGAR Re: BeLive Holdings Amendment No. 7 to Registration Statement on Form F-1 Filed on February 18, 2025 File No. 333-280739

Dear Ms. Veator:

We represent BeLive Holdings (“Registrant” and “Company”) as U.S. counsel. We are submitting herewith Amendment No. 8 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 verbal comment received on February 24, 2025, 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. 7 to Registration Statement on Form F-1

1. Please update the Executive Compensation table to include full year 2024 information.

Response:

The Executive Compensation table has been updated to include full year 2024 information.

See pages 87 and 89.

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

Show Raw Text
CORRESP
1
filename1.htm

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

February
25, 2025

VIA
EDGAR

Registration
Statement

U.S.
Securities and Exchange Commission

100
F. Street, N.E.

Washington,
DC 20549

    Re:
    BeLive
    Holdings

    Amendment
    No. 7 to Registration Statement on Form F-1

    Filed
    on February 18, 2025

    File
    No. 333-280739

Dear
Ms. Veator:

We
represent BeLive Holdings (“Registrant” and “Company”) as U.S. counsel. We are submitting herewith Amendment
No. 8 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 verbal comment received on February 24, 2025, 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. 7 to Registration Statement on Form F-1

    1.
    Please
    update the Executive Compensation table to include full year 2024 information.

Response:

The
Executive Compensation table has been updated to include full year 2024 information.

See
pages 87 and 89.

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