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CORRESP Filing

GCL Global Holdings Ltd
Date: Sept. 4, 2025 · CIK: 0002002045 · Accession: 0001213900-25-084545

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File numbers found in text: 333-290032

Date
September 4, 2025
Author
Sebastian Toke
Form
CORRESP
Company
GCL Global Holdings Ltd

Letter

VIA EDGAR Division of Corporation Finance Office of Technology Attn: Aliya Ishmukhamedova Re: GCL Global Holdings Ltd (the "Company") Registration Statement on Form F-1 (File No. 333-290032) (the "Registration Statement")

Dear Ms. Ishmukhamedova:

The Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4:30 p.m. on September 8, 2025, or as soon thereafter as practicable.

The Company hereby acknowledges that:

● Should the Securities and Exchange Commission (the "Commission") or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

● The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

● The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[ Signature page follows ]

Very truly yours,
GCL Global Holdings Ltd

Show Raw Text
CORRESP
 1
 filename1.htm

 GCL Global Holdings Ltd

 29 Tai Seng Avenue #02-01

 Natural Cool Lifestyle Hub

 Singapore 534119

 September 4, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Technology

 Washington, D.C. 20549

 Attn: Aliya Ishmukhamedova

 Re: GCL Global Holdings Ltd (the "Company")

 Registration Statement on Form F-1

 (File No. 333-290032) (the "Registration
Statement")

 Dear Ms. Ishmukhamedova:

 The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the above-referenced Registration
Statement so that such Registration Statement will become effective as of 4:30 p.m. on September 8, 2025, or as soon thereafter as practicable.

 The Company hereby acknowledges
that:

 ● Should the Securities and Exchange Commission (the "Commission") or the Staff, acting pursuant
to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with
respect to the Registration Statement;

 ● The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration
Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the
Registration Statement; and

 ● The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States.

 [ Signature page follows ]

 Very truly yours,

 GCL Global Holdings Ltd

 By:
 /s/ Sebastian Toke

 Name:
 Sebastian Toke

 Title:
 Group Chief Executive Officer