SecProbe.io

January 17, 2025
Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Re:Alps Global Holding Pubco
Registration Statement on Form F-4
Filed December 23, 2024
File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:
            We have reviewed your registration statement and have the following comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our November 22,
2024 letter.

January 17, 2025
Page 2

Registration Statement on Form F-4 filed December 23, 2024
Background of the Business Combination, page 119
1.We note your response to prior comment 2. Please address the following:
•We note that as of March 31, 2024, Alps has not commenced operations for its
Car-T, NK Cells and blood testing segments. Please disclose if and when these
operations have started subsequent to March 31, 2024; and
•Please specifically disclose on page 122 your basis for assuming that the NK Cell,
Car-T and Mesenchymal Stem Cells treatments can be utilized under
compassionate use at your projected scale and growth rate, as well as the current
status of the pending regulatory approval.
Executive Compensation
Globalink, page 266
2.Please update your executive compensation disclosure to include compensation for
Globalink's most recently completed fiscal year. Refer to Item 402 of Regulation S-K.
Note 9. Investment in Associates, page F-83
3.We note your response to prior comment 4. Please revise and ensure that each column
of the restated financial statements are labeled as “restated” on the face of each
respective financial statement. In addition, please tell us what consideration you gave
to providing financial information pursuant to Rule 3-09 of Regulation S-X in regards
to your investment in Cilo Cybin Holdings Limited.

Exhibit 23.2, page EX-23
4.If your auditor uses one consent to cover all three sets of financial statements for three
entities, please have your auditor revise to clearly and separately refer to each entity
name, the related financial statement periods consistent with the auditor's report, and
specific dates of auditor's report including both original and updated report dates.
General
We note your response to prior comment 7 and reissue the comment in part. Your
disclosure states that you are "no longer in compliance with Nasdaq listing rules" and
that "[f]ollowing the desilting of [y]our securities from the Nasdaq, PubCo may face
increased difficulties and uncertainties in meeting the initial and continued listing
requirement of Nasdaq..." You also disclose that Globalink’s units, common stock,
public warrants and public rights are traded on the OTC Pink. Please revise to update
your disclosure to clearly disclose that Globalink’s securities have been delisted from
Nasdaq and whether you believe it is possible for Globalink to regain compliance with
the continued listing requirements of Nasdaq. Additionally, because one of the
conditions to the consummation of the business combination is the listing by Nasdaq
of the PubCo ordinary shares and PubCo warrants and satisfaction of initial and 5.

January 17, 2025
Page 3
continued listing requirements as disclosed on page 29, please update your disclosure
to address whether you expect to be able to satisfy the conditions to the consummation
of the business combination. If you plan to seek a waiver or amendment of this
closing condition, please explain this clearly along with the associated risks.
            Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391 if you have
questions regarding comments on the financial statements and related matters. Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Jenny Chen-Drake, Esq.