SecProbe.io

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 April 11, 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
 Amendment No. 1 to Registration Statement on Form F-4
 Filed April 1, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended registration statement and have the
following
comments.

 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 January 17,
2025 letter.
 April 11, 2025
Page 2

Amendment No. 1 to Registration Statement on Form F-4 filed April 1, 2025
Availability and terms of PIPE Investment, page 34

1. We note your disclosure on page 34 that the Board negotiated the terms
of the PIPE
 Investment with Alps and mutually agreed that the PIPE Investment would
be used
 for PubCo s working capital after the Business Combination. Please
revise your filing
 to include risk factor disclosure that addresses how the changes to the
PIPE
 Investment could impact PubCo s ability to operate its business after
the closing.
Background of the Business Combination, page 126

2. We note your disclosure that the verbal commitment to securing PIPE
Investments
 was what the Globalink Board considered as the primary basis for the
pre-money
 valuation of Alps of approximately $1.6 billion and that the Board
placed a high
 significance weighting on the availability and terms of the PIPE
Investments in
 approving the transaction. Your disclosure of the dollar amount of the
PIPE
 Investments that the Board considered when determining to approve the
 transaction was reduced from US$40.23 million to US$3.48 million. This
appears to
 reflect the smaller available PIPE investment after the termination of
two of the
 Subscription Agreements in March 2025. Given that the Board approved the
 transaction in January 2024, please clarify the information the Board
relied upon at
 the time it made its determination to approve the transaction. In this
regard, we note
 your statement on page 129 that the Board "considered the availability
and terms of
 the PIPE Investment prior to approving the Business Combination" and
placed a "high
 significance weighing on this factor." Additionally, please explain what
consideration
 the Board gave to reapproving or reevaluating their determination that
the Business
 Combination is in the best interests of, and advisable to, the Globalink
stockholders
 following the termination of the vast majority of the PIPE Investments
and the
 removal of the Earnout Shares from the consideration payable to
Globalink
 shareholders.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
ALPS
Cost of sales, page 236

3. Here you discussed three partners to provide specialized medical and
aesthetic
 services under profit sharing arrangement. Please update your related
revenue
 recognition accounting policies for principal versus agent including at
page F-72 as it
 currently only refers to hair implant services.
Financial Statements of Alp Life Sciences Inc., page F-116

4. In regards to the financial statements for Alps Life Science Inc, please
address the
 following:
 We note that for the unaudited financial statements for the six
months ended
 September 30, 2024 you are also presenting financial statements for
the six
 April 11, 2025
Page 3

 months ended September 30, 2023, which is prior to inception. Please
clarify in
 your disclosures whether these are the financial statements of Alps
Global
 Holding Berhad. Please also address what consideration you gave as
to whether
 Alps Global Holding Berhad should be considered the predecessor
entity pursuant
 to Rule 405 of Regulation C in the audited financial statements.

 Please address what consideration you gave to Item 8.A.4 of the
Form 20-F in
 determining when the audited annual financial statements should be
updated.
Financial Statements of Cilo Cybin Holdings Limited, page F-180

5. Please include the independent auditor s report and consent for the
financial
 statements of Cilo Cybin Holdings Limited.
Exhibit 23.2, page EX-23

6. We note your response to previous comment four. Please address the
following:
 As previously requested, please have your auditor revise the consent
to separately
 refer to the specific dates of the auditor s report including both
original and
 updated report dates. For example for the financial statements of Alps
Global
 Holding Berhad, the consent should refer to the various specific
report dates
 which include June 18, 2024, August 12, 2024, and December 4, 2024.
 The consent for ALPS Global Holding Pubco does not appear to refer
to the
 appropriate report date. Please have your auditor revise as necessary.
General

7. We note your response to previous comment 5 and your revised disclosure
that while
 you do not believe it is possible for Globalink to regain compliance
with the continued
 listing requirements of Nasdaq or otherwise get listed on Nasdaq again
prior to the
 Closing, you still expect to be able to satisfy the conditions to the
consummation of
 the Business Combination and do not expect to seek a waiver or amendment
of these
 closing conditions. Notwithstanding the possibility of PubCo's
securities receiving
 listing approval while Globalink's securities remain delisted, please
explain whether
 the continued delisting of Globalink's securities would prevent you from
satisfying the
 closing conditions under the Business Combination Agreement.
Specifically, we note
 that Section 6.10 of the Amended and Restated Merger Agreement appears
to include
 a representation that Globalink's securities are listed on Nasdaq and
Section 10.3(b)
 appears to require this representation to be brought down as of the
Closing Date in all
 material respects.
 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.
 April 11, 2025
Page 4

 Sincerely,

 Division of Corporation Finance
 Office of Industrial Applications and
 Services
cc: Jenny Chen-Drake, Esq.
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