SecProbe.io

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 June 18, 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. 4 to Registration Statement on Form F-4
 Filed June 9, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended 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 April 23,
2025 letter.
 June 18, 2025
Page 2

Amendment No. 4 to Registration Statement on Form F-4
Financial Statements for Globalink Investment Inc. for the Period Ended March
31, 2025
Note 5. Related Party Transactions, page F-31

1. We note that you had two debt transactions in which the terms were
modified and for
 which you determined that extinguishment accounting should be used.
Specifically,
 the March 24, 2025 transaction related to advances from the affiliate of
the sponsor
 and the March 5, 2025 transaction with Public Gold Marketing Sdn Bhd.
Please help
 us better understand how you determined the appropriate accounting for
these
 transactions pursuant to ASC 470-50, including how you determined it
should be
 treated as an extinguishment. Please also address how you determined
that the gain
 should be considered a debt discount and amortized over the expected
term of the
 notes. Refer to ASC 470-50-40-2 which indicates that the difference
between the
 reacquisition price of debt and the net carrying amount of the
extinguished debt shall
 be recognized currently in income in the period of extinguishment as
losses or gains
 and identified as a separate item. This guidance also notes that gains
shall not be
 amortized to future periods and that extinguishment transactions between
related
 entities may be in essence capital transactions. Please advise.
Financial Statements of Alps Global Holding Pubco, page F-103

2. As it appears that it has been more than a year since the incorporation
of Alps Global
 Holding Pubco (Pubco) on May 14, 2024, we remind you that the Pubco is
no longer
 eligible to continue to rely on the financial statement accommodation
for a foreign
 private issuer that has been in existence less than a year to include an
audited balance
 sheet that is no more than nine months old as well as the corresponding
audited
 statements of comprehensive income, stockholders equity and cash
flows for the
 period from the date of inception to the date of the audited balance
sheet. Please revise
 to disclose the Pubco's fiscal year end and provide updated financial
statements
 accordingly.
Exhibits

3. Please include currently dated auditor consents. There appears to only
be a currently
 dated auditor consent for Globalink Investment Inc.
4. Please refile Exhibit 10.43 in proper text-searchable format. It appears
that the exhibit
 is currently filed as an image. For guidance, please refer to Item 301
of Regulation S-
 T.
 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.
 June 18, 2025
Page 3

 Sincerely,

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