SecProbe.io

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 August 4, 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. 6 to Registration Statement on Form F-4
 Filed July 25, 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 July 1, 2025
letter.
 August 4, 2025
Page 2

Amendment No. 6 to Registration Statement on Form F-4 filed July 25, 2025
Risk Factors
If certain December 2024 Redeeming Stockholders choose not to return the
December 2024
Extension Overpayment Amount..., page 77

1. We note your disclosure here and elsewhere in the prospectus regarding
the December
 2024 Extension Overpayment Amount. Please revise your disclosure to
address the
 following items:

 Given that return of the December 2024 Extension Overpayment
Amount is not
 guaranteed, please clearly disclose that your assumptions that such
payment will
 be received are not guaranteed, and revise your disclosure to show
the estimated
 per share redemption price and other related disclosures under the
assumption that
 the December 2024 Extension Overpayment Amount is not returned.
Please also
 disclose the risks, if material, related to the overpayment and your
request that
 shareholders return the funds.

 You state that the Company was allowed to withdraw additional
interest from the
 Trust Account to "cover income and franchise taxes." Please quantify
the amount
 of these taxes and explain whether they have already been paid from
other sources
 or if they remain outstanding. If they have been paid, please
disclose the source of
 funds used for such payment. If they have not been paid, please
disclose whether
 you have sources of funds outside of the Trust Account available for
such
 payment, and disclose the risks, if any, related to your ability to
pay the
 outstanding amount.

 Given your disclosure that there was approximately $0.95 million
of funds in the
 Trust Account as of July 8, 2025 and that the Aggregate December
2024
 Extension Overpayment Amount was approximately $0.56 million, please
expand
 on your disclosure to explain the consequences to existing
stockholders if
 the December 2024 Extension Overpayment Amount is not returned in
whole or
 in part. Specifically, please disclose whether you intend to request
Continental
 release additional funds from the Trust Account to cover the income
and franchise
 taxes that resulted in the overpayment. In this regard, we note that
it appears
 Section 2 of the Trust Agreement provides distributions to cover
income or other
 tax obligations owed by the Company may only be made from interest
earned on
 the funds in the Trust Account and not the initial proceeds, and
Section 1(k) of the
 Trust Agreement provides that the Trustee may not disburse any
amounts from
 the Trust Account in connection with a Business Combination in the
event that the
 amount per share to be received by the redeeming Public Shareholders
is less than
 $10.15 per share (plus the amount per share deposited in the Trust
Account
 pursuant to any Extension Letter).

 Please address your proposed treatment of any portion of the
December 2024
 Extension Overpayment Amount received after the completion of a
Business
 August 4, 2025
Page 3

 Combination. Specifically, please disclose whether redeeming
stockholders would
 have any beneficial interest in such repayments or if you believe
their interest
 would be limited to any amounts distributed by the Trustee at the
time of the
 Business Combination.

 Please disclose whether and to what extent you have had
discussions with the
 Trustee regarding the December 2024 Extension Overpayment Amount. To
the
 extent material, please add risk factor disclosure addressing the
possibility that the
 Trustee may disagree with your determinations regarding the December
2024
 Redemption Payment, your interpretation of the Trust Agreement, or
your
 proposed application or treatment of any portion of the December
2024 Extension
 Overpayment Amount you ultimately receive.
Financial Statements of Cilo Cybin Holdings Limited, page F-104

2. The independent auditor s report provided on page F-119 for the year
ended March
 31, 2024 appears to be missing certain paragraphs including the opinion
and basis for
 opinion paragraphs included in the prior amendment. Please have your
auditor revise
 as necessary to ensure the auditor report(s) cover all periods included
and are placed
 appropriately.
Exhibits

3. We note your response to prior comment 2. The report date included in
the auditor's
 consent for ALPS Global Holding Pubco is not the same date as the report
date of
 June 24, 2025 provided on page F-90. Please have your auditor revise as
necessary.
 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 Katherine Bagley at 202-551-2545 with any
other
questions.

 Sincerely,

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