SecProbe.io

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 April
25, 2025

 Division
of Corporation Finance

 Office
of Industrial Applications and Services

 U.S.
Securities & Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 Attention:
 Conlon
 Danberg

 Lauren
 Nguyen
 Nudrat
 Salik

 Li
 Xiao

 Re:
 Alps
 Global Holding Pubco

 Amendment
 No. 2 to Registration Statement on Form F-4
 Filed
 April 18, 2025

 File
 No. 333-284035

 Ladies
and Gentlemen:

 On
behalf of Alps Global Holding Pubco (the " Company ," " we ," " our ," or " us "),
we submit this letter in response to the comments provided by the staff (the " Staff ") of the U.S. Securities and Exchange
Commission (the " Commission ") in its letter dated April 23, 2025 (the " Comment Letter ") with respect
to the Amendment No. 2 to the Registration Statement on Form F-4 filed with the Commission on April 18, 2025 (the " Amendment
No. 2 ") through EDGAR.

 For
your convenience, we have repeated each of the Staff's comments below in bold text, followed by the Company's responses.
We have included page references in the Amendment No. 1 where the language addressing a particular comment appears. Capitalized terms
used but not defined herein have the meanings set forth in the Amendment No. 2.

 The
Company has revised the Amendment No. 2 in response to the Staff's comments and is concurrently submitting the Amendment No. 3
to the Registration Statement on Form F-4 (the " Amendment No. 3 ") with this letter, which reflects these revisions
and updates and clarifies certain other information.

 Amendment
No. 2 to Form F-4 filed April 18, 2025

 Financial
Statements of Alp Life Sciences Inc., page 296

 1.
 We
 note your response to prior comment 4. Please address your consideration of Item 8.A.4 of Form 20-F in determining when the audited
 annual financial statements should be updated. Specifically this guidance states that the audited financial statements shall be as
 of a date not older than 12 months in the case of the company's initial public offering. In addition Instruction 2 to this
 item further states that the additional requirement that financial statements be no older than 12 months at the date of filing applies
 only in those limited cases where a nonpublic company is registering its initial public offering of securities. A company may comply
 with only the 15-month requirement in this item if the company is able to represent that it is not required to comply with the 12-month
 requirement in any other jurisdiction outside the United States and that complying with the 12-month requirement is impracticable
 or involves undue hardship. This representation should be filed as an exhibit to the registration statement.

 Response:
In response to the Staff's comment, we respectfully advise the Staff that the Company is not required to comply with the requirement
provided in Item 8.A.4 of the Form 20-F in any other jurisdiction outside the United States and that complying with the requirement
is impracticable or involves undue hardship. We have included with Amendment No. 3 a request for waiver filed as Exhibit
99.8.

 General

 2.
 We
 note your response to prior comment 2. Please provide a description of the final fairness opinion and explain whether there are material
 differences between the draft and final fairness opinions. We note your disclosure on page 130.

 Response:
In response to the Staff's comment, we have filed the final fairness opinion as Annex I to Amendment No.3. There are no differences
between the draft and the final fairness opinions.

 Very
 truly yours,

 /s/
 Say Leong Lim

 Say
 Leong Lim

 Chief
 Executive Officer and
 Chairman of the Board of Directors of Globalink Investment Inc.

 Very
 truly yours,

 /s/
 Tham Seng Kong

 Tham
 Seng Kong

 Chief
 Executive Officer of Alps Global Holding Pubco