SecProbe.io

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 July
24, 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. 5 to Registration Statement on Form F-4
 Filed
 June 27, 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 July 1, 2025 (the " Comment Letter ") with respect
to the Amendment No. 5 to the Registration Statement on Form F-4 filed with the Commission on June 27, 2025 (the " Amendment
No. 5 ") 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. 5 where the language addressing a particular comment appears. Capitalized terms
used but not defined herein have the meanings set forth in the Amendment No. 5.

 The
Company has revised the Amendment No. 5 in response to the Staff's comments and is concurrently submitting the Amendment No. 6
to the Registration Statement on Form F-4 (the " Amendment No. 6 ") with this letter, which reflects these revisions
and updates and clarifies certain other information.

 Amendment
No. 5 to Form F-4 Filed June 27, 2025

 Financial
Statements for Globalink Investment Inc. for the Period Ended March 31, 2025

 Note
5. Related Party Transactions, page F-31

 1.
 We
 note your response to comment 1. As previously requested, please also address how you determined that the gain should be considered
 a debt discount and amortized over the expected term of the notes. Note that ASC 470-50-40-13 states that if extinguishment accounting
 is applied, the new debt instrument shall be initially recorded at fair value. ASC 470-50-40-2 also specifically states that gains
 and losses from extinguished debt shall not be amortized to future periods.

 Response:
The Company acknowledges the Staff's comment and respectfully advises the Staff that the Company recognized an extinguishment
gain within equity pursuant with ASC 470-50-40-2, which states:

 A
difference between the reacquisition price of debt and the net carrying amount of the extinguished debt shall be recognized currently
in income of the period of extinguishment as losses or gains and identified as a separate item. Gains and losses shall not be amortized
to future periods. If upon extinguishment of debt the parties also exchange unstated (or stated) rights or privileges, the portion of
the consideration exchanged allocable to such unstated (or stated) rights or privileges shall be given appropriate accounting recognition.
Moreover, extinguishment transactions between related entities may be in essence capital transactions.

 The
Company recognized an extinguishment gain for the excess of the net carrying value of the extinguished debt over the fair value of the
new debt (representative of the reacquisition price of the extinguished debt). The full amount of the extinguishment gain is recognized
within equity instead of income/loss because the holder is a related party.

 The
Company subsequently accounted for the new debt in accordance with ASC 470-50-40-13, which states:

 If
it is determined that the original and new debt instruments are substantially different, the new debt instrument shall be initially recorded
at fair value, and that amount shall be used to determine the debt extinguishment gain or loss to be recognized and the effective rate
of the new instrument.

 As
the original and new debt instruments are concluded to be substantially different, the new debt is initially recognized at fair value
(representative of the reacquisition price of the extinguished debt) and that amount was used to determine the effective interest rate
of the new debt. As the initial carrying amount of the new debt initially recognized differs from the principal amount due at maturity,
we recorded effective interest on the new debt for this difference. Accordingly, the carrying amount of the new debt is accreted to its
principal amount using the interest method as prescribed in ASC 835 and the carrying amount of the new debt at any point of its remaining
contractual term is equal to the sum of the (i) initial carrying amount plus (ii) effective interest.

 2.
 We
 note your response to comment 3. Please provide a currently dated auditor consent for ALPS Global Holding Pubco for the audited financial
 statements as of March 31, 2025 for which the audit report is dated June 24, 2025.

 Response:
In response to the Staff's comment, we filed a currently dated auditor consent as an exhibit to the Amendment
No. 6 for ALPS Global Holding Pubco for the audited financial statements as of March 31, 2025.

 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