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Correspondence 0001493152-25-009614 from GIBO HOLDINGS Ltd (GIBO)

GIBO HOLDINGS Ltd
Date: March 10, 2025 · CIK: 0002034520 · Accession: 0001493152-25-009614

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File numbers found in text: 333-285183

Date
March 10, 2025
Author
Director
Form
CORRESP
Company
GIBO HOLDINGS Ltd

Letter

VIA EDGAR Division of Corporation Finance Office of Finance Mr. Matthew Derby Re: GIBO Holdings Limited (CIK No. 0002034520) Global IBO Group Ltd (CIK No. 0002034047) Registration Statement on Form F-4 (File No. 333-285183)

Dear Ladies and Gentlemen,

Pursuant Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended (the "Securities Act"), GIBO Holdings Limited and Global IBO Group Ltd (the "Co-Registrants") hereby request that the effectiveness of the above-referenced registration statement on Form F-4, as amended (the "F-4 Registration Statement"), be accelerated to, and that the F-4 Registration Statement become effective at 8:00 a.m., Eastern Time on March 12, 2025, or at such later time as the Co-Registrants or their counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.

In connection with this request, the Co-Registrants acknowledge their obligations under the Securities Act.

Very
truly yours,
GIBO
Holdings Limited

Show Raw Text
CORRESP
 1
 filename1.htm

 VIA
EDGAR

 Division
of Corporation Finance

 Office
of Finance

 U.S.
Securities and Exchange Commission

 100
F Street, N.E. Washington, D.C. 20549

 Attn:
 Mr.
 Dave Edgar

 Ms.
 Kathleen Collins

 Mr.
 Jeff Kauten

 Mr.
 Matthew Derby

 Re:
 GIBO
 Holdings Limited (CIK No. 0002034520)

 Global
 IBO Group Ltd (CIK No. 0002034047)

 Registration
 Statement on Form F-4 (File No. 333-285183)

 Dear
Ladies and Gentlemen,

 Pursuant
Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended (the "Securities Act"), GIBO Holdings Limited
and Global IBO Group Ltd (the "Co-Registrants") hereby request that the effectiveness of the above-referenced registration
statement on Form F-4, as amended (the "F-4 Registration Statement"), be accelerated to, and that the F-4 Registration Statement
become effective at 8:00 a.m., Eastern Time on March 12, 2025, or at such later time as the Co-Registrants or their counsel may orally
request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.

 In
connection with this request, the Co-Registrants acknowledge their obligations under the Securities Act.

 Very
truly yours,

 GIBO
 Holdings Limited

 By:
 /s/
 Chun Yen "Dereck" Lim

 Name:

 Chun
 Yen "Dereck" Lim

 Title:
 Director

 Global
 IBO Group Ltd

 By:
 /s/
 Chun Yen "Dereck" Lim

 Name:

 Chun
 Yen "Dereck" Lim

 Title:
 Director

 By:
 /s/
 Kwan Chen "Katrina" Hung

 Name:

 Kwan
 Chen "Katrina" Hung

 Title:
 Director

 cc:
 Jing
 Tuang "Zelt" Kueh, Chief Executive Officer, GIBO Holdings Limited

 Arila
 E. Zhou, Esq., Partner, Robinson & Cole LLP

 Ze'-ev
 D. Eiger, Esq., Partner, Robinson & Cole LLP