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
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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