SecProbe.io

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 AVALON
GLOBCARE CORP.

 4400 Route 9 South, Suite 3100

 Freehold, NJ 07728

 April 16, 2026

 VIA EDGAR

 United States Securities

 and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Jan Woo

 Re:
 Avalon GloboCare Corp.

 Registration Statement on Form S-1

 File No. 333-294936

 Ladies and Gentlemen:

 Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), Avalon GloboCare Corp (the "Company")
respectfully requests that the effective date of the registration statement referred to above be accelerated so that it will become effective
at 5:00 p.m., Eastern Daylight Time, on Monday April 20, 2026, or as soon thereafter as practicable.

 Please notify Greg Carney
of Sheppard, Mullin, Richter & Hampton LLP, counsel to the Company, at (213) 617-4209 as soon as possible as to the time the
Registration Statement has been declared effective pursuant to this acceleration request.

 Thank you,

 AVALON GLOBOCARE CORP.

 By:
 /s/ Luisa Ingargiola

 Name:
 Luisa Ingargiola

 Title:
 Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 14, 2026

Luisa Ingargiola
Chief Financial Officer
Avalon GloboCare Corp.
4400 Route 9 South, Suite 3100
Freehold, NJ 07728

 Re: Avalon GloboCare Corp.
 Registration Statement on Form S-1
 Filed April 8, 2026
 File No. 333-294936
Dear Luisa Ingargiola:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Jan Woo at 202-551-3453 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Gregory Carney, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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AVALON GLOBOCARE CORP.

4400 Route 9 South, Suite 3100

Freehold, New Jersey 07728

June 27, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Avalon
GloboCare Corp.

Registration Statement on Form S-3

File No. 333-272736

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, Avalon GloboCare Corp. (the “Registrant”) hereby requests
acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-272736), so that it may become effective
at 4:30 p.m. Eastern time on June 28, 2023, or as soon thereafter as practicable, or at such later time as the Registrant or its
counsel may orally request via telephone call to the staff.

    Very truly yours,

    AVALON GLOBOCARE CORP.

    By:
    /s/ Luisa Ingargiola

    Name:
    Luisa Ingargiola

    Title:
    Chief Financial Officer

 cc: Steven M. Skolnick, Esq.

Lowenstein Sandler LLP

United States securities and exchange commission logo
June 22, 2023
David Jin, M.D., Ph.D.
Chief Executive Officer
Avalon GloboCare Corp.
4400 Route 9 South, Suite 3100
Freehold, NJ 07728
Re:Avalon GloboCare Corp.
Registration Statement on Form S-3
Filed June 16, 2023
File No. 333-272736
Dear David Jin:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Tyler Howes at 202-551-3370 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Steven M. Skolnick, Esq.

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VIA EDGAR

August 8, 2018

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3233

100 F Street, N.E.

Washington, D.C. 20549

Attention: Kasey Robinson

Re: Avalon GloboCare Corp.

Acceleration Request for Registration Statement on Form S-1

File No. 333-224343

    Requested Date:
    August 9, 2018

    Requested Time:
    4:00 p.m. Eastern Time

Dear Ms. Robinson:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended (the “Act”), Avalon GloboCare Corp. (the “Company”) hereby requests that the effective
date of the above-referenced registration statement (the “Registration Statement”) be accelerated to August
9, 2018, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter LLP,
request by telephone that such Registration Statement be declared effective at some other time. In making this acceleration request,
the Company acknowledges that it is aware of its responsibilities under the Act.

Once the Registration Statement is effective, please orally
confirm the event with our counsel, Goodwin Procter LLP by calling Thomas Levato at (212) 459-7256. We also respectfully request
that a copy of the written order from the Securities and Exchange Commission (the “Commission”) verifying the
effective time and date of the Registration Statement be sent to our counsel, Goodwin Procter LLP, Attention: Thomas Levato, by
facsimile to (212) 355-3333.

If you have any questions regarding this request, please
contact Thomas Levato of Goodwin Procter LLP at (212) 459-7256.

    Sincerely,

    Avalon GloboCare Corp.

    By:
    /s/ Luisa Ingargiola

    Name: Luisa Ingargiola

    Title:   Chief Financial Officer

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August 7, 2018

Securities and Exchange Commission

100 F. Street, NE

Washington, D.C. 20549

    Re:
    Avalon GloboCare Corp.

    Registration Statement on Form S-1

    File No. 333-224343

VIA EDGAR

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Boustead Securities, LLC, as the sole
underwriter, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will
become effective at 4:00 p.m., Washington D.C. time, on August 9, 2018, or as soon thereafter as practicable.

The following is supplemental information supplied under Rule 418(a)(7)
and Rule 460 under the Securities Act of 1933:

 (i) Date of preliminary prospectus: August 7, 2018

 (ii) Dates of distribution: August 7, 2018 to August 9, 2018

 (iii) Number of prospective underwriters and dealers to whom the preliminary prospectus was furnished:
2

 (iv) Number of prospectuses so distributed: 300

The undersigned confirms that it has
complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that they
have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection
with the above-referenced issue.

Boustead Securities, LLC

    By:
    /s/ Keith Moore

    Name: Keith Moore

    Title: CEO

Mail Stop 3233
May 3 , 2018

Via E -Mail
David Jin
Chief Executive Officer
Avalon GloboCare Corp.
4400 Route 9 South, Suite 3100
Freehold, New Jersey 07728

Re: Avalon GloboCare  Corp.
  Registration Statement on Form S-1
Filed  April 19, 2018
  File No.  333-224343

Dear Mr. Jin:

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Kasey Robinson, Staff Attorney,  at (202) 551 -5880 with any questions.

Sincerely,

 /s/ Sonia Gupta Barros

Sonia Gupta Barros
Assistant Director
Office of Real Estate and
Commodities

cc: Thomas S. Levato
Goodwin Procter LLP

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AVALON
GLOBOCARE CORP.

83
South Street, Suite 101

Freehold,
New Jersey 07728

August
8, 2017

VIA
EDGAR

United
States Securities

and
Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Pamela A. Long, Assistant Director

    Re:
    Avalon GloboCare Corp.

    Registration Statement on Form S-1

    File No. 333-217809

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Avalon
GloboCare Corp. (the “Company”) respectfully requests that the effective date of the registration statement referred
to above be accelerated so that it will become effective at 10:00 a.m., Eastern Time, on Thursday August 10, 2017, or as soon
thereafter as possible.

We
hereby acknowledge the following:

 • that
                                         should the Commission or the staff, acting pursuant to delegated authority, declare the
                                         filing effective, it does not foreclose the Commission from taking any action with respect
                                         to the filing;

 • the
                                         action of the Commission or the staff, acting pursuant to delegated authority, in declaring
                                         the filing effective, does not relieve the Company from its full responsibility for the
                                         adequacy and accuracy of the disclosure in the filing; and

 • the
                                         Company may not assert staff comments and the declaration of effectiveness as a defense
                                         in any proceeding initiated by the Commission or any person under the federal securities
                                         laws of the United States.

AVALON
GLOBOCARE CORP.

By:
/s/ David Jin

Name:
David Jin

Title:
Chief Executive Officer

Mail Stop 4631

July 20, 2017

Luisa Ingargiola
Chief Financial Officer
Avalon GloboCare Corp.
83 South Street, Suite 101
Freehold, NJ 07728

Re: Avalon GloboCare Corp.
Amendment No. 1 to Registration Statement on Form S -1
Filed July 7, 2017
  File No. 333 -217809

Dear Ms. Ingargiola :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not bel ieve 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 these  comments, we may have  additional comments.

Prospectus Summary, page 1

Common Stock Offered by Us, page 2

1. We note your response to comment 5 of our letter dated June 5, 2017.  We reissue our
comment.  Based on disclosure in your risk factor entitled “There is no minimum raise
required . . .” on page 15 and in your Us e of Proceeds on page 19, it appears that if you
raise $2,000,000 or less, you will use proceeds only for general and administrative
expenses and working capital, and will not be able to implement your business plan.
However, narrative disclosure on pages  2 and 19  states that if you sell any less than
$5,000,000, you will utilize the proceeds in your operations, but will not be able to
implement your business plan.  Please reconcile these disclosures, and clarify the
minimum amount you will need to be abl e to begin implementing your business plan, as
opposed to only covering general and administrative expenses and working capital.

Luisa Ingargiola
Avalon GloboCare Corp.
July 20, 2017
Page 2

 Terms of the Offering, page 21

2. This section describes the plan of distribution for the company’s offering.  Please
consider adding this discussion to the discussion of the selling shareholder’s plan of
distribution under “Plan of Distribution” on page 51, or otherwise revising the title of this
section to indicate that this is your plan of distribution for the company’s offe ring and the
section on page 61 is the plan of distribution for the selling shareholders.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
23

Critical Accounting Policies and Estimates, page 24
Stock -based Compe nsation, page 25

3. We note your response to prior comment ten where you stated that “the revaluation does
not apply to these shares issued to the attorney and consultants.”  In this regard, please
revise your registration statement to delete the last sentence in the second paragraph of
your disclosure.  This comment also applies to your related significant accounting policy
in Note 3 on pages F -10 and F -28.

Cash Flows, page 30

4. We note that you removed your discussion of cash flows for the year ended December
31, 2016 as compared to the period from May 18, 2015 ( date of inception) through
December 31, 2015 .  Your discussion of cash flows should be provided for both the
annual and interim periods.  Please revise your registration statement to reinstate your
previous disclosure.

Consolidated Financial Statements, page F -1

Note 11 – Commitments and Contingencies, page F -35
Real property purchase agreement, page F -36

5. Please expand your disclosure to address the business purpose for purchasing the
property.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding reques ts for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Luisa Ingargiola
Avalon GloboCare Corp.
July 20, 2017
Page 3

 You may contact Dale Welcome, Staff Accountant , at (202) 551 -3865  or Kevin Stertzel,
Staff Accountant , at (202) 551 -3723  if you have questions regarding comments on the financial
statements and related matters.  Please contact Sergio Chinos, Staff Attorney,  at (202) 551 -7844
or me at (202) 551 -3765  with any other questions.

Sincerely,

 /s/ Pamela A. Long

 Pamela A. Long
Assistant Director
Office of Manufacturing and
Construction

cc: Stephen M. Fleming, Esq.

Mail Stop 4631
June 5 , 2017

Luisa Ingargiola
Chief Financial Officer
Avalon GloboCare Corp.
83 South Street, Suite 101
Freehold, NJ 07728

Re: Avalon GloboCare Corp.
Registration Statement on Form S -1
Filed May 9, 2017
  File No. 333 -217809

Dear Ms. Ingargiola :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply 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 these  comments, we may have additional comments.

General

1. Please revise your registration statement to provide update d financial statements and
related disclosures as required by Rule 8-08 of Regulation S -X.

Registration Statement Cover Pag e

2. We note your disclosure here that “[t]he Offering price has been estimated solely for the
purpose of calculating the registration fee in accordance with Rule 457(c) of the
Securities Act and is based upon the average of the high and low price of $0.75 p er share
of the Registrant’s Common Stock on the OTCQB Market.”  Please reconcile this with
your disclosure elsewhere throughout the filing that you intent to sell up to 20,000,000
shares of common stock at $1.00 per share.  As you appear to be registering  the number
of securities offered, not the dollar amount, it appears that Rule 457(a) is appropriate.

Luisa Ingargiola
Avalon GloboCare Corp.
June 5 , 2017
Page 2

 Prospectus Summary, page 1

3. Please disclose here that you have limited operating history, limited revenue, debt, and
that your auditor has raised substan tial doubt about your ability to continue as a going
concern.

4. As applicable, please disclose here that you are not a blank check and have no plans to
use this company as a vehicle for a future business combination.

5. Please reconcile the disclosure here th at if you only sell $1,000,000 (5% of the offering),
you will utilize the proceeds in operations but will not be able to implement your
business plan to any meaningful extent rendering an investment worthless w ith the
disclosure on pa ge 15 regarding sellin g only $2,000,000 (10% of the offering).

Lock -Up, page 2

6. Please provide more information about the operation of the lock -up.  For instance,
describe how the 75% limitation will be allocated amongst investors and whether there
are any circumstances where the lock-up period might be waived.

Risks Related to Doing Business in China, page 9

7. Please expand your risk factors to address the risks associated with restrictions on the
transfer of cash from China, as well as on the exchange of currency and how they may
constrain the company’s liquidity and the ability to use cash in its operations.

Use of Proceeds, page 19

8. We note that you will use some of the proceeds to engage in mergers and acquisitions.  I n
particular, on page 33 you state that you are in negotiat ion in your areas of focus with
respect to potential acquisitions and strategic partnerships.  Please provide the
information required by Instruction 6 to Item 504 of Regulation S -K.

Terms of the Offering, page 21

9. Please disclose more detail regarding th e manner in which these securities will be
offered.  For instance, will the responsible individuals solicit investors through direct
mailings, personal contact, or other sales material.  We also  note the disclosure that your
relationships, positive press, and word -of-mouth will be relied upon to attract interest in
the offering.  Please disclose whether you will be utilizing this prospectus in these selling
efforts or other mechanisms.  We may have further comments after reviewing your
response.

Luisa Ingargiola
Avalon GloboCare Corp.
June 5 , 2017
Page 3

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
23

Critical Accounting Policies and Estimates, page 24
Stock -based Compensation, page 25

10. In light of how you accounted for stock –based payments for legal and consulting services
in 2016, please clarify to us the last sentence of your policy, whereby you state stock
awards are “revalued or total compensation is recalculated based on the then current fair
value, at each subsequent reporting date.”

Cost of Revenu e, page 25

11. Please explain what the subcontractor costs were.

Operating Expenses, page 26

12. Please describe what the sales and marketing expenses were, particularly as associated
with the related party transactions from which you earned revenue.

Liquidity  and Capital Resources, page 27

13. Given the significant amount of cash held in China, please expand your disclosure to
describe any limitations imposed by the People’s Republic of China that may restrict the
transfer of cash out of the country.  Additionall y, please discuss the tax impact, if any,
should you need to repatriate such funds.  Refer to Topic 501.13 of the Codification of
Financial Reporting Policies.

Business and Properties , page 32

14. Please disclose the business purposes for which this property  will be used.

15. Please fully describe the relationships and services associated with the revenue
generating related party transactions in China. We may have further comments upon
reviewing your response.

16. Please significantly revise to precisely describe your revenue generating operations,
where you conduct those operations, how you provide services and products, and which
of your employees support these activities.  For example, it is unclear where you carryout
operations.  On page 1 you state that the tr ansaction with Avalon Healthcare Systems was
done for the purpose of acquiring U.S. based healthcare companies but its subsidiaries are
based in China and on page 30 and elsewhere you state that your primary operations are
in China.

Luisa Ingargiola
Avalon GloboCare Corp.
June 5 , 2017
Page 4

 17. Consider providing an organization chart describing your subsidiaries and operating
entities, their locations, and business activities.

Markets, page 33

18. You discuss collaborations and clinical bases with other entities under both the Avalon
Cell and Rehab platforms.  Please f ully describe all material terms of such arrangements
and file any agreements as exhibits to this registration statement.

19. We note that you will focus on projects with strong intellectual property.  Please disclose
how you will carry out your business in t his regard.  Will you be licensing and/or
acquiring patents or other intellectual property?

Properties, page 35

20. We note your disclosure here that pursuant to the Purchase Agreement for the Property,
the Seller also assigned all lease agreements to you.  Please disclose any material terms
related to the assignment of the lease agreements to you.

Government Regulation, page 35

21. Please substantially revise this section to discuss the various U.S. and Chinese regulations
specifically related to your business  and offering.  For example, please disclose whether
there are any specific regulatory requirements affecting access to the funds raised in this
offering.  Will you be delayed in utilizing the offering proceeds?  Are there any
regulations affecting dividen ds from Chinese based operating companies or liquidation of
assets in China?

Recent Sales of Unregistered Securities, page 37

22. Please substantially revise to explain in detail the “ March 2017 Accredited Investor”
transaction.  It is not clear what the purpose of this transaction was or the role of each
party.  Please also address the impact on your business of having to return the funds as
well as the role of the Beijing Commerce Commission.

Distribution to AHS’s Founders, page 46

23. Please revise your prospectus to explain that prior to the October 2016 share exchange,
Avalon Hea lthcare Systems, Inc. acquired control of your company. Reconcile this with
the disclosure that control changed with the share exchange.  Describe the “control
shares.”

Luisa Ingargiola
Avalon GloboCare Corp.
June 5 , 2017
Page 5

 Optio ns, page 51

24. Please reconcile the disclosure here that you have no issued options with the disclosure
on page 37, 47, and 54 that you issued stock options.

Consolidated Financial Statements, page F -1

Note 9 – Income Taxes, page F -15

25. Please expand your d isclosure to provide the components of income (loss) before income
taxes attributable to each of your domestic and Chinese operations.  Refer to Rule 4 -
08(h)(1) of Regulation S -X.

Note 14 – Restricted Net Assets, page F -19

26. Please explain  to us how you de termined that the restricted net assets of Avalon
(Shanghai) Healthcare Technology Co., Ltd. did not exceed 25% of your consolidated net
assets at December 31, 2016.   It appears from your disclosure that cash balances in
excess of $2.5 million, representin g a majority of your assets, are kept in financial
institutions located in China.

Note 15 – Subsequent Events, page F -19

Subscription agreement, page F -19

27. Please expand your disclosure to clarify whether Beijing DOING Biomedical Technology
Co., Ltd. is an unaffiliated third party or a related party.

Real property purchase supplemental and amendatory agreement, page F -20

28. Please update your disclosure to address whether the real property purchase has closed , as
well as the significant provisions of any financing arrangements that resulted in the
company’s ability to purchase the property for $7.6 million in cash given the amount of
cash held in the United States.    We note on page 29 of your document that you state the
purchase closed on May 5, 2017.   W e further note on page F -18 and F -20, the closing
date was extended to May 8, 2017.   Please reconcile these disclosures and explain the
sources of liquidity for this purchase.

Exhibits and Financial Statements, page 56

29. Please file as an exhibit any cons ulting agreements entered into in connection with
related parties.

Luisa Ingargiola
Avalon GloboCare Corp.
June 5 , 2017
Page 6

 We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by t he staff.

Refer to Rules 460 and 461 regarding requests for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

You may contact Dale Welcome, Staff Accountant,  at (202) 551 -3865 or Kevin Stertzel,
Staff Accountant,  at (202) 551 -3723 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sergio Chinos, Staff Attorney,  at (202) 551 -7844
or Craig Slivka,  Special Counsel,  at (202) 551 -3729 with any other questions.

Sincerely,

 /s/ Jay Ingram

Jay Ingram
Legal Branch Chief
Office of Manufacturing and
Construction

cc: Stephen M. Fleming, Esq.

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Global
Technologies Corp

c/o
Yair David Guttman

Maale
Amos 40

Maale
Amos, 90966 Israel

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100 F Street
N.E.

Washington,
D.C. 20549

    Attention:
    Barbara
    Jacobs

    Re:
    Global
    Technologies Corp .

    Amendment
    No. 1 to Registration Statement on Form S-1

    Filed
    March 26 , 2015

    Commission
    File No. 333-202164

NEW
REQUEST FOR ACCELERATION OF EFFECTIVENESS

(
and withdrawal of request filed on April 13 2015)

    Requested Date:

    April
    16 2015

    Requested Time:

    4:01
    PM Eastern Daylight Time

Ladies and
Gentlemen:

Triumph
Ventures Corp. (the “Registrant”) hereby wishes to withdraw the request for acceleration filed on April
13 2015 and make a new request that the Securities and Exchange Commission (the “Commission”) take appropriate
action to declare the above-captioned Registration Statements on Form S-1 effective at the “Requested Date”
and “Requested Time” set forth above (or as soon thereafter as practicable).

The
Registrant hereby authorizes attorney Thomas J. Craft, Jr. or Richard Rubin to orally modify this request for acceleration, if
necessary.

The
Registrant hereby acknowledges that:

    •

    should
        the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it
        does not foreclose the Commission from taking any action with respect to the filing;

    •

    the
        action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does
        not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing;
        and

    •

    the
        Registrant may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated
        by the Commission or any person under the federal securities laws of the United States.

The
Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Rubin at (917) 957-9092, or
in his absence, Mr. Craft at (561) 317-7036.

    Sincerely
    yours,

    Global
    Technologies Corp

    By:

    /s/
        Yair David Guttman

        CEO/DIRECTOR

CORRESP
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Global
Technologies Corp

c/o
Yair David Guttman

Maale
Amos 40

Maale
Amos, 90966 Israel

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100 F Street
N.E.

Washington,
D.C. 20549

    Attention:
    Barbara
    Jacobs

    Re:
    Global
    Technologies Corp .

    Amendment
    No. 1 to Registration Statement on Form S-1

    Filed
    March 26 , 2015

    Commission
    File No. 333-202164

NEW
REQUEST FOR ACCELERATION OF EFFECTIVENESS

(
and withdrawal of request filed on April 13 2015)

    Requested Date:

    April
    16 2015

    Requested Time:

    4:01
    PM Eastern Daylight Time

Ladies and
Gentlemen:

Global
Technologies Corp. (the “Registrant”) hereby wishes to withdraw the request for acceleration filed on
April 13 2015 and make a new request that the Securities and Exchange Commission (the “Commission”)
take appropriate action to declare the above-captioned Registration Statements on Form S-1 effective at the “Requested
Date” and “Requested Time” set forth above (or as soon thereafter as practicable).

The
Registrant hereby authorizes attorney Thomas J. Craft, Jr. or Richard Rubin to orally modify this request for acceleration, if
necessary.

The
Registrant hereby acknowledges that:

    •

    should
the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

    •

    the
                                                                                                                                     action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
                                                                                                                                     relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing;
                                                                                                                                     and

    •

    the
Registrant may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

The
Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Rubin at (917) 957-9092, or
in his absence, Mr. Craft at (561) 317-7036.

    Sincerely
    yours,

    Global
    Technologies Corp

    By:

    /s/
        Yair David Guttman

        CEO/DIRECTOR

CORRESP
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filename1.htm

Global
Technologies Corp

c/o
Yair David Guttman

Maale
Amos 40

Maale
Amos, 90966 Israel

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100 F Street
N.E.

Washington,
D.C. 20549

    Attention:
    Barbara
    Jacobs

    Re:
    Global
    Technologies Corp .

    Amendment
    No. 1 to Registration Statement on Form S-1

    Filed
    March 26 , 2015

    Commission
    File No. 333-202164

REQUEST
FOR ACCELERATION OF EFFECTIVENESS

    Requested Date:

    April
    13 2015

    Requested Time:

    4:01
    PM Eastern Daylight Time

Ladies and
Gentlemen:

Triumph
Ventures Corp. (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”)
take appropriate action to declare the above-captioned Registration Statements on Form S-1 effective at the “Requested
Date” and “Requested Time” set forth above or as soon thereafter as practicable.

The
Registrant hereby authorizes attorney Thomas J. Craft, Jr. or Richard Rubin to orally modify this request for acceleration, if
necessary.

The
Registrant hereby acknowledges that:

    •
    should
the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

    •
    the
                                                                                                                                     action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
                                                                                                                                     relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing;
                                                                                                                                     and

    •
    the
Registrant may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

The
Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Rubin at (917) 957-9092, or
in his absence, Mr. Craft at (561) 317-7036.

    Sincerely
    yours,

    Global
    Technologies Corp

    By:

    /s/
        Yair David Guttman

        CEO/DIRECTOR

March 17, 2015

Yair David Guttman
Chief Executive Officer
Maale Amos 40
Maale Amos, 90966
Israel

Re: Global Technologies Corp.
Registration Statement on Form S -1
Filed February 19, 2015
  File No. 333 -202164

Dear Mr. Guttman :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in yo ur
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Risk Factors

Risks Relating to Our Company

Since the sole Director and Officer  has outside activities…, page 10

1. Please revise this risk factor to address whether Mr. Guttman’s outside employment
creates a material risk of conflicts of interest with the company, and if so, how such
conflicts will be resolved.

Use of Proceeds, page 18

2. Given that you have structured this transaction on a best -efforts, no minimum  basis,
please revise the table t o add columns that assume the completion of a  smaller portion of
the offering.  We will not object if your table begins  with a colu mn that ass umes the sale

Yair David Guttman
Global Technologies Corp.
March 17, 2015
Page 2

 of ten percent of the offered shares.  Please make similar revisions throughout your
prospectus including, but not limited to, the disclosure in your Dilution and
Management’s Discussion and Analysis sections.

Certain Relationships and Relat ed Transactions, page 31

3. Please file the agreement covering the $2,900 loan from Mr. Guttman.  See Item
601(b)(10)(ii)(A).  If there is no written loan agreement, please tell us what consideration
you have given to filing a written summary of the oral loa n agreement as an exhibit to the
registration statement.  For additional guidance, please consider Question 146.04 of our
Regulation S -K Compliance and Disclosure Interpretations.

Description of Securities

Our Common Stock, page 33

4. Here  and in the second full risk factor on page 13 you state that your certificate of
incorporation authorizes the issuance of 480,000,000 shares of common stock.  However,
it appears that your certificate of incorporation (filed as Exhibit 3.1) authorizes the
issuance of 490,000,000 shares of common stock.  Please revise or advise.

Shares Eligible for Future Sale, page 34

5. In the second paragraph following this heading you state that upon completion of this
offering, and assuming all of the offered shares are  purchased, you would have
10,000,000 shares of common stock outstanding.  However, your disclosure on page 5
indicates that you  would have 7,000,000 shares outstanding.  Please revise or advise.

Part II

Dealer Prospectus Delivery Obligation, page 40

6. Please move the dealer prospectus delivery obligation to the outside back cover page of
the prospectus.  See Item 502(b) of Regulation S -K.

Indemnification of Director and Officer, page 40

7. We note that Article XII of your Bylaws provides that you will inde mnify your directors
and officers to the fullest extent permitted by Delaware law.  Please revise to briefly
discuss  the scope of indemnification required and permitted by Delaware law.  See Item
702 of Regulation S -K.

Yair David Guttman
Global Technologies Corp.
March 17, 2015
Page 3

 Signatures, page 43

8. Please remove the reference to amendment #3 or advise.

Exhibits Table

Exhibit 3.1

9. Exhibit  3.1 was filed in an improper format.  Please refile this agreement  in a text -searchable
format.  See Rule 301 of Regulation S -T and the EDGAR Filer Manual, Volume II:
“EDGAR Filin g,” Version 29 (December 2014).

Exhibit 23.1

10. The Consent of Independent Registered Public Accounting Firm includes an improper date
reference  of January 19, 2015 to the Report of Registered Independent Auditors dated
January 26, 2015 on page F -1 of the filing.  Please file a revised Exhibit 23.1 accordingly.

We urge all persons who are responsible for the accuracy and adequacy of the disclosur e
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they  are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement, please provide  a written statement from th e company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding reque sts for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securitie s Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow

Yair David Guttman
Global Technologies Corp.
March 17, 2015
Page 4

 adequate time  for us to review any amendment prior to the requested effectiv e date of the
registration statement.

You may contact Frank Knapp, Staff Accountant,  at (202) 551 -3805  or Patrick Gilmore,
Accounting Branch Chief, at (202) 551 -3406  if you have questions regarding comments on the
financial statements and related mat ters.  Please contact Mitchell Austin, Staff Attorney,  at (202)
551-3574  or me at (202) 551 -3735  with any other questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director

cc: Richard Rubin
 Office of Richard Rubin