SecProbe.io

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 September
11, 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

 Registration
 Statement on Form F-4

 File
 No. 333-284035

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of Regulation C ("Rule 461") promulgated under the Securities Act of 1933, as amended, Alps Global Holding Pubco
(the "Registrant") and Alps Life Sciences Inc. (the "Co-Registrant") 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, 5:00 p.m., Eastern Time on September 12, 2025, or as soon thereafter
as practicable. If there is any change in the acceleration request set forth above, the Registrant and Co-Registrant will promptly notify
you of the change, in which case the Registrant and Co-Registrant may be making an oral request of acceleration of the effectiveness
of the F-4 Registration Statement in accordance with Rule 461. Such request may be made by an executive officer of the Registrant and
Co-Registrant or by any attorney from their U.S. counsel, Law Offices of Jenny Chen-Drake.

 Very
 truly yours,

 ALPS
 GLOBAL HOLDING PUBCO

 /s/
 Tham Seng Kong

 Tham
 Seng Kong

 Chief
 Executive Officer of Alps Global Holding Pubco

 Very
 truly yours,

 ALPS
 LIFE SCIENCES INC.

 /s/
 Tham Seng Kong

 Tham
 Seng Kong

 Group
 Chief Executive Officer of Alps Life Sciences Inc.

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 September
8, 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

 Katherine
 Bagley

 Nudrat
 Salik

 Li
 Xiao

 Re:
 Alps
 Global Holding Pubco

 Amendment
 No. 7 to Registration Statement on Form F-4

 Filed
 August 29, 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 September 5, 2025 (the " Comment Letter ") with
respect to the Amendment No. 7 to the Registration Statement on Form F-4 filed with the Commission on August 29, 2025 (" Amendment
No. 7 ") through EDGAR.

 For
your convenience, we have repeated each of the Staff's comments below in bold text, followed by the Company's responses.
The Company has revised Amendment No. 7 in response to the Staff's comments and is concurrently submitting Amendment No. 8 to the
Registration Statement on Form F-4 (" Amendment No. 8 ") with this letter, which reflects these revisions and updates
and clarifies certain other information. Capitalized terms used but not defined herein have the meanings set forth in Amendment No. 8.

 Amendment
No. 7 to Registration Statement on Form F-4 filed August 29, 2025

 Item
21 Exhibits and Financial Statements Schedules

 Exhibit
23.2 and Exhibit 23.5, page II-2

 1.
 Please
 provide a currently dated consent from your auditors. Refer to Item 601(b)(23)(i) of Regulation S-K.

 Response:
 In response to the Staff's comment, the Company has filed currently dated consents from its auditors as Exhibits 23.2 and 23.5
 to this Amendment No. 8.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 5, 2025

Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

 Re: Alps Global Holding Pubco
 Amendment No. 7 to Registration Statement on Form F-4
 Filed August 29, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended registration statement and have the
following
comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our August 4,
2025 letter.
 September 5, 2025
Page 2

Amendment No. 7 to Registration Statement on Form F-4 Filed August 29, 2025
Item 21. Exhibits and Financial Statements Schedules
Exhibit 23.2 and Exhibit 23.5, page II-2

1. Please provide a currently dated consent from your auditors. Refer to
Item
 601(b)(23)(i) of Regulation S-K.
 Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Jenny Chen-Drake, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 August
29, 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

 Katherine
 Bagley
 Nudrat
 Salik

 Li
 Xiao

 Re:
 Alps
 Global Holding Pubco

 Amendment
 No. 6 to Registration Statement on Form F-4
 Filed
 July 25, 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 August 4, 2025 (the " Comment Letter ") with respect
to the Amendment No. 6 to the Registration Statement on Form F-4 filed with the Commission on July 25, 2025 (" Amendment
No. 6 ") through EDGAR.

 For
your convenience, we have repeated each of the Staff's comments below in bold text, followed by the Company's responses.
The Company has revised Amendment No. 6 in response to the Staff's comments and is concurrently submitting Amendment No. 7 to
the Registration Statement on Form F-4 (" Amendment No. 7 ") with this letter, which reflects these revisions and updates
and clarifies certain other information. Capitalized terms used but not defined herein have the meanings set forth in Amendment No.
7.

 Amendment
No. 6 to Registration Statement on Form F-4 filed July 25, 2025

 Risk
Factors

 If
certain December 2024 Redeeming Stockholders choose not to return the December 2024 Extension Overpayment Amount..., page 77

 1.
 We
 note your disclosure here and elsewhere in the prospectus regarding the December 2024 Extension Overpayment Amount. Please revise
 your disclosure to address the following items:

 ●
 Given
 that return of the December 2024 Extension Overpayment Amount is not guaranteed, please clearly disclose that your assumptions that
 such payment will be received are not guaranteed, and revise your disclosure to show the estimated per share redemption price and
 other related disclosures under the assumption that the December 2024 Extension Overpayment Amount is not returned. Please also disclose
 the risks, if material, related to the overpayment and your request that shareholders return the funds.

 Response:
 In response to the Staff's comment, we revised the disclosure on the cover page, page 77 and page 165 of Amendment No.
 7 to disclose that it is not guaranteed that we will receive such payment, and that upon the closing of the Business Combination
 or collecting the Aggregate December 2024 Extension Overpayment Amount, whichever occurs first, Globalink intends to request Continental,
 the trustee of the Trust Account, to release only the funds actually received from the December 2024 Extension Redeeming Stockholders
 as of such date. As such, Globalink does not expect the per share redemption price payable to redeeming stockholders at the Special
 Meeting would be affected by the portion of the Aggregate December 2024 Extension Overpayment Amount recovered. In response to the
 Staff's comment, we expanded the risk factor titled " If certain December 2024 Redeeming Stockholders choose not to
 return the December 2024 Extension Overpayment Amount to Continental, this shortfall will reduce the funds available in the Trust
 Account for withdrawal by Globalink to cover its outstanding taxes " on page 78 of Amendment No. 7 to disclose the risks
 related to the overpayment and the request that stockholders return the funds.

 ●
 You
 state that the Company was allowed to withdraw additional interest from the Trust Account to "cover income and franchise taxes."
 Please quantify the amount of these taxes and explain whether they have already been paid from other sources or if they remain outstanding.
 If they have been paid, please disclose the source of funds used for such payment. If they have not been paid, please disclose whether
 you have sources of funds outside of the Trust Account available for such payment, and disclose the risks, if any, related to your
 ability to pay the outstanding amount.

 Response:
 In response to the Staff's comment, we revised our disclosure on the cover page, page 78 and page 165 of Amendment No. 7 to
 quantify the amount of these taxes, explain that the taxes remain outstanding, and disclose the source of funds intended to be used
 for paying the outstanding taxes. We also included a risk factor titled " Globalink has not yet paid certain franchise and
 income taxes and may be subject to penalties and interests, which could materially and adversely affect its financial
 condition " on page 78 of Amendment No. 7 to disclose the risks related to Globalink's ability to pay the outstanding
 amount.

 ●
 Given
 your disclosure that there was approximately $0.95 million of funds in the Trust Account as of July 8, 2025 and that the Aggregate
 December 2024 Extension Overpayment Amount was approximately $0.56 million, please expand on your disclosure to explain the consequences
 to existing stockholders if the December 2024 Extension Overpayment Amount is not returned in whole or in part. Specifically, please
 disclose whether you intend to request Continental release additional funds from the Trust Account to cover the income and franchise
 taxes that resulted in the overpayment. In this regard, we note that it appears Section 2 of the Trust Agreement provides distributions
 to cover income or other tax obligations owed by the Company may only be made from interest earned on the funds in the Trust Account
 and not the initial proceeds, and Section 1(k) of the Trust Agreement provides that the Trustee may not disburse any amounts from
 the Trust Account in connection with a Business Combination in the event that the amount per share to be received by the redeeming
 Public Shareholders is less than $10.15 per share (plus the amount per share deposited in the Trust Account pursuant to any Extension
 Letter).

 Response:
 In response to the Staff's comment, we revised our disclosure on the cover page, page 78 and page 165 of Amendment No.
 7 to disclose that (i) Globalink intends to request Continental to release additional funds from the Trust Account to Globalink to
 cover the income and franchise taxes that resulted in the previous overpayment, and (ii) Globalink does not intend to withdraw funds
 from the Trust Account if such withdrawal would either cause the aggregate amount withdrawn from the Trust Account to exceed the
 aggregate interests earned on the funds in the Trust Account, or result in the estimated redemption price per share payable to redeeming
 public stockholders at the Special Meeting falling below $10.15 (plus the amount per share deposited in the Trust Account pursuant to any Extension Letter).

 ●
 Please
 address your proposed treatment of any portion of the December 2024 Extension Overpayment Amount received after the completion of
 a Business Combination. Specifically, please disclose whether redeeming stockholders would have any beneficial interest in such repayments
 or if you believe their interest would be limited to any amounts distributed by the Trustee at the time of the Business Combination.

 Response:
 In response to the Staff's comment, we revised our disclosure on the cover page, page 78 and page 165 of Amendment No. 7 to
 clarify that Globalink intends to keep collecting the December 2024 Extension Overpayment Amount until the full amount is received,
 or until immediately prior to the closing of the Business Combination, whichever occurs first. If a portion of the December 2024
 Extension Overpayment Amount remains outstanding at Closing, Globalink will withdraw from the Trust Account only the portion of the
 December 2024 Extension Overpayment Amount it has actually received. It will then use its working capital balance if available; and
 if needed, it will issue promissory notes to Globalink's Sponsor or PGM to obtain additional cash to cover any remaining
 outstanding taxes. Globalink believes that, regardless of to the extent to which the December 2024 Extension Overpayment Amount is
 recovered, redeeming stockholders at the Special Meeting will receive the same amount per-share redemption price. Accordingly, their interests will not be impacted by the amount Globalink is able to recover at the Closing.

 ●
 Please
 disclose whether and to what extent you have had discussions with the Trustee regarding the December 2024 Extension Overpayment Amount.
 To the extent material, please add risk factor disclosure addressing the possibility that the Trustee may disagree with your determinations
 regarding the December 2024 Redemption Payment, your interpretation of the Trust Agreement, or your proposed application or treatment
 of any portion of the December 2024 Extension Overpayment Amount you ultimately receive.

 Response:
 In response to the Staff's comment, we revised our disclosure on the cover page, page 79 and page 165 of Amendment No.
 7 to disclose the discussions we had with the Trustee regarding the December 2024 Extension Overpayment Amount and included a risk
 factor titled " Any disagreements with the Trustee regarding the December 2024 Redemption Payment or interpretation of the
 Trust Agreement may adversely affect Globalink's ability to complete the business combination or satisfy redemption obligations "
 on page 79 of Amendment No. 7 to address the possibility that the Trustee may disagree with Globalink's determinations regarding
 the December 2024 Redemption Payment, interpretation of the Trust Agreement, or proposed application or treatment of any portion
 of the December 2024 Extension Overpayment Amount that Globalink ultimately receives.

 Financial
Statements of Cilo Cybin Holdings Limited, page F-104

 2.
 The independent auditor's report provided
on page F-119 for the year ended March 31, 2024 appears to be missing certain paragraphs including the opinion and basis for opinion
paragraphs included in the prior amendment. Please have your auditor revise as necessary to ensure the auditor report(s) cover all periods
included and are placed appropriately.

 Response:
In response to the Staff's comment, we have revised our disclosure to include the opinion and basis for opinion paragraphs particularly
on pages F-115, F-116, and F-117 of Amendment No. 7 and have made corresponding updates to ensure the independent auditor's report
appropriately covers all periods presented.

 Exhibits

 2.
 We
 note your response to prior comment 2. The report date included in the auditor's consent for ALPS Global Holding Pubco is not
 the same date as the report date of June 24, 2025 provided on page F-90. Please have your auditor revise as necessary.

 Response:
In response to the Staff's comment, we have refiled the auditor's consent for ALPS Global Holding Pubco as Exhibit 23.2,
to align with the report date disclosed on page F-90.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 4, 2025

Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

 Re: Alps Global Holding Pubco
 Amendment No. 6 to Registration Statement on Form F-4
 Filed July 25, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our July 1, 2025
letter.
 August 4, 2025
Page 2

Amendment No. 6 to Registration Statement on Form F-4 filed July 25, 2025
Risk Factors
If certain December 2024 Redeeming Stockholders choose not to return the
December 2024
Extension Overpayment Amount..., page 77

1. We note your disclosure here and elsewhere in the prospectus regarding
the December
 2024 Extension Overpayment Amount. Please revise your disclosure to
address the
 following items:

 Given that return of the December 2024 Extension Overpayment
Amount is not
 guaranteed, please clearly disclose that your assumptions that such
payment will
 be received are not guaranteed, and revise your disclosure to show
the estimated
 per share redemption price and other related disclosures under the
assumption that
 the December 2024 Extension Overpayment Amount is not returned.
Please also
 disclose the risks, if material, related to the overpayment and your
request that
 shareholders return the funds.

 You state that the Company was allowed to withdraw additional
interest from the
 Trust Account to "cover income and franchise taxes." Please quantify
the amount
 of these taxes and explain whether they have already been paid from
other sources
 or if they remain outstanding. If they have been paid, please
disclose the source of
 funds used for such payment. If they have not been paid, please
disclose whether
 you have sources of funds outside of the Trust Account available for
such
 payment, and disclose the risks, if any, related to your ability to
pay the
 outstanding amount.

 Given your disclosure that there was approximately $0.95 million
of funds in the
 Trust Account as of July 8, 2025 and that the Aggregate December
2024
 Extension Overpayment Amount was approximately $0.56 million, please
expand
 on your disclosure to explain the consequences to existing
stockholders if
 the December 2024 Extension Overpayment Amount is not returned in
whole or
 in part. Specifically, please disclose whether you intend to request
Continental
 release additional funds from the Trust Account to cover the income
and franchise
 taxes that resulted in the overpayment. In this regard, we note that
it appears
 Section 2 of the Trust Agreement provides distributions to cover
income or other
 tax obligations owed by the Company may only be made from interest
earned on
 the funds in the Trust Account and not the initial proceeds, and
Section 1(k) of the
 Trust Agreement provides that the Trustee may not disburse any
amounts from
 the Trust Account in connection with a Business Combination in the
event that the
 amount per share to be received by the redeeming Public Shareholders
is less than
 $10.15 per share (plus the amount per share deposited in the Trust
Account
 pursuant to any Extension Letter).

 Please address your proposed treatment of any portion of the
December 2024
 Extension Overpayment Amount received after the completion of a
Business
 August 4, 2025
Page 3

 Combination. Specifically, please disclose whether redeeming
stockholders would
 have any beneficial interest in such repayments or if you believe
their interest
 would be limited to any amounts distributed by the Trustee at the
time of the
 Business Combination.

 Please disclose whether and to what extent you have had
discussions with the
 Trustee regarding the December 2024 Extension Overpayment Amount. To
the
 extent material, please add risk factor disclosure addressing the
possibility that the
 Trustee may disagree with your determinations regarding the December
2024
 Redemption Payment, your interpretation of the Trust Agreement, or
your
 proposed application or treatment of any portion of the December
2024 Extension
 Overpayment Amount you ultimately receive.
Financial Statements of Cilo Cybin Holdings Limited, page F-104

2. The independent auditor s report provided on page F-119 for the year
ended March
 31, 2024 appears to be missing certain paragraphs including the opinion
and basis for
 opinion paragraphs included in the prior amendment. Please have your
auditor revise
 as necessary to ensure the auditor report(s) cover all periods included
and are placed
 appropriately.
Exhibits

3. We note your response to prior comment 2. The report date included in
the auditor's
 consent for ALPS Global Holding Pubco is not the same date as the report
date of
 June 24, 2025 provided on page F-90. Please have your auditor revise as
necessary.
 Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Katherine Bagley at 202-551-2545 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Jenny Chen-Drake, Esq.
</TEXT>
</DOCUMENT>

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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 1, 2025

Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

 Re: Alps Global Holding Pubco
 Amendment No. 5 to Registration Statement on Form F-4
 Filed June 27, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your registration statement and have the following
comments.

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

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
 July 1, 2025
Page 2

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.

Exhibits

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.
 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 requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Jenny Chen-Drake, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 June
26, 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. 4 to Registration Statement on Form F-4
 Filed
 June 9, 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 June 18, 2025 (the " Comment Letter ") with respect
to the Amendment No. 4 to the Registration Statement on Form F-4 filed with the Commission on June 9, 2025 (the " Amendment No.
4 ") 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. 4 where the language addressing a particular comment appears. Capitalized terms
used but not defined herein have the meanings set forth in the Amendment No. 4.

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

 Amendment
No. 4 to Registration Statement on Form F-4

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

 Note
5. Related Party Transactions, page F-31

 1.
 We
 note that you had two debt transactions in which the terms were modified and for which you determined that extinguishment accounting
 should be used. Specifically, the March 24, 2025 transaction related to advances from the affiliate of the sponsor and the March
 5, 2025 transaction with Public Gold Marketing Sdn Bhd. Please help us better understand how you determined the appropriate accounting
 for these transactions pursuant to ASC 470-50, including how you determined it should be treated as an extinguishment. Please also
 address how you determined that the gain should be considered a debt discount and amortized over the expected term of the notes.
 Refer to ASC 470-50-40-2 which indicates that the difference between the reacquisition price of debt and the net carrying amount
 of the extinguished debt shall be recognized currently in income in the period of extinguishment as losses or gains and identified
 as a separate item. This guidance also notes that gains shall not be amortized to future periods and that extinguishment transactions
 between related entities may be in essence capital transactions. Please advise.

 Response : The
Company acknowledges the Staff's comment and respectfully advises the Staff that the Company considered whether the
transactions supported the derecognition of a liability and concluded that the liability should not be derecognized until the cash
payment and capitalized shares are transferred in accordance with ASC 405-20, which does not occur in this case until 60 days of
closing. As a result of the conclusions above, the Company considered whether the transactions qualified as a debt extinguishment in
accordance with ASC 470-50 as a result of the addition of a substantive conversion feature under the amended terms and concluded
that the transactions, after amendment, contain substantially different terms due to the addition of a substantive conversion
feature; therefore, in accordance with ASC 470-50, should be accounted for as a debt extinguishment. The substantive conversion
feature added to the agreement is considered substantive because it meets the criteria outlined in ASC 470-20-40-7 through 40-9.
Specifically, the conversion feature is reasonably possible to be exercised in the future. The conversion price of $10.00 per share
is favorable compared to the traded stock price of $12.00 as of the modification date, making it economically advantageous for the
lender to exercise the conversion option. The conversion feature is contingent upon the close of the merger, which is reasonably
possible to occur. Additionally, the addition of the conversion feature changes the economic terms of the debt instrument
significantly, as it introduces a new mechanism for settlement that is favorable to the lender. Based on the debt extinguishment
conclusion above, the Company concluded that the transaction resulted in the recognition of an extinguishment gain, computed as the
net carrying value of the original debt less the fair value of the new debt. As a result of the creditor being a related party of
the Company, the Company followed the guidance in ASC 470-50-40-2 and determined that a rebuttable assumption that debt
extinguishment "gains" in transactions with related parties (e.g., the investor is a significant shareholder, part of
management, or an affiliate of the issuer) should be recognized as equity contributions (i.e., in APIC and not in earnings) unless
there is substantive evidence that the entity would have obtained the same economic outcome in an arm's-length transaction,
which in this case does not exist. The Company also considered the remarks provided during the 2010 AICPA Conference on Current SEC
and PCAOB Developments, then SEC Professional Accounting Fellow Sagar Teotia addressed how the SEC staff expects issuers to
determine whether an extinguishment transaction with a related party represents a capital transaction. As part of this
consideration, the Company determined that the role of the related party in the transaction was to provide the Company with the
necessary capital to consummate the business combination referred to within this filing. The Company also considered why the related
party would accept the Company's offer which resulted in the related party accepting a combination of cash and equity
securities that was significantly lower in value than the carrying value of the debt and determined that the related party accepted
such an offer in order to provide the necessary capital to consummate the business combination referred to within this filing and
avoid the dissolution of the Company which would result in the related party receiving significantly less capital, if any. The
Company also determined that the substance of the arrangement was a partial forgiveness of an outstanding payable owed to a related
party. Based on the conclusions above, the Company determined that the exchange of cash and equity securities in exchange for the
outstanding payable with the related party should be accounted for as an extinguishment gain recognized within equity as a capital
contribution.

 Financial
Statements of Alps Global Holding Pubco, page F-103

 2.
 As
 it appears that it has been more than a year since the incorporation of Alps Global Holding Pubco (Pubco) on May 14, 2024, we remind
 you that the Pubco is no longer eligible to continue to rely on the financial statement accommodation for a foreign private issuer
 that has been in existence less than a year to include an audited balance sheet that is no more than nine months old as well as the
 corresponding audited statements of comprehensive income, stockholders' equity and cash flows for the period from the date
 of inception to the date of the audited balance sheet. Please revise to disclose the Pubco's fiscal year end and provide updated
 financial statements accordingly.

 Response :
We acknowledge the Staff's comment. The audited financial statements for Alps Global Holding Pubco have been completed and included in Amendment No. 5 accordingly.

 Exhibits

 3.
 Please
 include currently dated auditor consents. There appears to only be a currently dated auditor consent for Globalink Investment Inc.

 Response : We
acknowledge the Staff's comment. The auditor consents of Marcum LLP and UHY Malaysia PLT have been filed as Exhibits 23.1 and
23.2 to Amendment No.5. The auditor consent of Nexia SAB&T is expected to be updated upon completion and updates of the financials statements
of Cilo Cybin Holdings Limited for the year ended March 31, 2025.

 4.
 Please
 refile Exhibit 10.43 in proper text-searchable format. It appears that the exhibit is currently filed as an image. For guidance,
 please refer to Item 301 of Regulation S-T.

 Response :
We acknowledge the Staff's comment. An updated Exhibit 10.43 in a proper text-searchable format has been filed as an
exhibit to Amendment No. 5.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 18, 2025

Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

 Re: Alps Global Holding Pubco
 Amendment No. 4 to Registration Statement on Form F-4
 Filed June 9, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended registration statement and have the
following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our April 23,
2025 letter.
 June 18, 2025
Page 2

Amendment No. 4 to Registration Statement on Form F-4
Financial Statements for Globalink Investment Inc. for the Period Ended March
31, 2025
Note 5. Related Party Transactions, page F-31

1. We note that you had two debt transactions in which the terms were
modified and for
 which you determined that extinguishment accounting should be used.
Specifically,
 the March 24, 2025 transaction related to advances from the affiliate of
the sponsor
 and the March 5, 2025 transaction with Public Gold Marketing Sdn Bhd.
Please help
 us better understand how you determined the appropriate accounting for
these
 transactions pursuant to ASC 470-50, including how you determined it
should be
 treated as an extinguishment. Please also address how you determined
that the gain
 should be considered a debt discount and amortized over the expected
term of the
 notes. Refer to ASC 470-50-40-2 which indicates that the difference
between the
 reacquisition price of debt and the net carrying amount of the
extinguished debt shall
 be recognized currently in income in the period of extinguishment as
losses or gains
 and identified as a separate item. This guidance also notes that gains
shall not be
 amortized to future periods and that extinguishment transactions between
related
 entities may be in essence capital transactions. Please advise.
Financial Statements of Alps Global Holding Pubco, page F-103

2. As it appears that it has been more than a year since the incorporation
of Alps Global
 Holding Pubco (Pubco) on May 14, 2024, we remind you that the Pubco is
no longer
 eligible to continue to rely on the financial statement accommodation
for a foreign
 private issuer that has been in existence less than a year to include an
audited balance
 sheet that is no more than nine months old as well as the corresponding
audited
 statements of comprehensive income, stockholders equity and cash
flows for the
 period from the date of inception to the date of the audited balance
sheet. Please revise
 to disclose the Pubco's fiscal year end and provide updated financial
statements
 accordingly.
Exhibits

3. Please include currently dated auditor consents. There appears to only
be a currently
 dated auditor consent for Globalink Investment Inc.
4. Please refile Exhibit 10.43 in proper text-searchable format. It appears
that the exhibit
 is currently filed as an image. For guidance, please refer to Item 301
of Regulation S-
 T.
 Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.
 June 18, 2025
Page 3

 Sincerely,

 Division of Corporation Finance
 Office of Industrial Applications and
 Services
cc: Jenny Chen-Drake, Esq.
</TEXT>
</DOCUMENT>

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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 23, 2025

Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

 Re: Alps Global Holding Pubco
 Amendment No. 2 to Registration Statement on Form F-4
 Filed April 18, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our April 1,
2025 letter.
 April 23, 2025
Page 2

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.
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.
 Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Jenny Chen-Drake, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 April
18, 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. 1 to Registration Statement on Form F-4
 Filed
 April 1, 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 11, 2025 (the " Comment Letter ") with respect
to the Amendment No. 1 to the Registration Statement on Form F-4 filed with the Commission on April 1, 2025 (the " Amendment
No. 1 ") 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. 1.

 The
Company has revised the Amendment No. 1 in response to the Staff's comments and is concurrently submitting the Amendment No. 2
to the Registration Statement on Form F-4 (the " Amendment No. 2 ") with this letter, which reflects these revisions
and updates and clarifies certain other information.

 Amendment
No. 1 to Registration Statement on Form F-4 filed April 1, 2025

 Availability
and terms of PIPE Investment, page 34

 1. We
 note your disclosure on page 34 that the Board negotiated the terms of the PIPE Investment
 with Alps and mutually agreed that the PIPE Investment would be used for PubCo's working
 capital after the Business Combination. Please revise your filing to include risk factor
 disclosure that addresses how the changes to the PIPE Investment could impact PubCo's
 ability to operate its business after the closing.

 Response:
In response to the Staff's comment, we revised our disclosure on page 85 of Amendment No. 2 to include a risk factor addressing
the potential adverse impacts that the reduction in the PIPE Investment may have on PubCo's ability to operate its business following
the closing of the Business Combination.

 Background
of the Business Combination, page 126

 2. We
 note your disclosure that the verbal commitment to securing PIPE Investments was what the
 Globalink Board considered as the primary basis for the pre-money valuation of Alps of approximately
 $1.6 billion and that the Board placed a high significance weighting on the availability
 and terms of the PIPE Investments in approving the transaction. Your disclosure of the dollar
 amount of the PIPE Investments that the Board considered when determining to approve the
 transaction was reduced from US$40.23 million to US$3.48 million. This appears to reflect
 the smaller available PIPE investment after the termination of two of the Subscription Agreements
 in March 2025. Given that the Board approved the transaction in January 2024, please clarify
 the information the Board relied upon at the time it made its determination to approve the
 transaction. In this regard, we note your statement on page 129 that the Board "considered
 the availability and terms of the PIPE Investment prior to approving the Business Combination"
 and placed a "high significance weighing on this factor." Additionally, please
 explain what consideration the Board gave to reapproving or reevaluating their determination
 that the Business Combination is in the best interests of, and advisable to, the Globalink
 stockholders following the termination of the vast majority of the PIPE Investments and the
 removal of the Earnout Shares from the consideration payable to Globalink shareholders.

 Response :
In response to the Staff's comment, we revised our disclosure throughout Amendment No. 2 to clarify that the dollar amount of the
PIPE Investments that the Board considered when initially determining to approve the transaction was US$40.2 million and that the Board
placed a high significance weighing on this factor. Additionally, we revised our disclosure on pages 34 and 129 of Amendment
No. 2 to explain the consideration the Board gave to reevaluating their determination that the Business Combination is still in the best
interests of, and advisable to, the Globalink stockholders following the termination of the vast majority of the PIPE Investments and
the removal of the Earnout Shares from the consideration payable to Alps Holdco shareholders.

 Management's
Discussion and Analysis of Financial Condition and Results of Operations of ALPS

 Cost
of sales, page 236

 3. Here
 you discussed three partners to provide specialized medical and aesthetic services under
 profit sharing arrangement. Please update your related revenue recognition accounting policies
 for principal versus agent including at page F-72 as it currently only refers to hair implant
 services.

 Response:
We have updated the revenue recognition accounting policy on page F-72 to include the principal versus agent considerations for the specialized
medical and aesthetic services provided under profit-sharing arrangements with the partners. Please refer below for the amendments:

 ‘‘For
hair implant services, specialised medical and aesthetic services, the Group exercises control over the delivery of the service before
it reaches the customer. Consequently, the Group is deemed a principal for these services and recognises revenue based on the total amount
charged to the customer.''

 Financial
Statements of Alp Life Sciences Inc., page F-116

 4. In
 regards to the financial statements for Alps Life Science Inc, please address the following:

 ● We
 note that for the unaudited financial statements for the six months ended September 30, 2024
 you are also presenting financial statements for the six months ended September 30, 2023,
 which is prior to inception. Please clarify in your disclosures whether these are the financial
 statements of Alps Global Holding Berhad. Please also address what consideration you gave
 as to whether Alps Global Holding Berhad should be considered the predecessor entity pursuant
 to Rule 405 of Regulation C in the audited financial statements.

 Response:
In response to the Staff's comment, we have revised the financial statements to include a note on page F-155 clarifying that the
comparative figures presented in the unaudited financial statements for the six months ended September 30, 2024 and September 30, 2023
reflect the historical financial information of Alps Global Holding Berhad ("AGHB"), the legal predecessor to Alps Life Sciences
Inc. prior to the corporate reorganization.

 We
have also considered the applicability of Rule 405 of Regulation C and concluded that AGHB qualifies as the predecessor entity of Alps
Life Sciences Inc. This conclusion is based on the continuity of business operations, management, and ownership between AGHB and Alps
Life Sciences Inc. The reorganization did not result in a substantive change to the business, and the current operations of the Company
are a continuation of AGHB's historical activities.

 Accordingly,
AGHB has been presented as the predecessor entity in the unaudited financial statements, and its historical financial information is
included for comparative purposes in the unaudited interim financial statements.

 ● Please
 address what consideration you gave to Item 8.A.4 of the Form 20-F in determining when the
 audited annual financial statements should be updated.

 Response:
In response to the Staff's comment, the first financial year end of Alps Life Science Inc is determined to be on March 31, 2025.
The latest audited financials for Alps Life Science Inc are for the financial period May 31, 2024. Item 8.A.4 of the Form 20-F requires
that the last year of audited financial statements may not be older than 15 months at the time of the offering or listing. Accordingly,
the audited annual financial statements as of May 31, 2024, remain valid within the 15-month period permitted for a Foreign Private Issuer
(FPI) and will be updated with the financial statements for the year ended March 31, 2025, upon expiry of the validity period.

 Financial
Statements of Cilo Cybin Holdings Limited, page F-180

 5. Please
 include the independent auditor's report and consent for the financial statements of
 Cilo Cybin Holdings Limited.

 Response:
In response to the Staff's comment, the independent auditor's report for the financial statements of Cilo Cybin Holdings
Limited has been included at pages F-191 to F-193 of Amendment No. 2. The auditor's consent has been annexed as Exhibit 23.5.

 Exhibit
23.2, page EX-23

 6. We
 note your response to previous comment four. Please address the following:

 ● As
 previously requested, please have your auditor revise the consent to separately refer to
 the specific dates of the auditor’s report including both original and updated report
 dates. For example for the financial statements of Alps Global Holding Berhad, the consent
 should refer to the various specific report dates which include June 18, 2024, August 12,
 2024, and December 4, 2024.

 Response:
We have amended the consent letter date to include June 18, 2024 and August 12, 2024.

 ● The
 consent for ALPS Global Holding Pubco does not appear to refer to the appropriate report
 date. Please have your auditor revise as necessary.

 Response:
We have amended the consent letter to report date on September 27, 2024.

 General

 7. We
 note your response to previous comment 5 and your revised disclosure that while you do not
 believe it is possible for Globalink to regain compliance with the continued listing requirements
 of Nasdaq or otherwise get listed on Nasdaq again prior to the Closing, you still expect
 to be able to satisfy the conditions to the consummation of the Business Combination and
 do not expect to seek a waiver or amendment of these closing conditions. Notwithstanding
 the possibility of PubCo's securities receiving listing approval while Globalink's
 securities remain delisted, please explain whether the continued delisting of Globalink's
 securities would prevent you from satisfying the closing conditions under the Business Combination
 Agreement. Specifically, we note that Section 6.10 of the Amended and Restated Merger Agreement
 appears to include a representation that Globalink's securities are listed on Nasdaq
 and Section 10.3(b) appears to require this representation to be brought down as of the Closing
 Date in all material respects.

 Response:
In response to the Staff's comment, we revised our disclosure on the cover page and pages 38, 41, 77, 96 and 164
of Amendment No. 2 to clarify that the parties has executed an amendment to the Amended and Restated Merger Agreement to remove
Section 6.10 as a closing condition, and that we still expect to be able to satisfy the conditions to the consummation of the Business
Combination, and to the extent that certain closing conditions cannot be satisfied prior to the Closing as a result of the delisting
of Globalink's securities from Nasdaq, we expect to seek a waiver or amendment of the applicable closing condition.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 11, 2025

Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia

 Re: Alps Global Holding Pubco
 Amendment No. 1 to Registration Statement on Form F-4
 Filed April 1, 2025
 File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our January 17,
2025 letter.
 April 11, 2025
Page 2

Amendment No. 1 to Registration Statement on Form F-4 filed April 1, 2025
Availability and terms of PIPE Investment, page 34

1. We note your disclosure on page 34 that the Board negotiated the terms
of the PIPE
 Investment with Alps and mutually agreed that the PIPE Investment would
be used
 for PubCo s working capital after the Business Combination. Please
revise your filing
 to include risk factor disclosure that addresses how the changes to the
PIPE
 Investment could impact PubCo s ability to operate its business after
the closing.
Background of the Business Combination, page 126

2. We note your disclosure that the verbal commitment to securing PIPE
Investments
 was what the Globalink Board considered as the primary basis for the
pre-money
 valuation of Alps of approximately $1.6 billion and that the Board
placed a high
 significance weighting on the availability and terms of the PIPE
Investments in
 approving the transaction. Your disclosure of the dollar amount of the
PIPE
 Investments that the Board considered when determining to approve the
 transaction was reduced from US$40.23 million to US$3.48 million. This
appears to
 reflect the smaller available PIPE investment after the termination of
two of the
 Subscription Agreements in March 2025. Given that the Board approved the
 transaction in January 2024, please clarify the information the Board
relied upon at
 the time it made its determination to approve the transaction. In this
regard, we note
 your statement on page 129 that the Board "considered the availability
and terms of
 the PIPE Investment prior to approving the Business Combination" and
placed a "high
 significance weighing on this factor." Additionally, please explain what
consideration
 the Board gave to reapproving or reevaluating their determination that
the Business
 Combination is in the best interests of, and advisable to, the Globalink
stockholders
 following the termination of the vast majority of the PIPE Investments
and the
 removal of the Earnout Shares from the consideration payable to
Globalink
 shareholders.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
ALPS
Cost of sales, page 236

3. Here you discussed three partners to provide specialized medical and
aesthetic
 services under profit sharing arrangement. Please update your related
revenue
 recognition accounting policies for principal versus agent including at
page F-72 as it
 currently only refers to hair implant services.
Financial Statements of Alp Life Sciences Inc., page F-116

4. In regards to the financial statements for Alps Life Science Inc, please
address the
 following:
 We note that for the unaudited financial statements for the six
months ended
 September 30, 2024 you are also presenting financial statements for
the six
 April 11, 2025
Page 3

 months ended September 30, 2023, which is prior to inception. Please
clarify in
 your disclosures whether these are the financial statements of Alps
Global
 Holding Berhad. Please also address what consideration you gave as
to whether
 Alps Global Holding Berhad should be considered the predecessor
entity pursuant
 to Rule 405 of Regulation C in the audited financial statements.

 Please address what consideration you gave to Item 8.A.4 of the
Form 20-F in
 determining when the audited annual financial statements should be
updated.
Financial Statements of Cilo Cybin Holdings Limited, page F-180

5. Please include the independent auditor s report and consent for the
financial
 statements of Cilo Cybin Holdings Limited.
Exhibit 23.2, page EX-23

6. We note your response to previous comment four. Please address the
following:
 As previously requested, please have your auditor revise the consent
to separately
 refer to the specific dates of the auditor s report including both
original and
 updated report dates. For example for the financial statements of Alps
Global
 Holding Berhad, the consent should refer to the various specific
report dates
 which include June 18, 2024, August 12, 2024, and December 4, 2024.
 The consent for ALPS Global Holding Pubco does not appear to refer
to the
 appropriate report date. Please have your auditor revise as necessary.
General

7. We note your response to previous comment 5 and your revised disclosure
that while
 you do not believe it is possible for Globalink to regain compliance
with the continued
 listing requirements of Nasdaq or otherwise get listed on Nasdaq again
prior to the
 Closing, you still expect to be able to satisfy the conditions to the
consummation of
 the Business Combination and do not expect to seek a waiver or amendment
of these
 closing conditions. Notwithstanding the possibility of PubCo's
securities receiving
 listing approval while Globalink's securities remain delisted, please
explain whether
 the continued delisting of Globalink's securities would prevent you from
satisfying the
 closing conditions under the Business Combination Agreement.
Specifically, we note
 that Section 6.10 of the Amended and Restated Merger Agreement appears
to include
 a representation that Globalink's securities are listed on Nasdaq and
Section 10.3(b)
 appears to require this representation to be brought down as of the
Closing Date in all
 material respects.
 Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.
 April 11, 2025
Page 4

 Sincerely,

 Division of Corporation Finance
 Office of Industrial Applications and
 Services
cc: Jenny Chen-Drake, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 VIA
EDGAR

 March
31, 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

 Registration Statement on Form F-4
 Filed
 December 3, 2024

 File
 No. 333-284035

 Dear
Mr. Danberg:

 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 January 17, 2025 (the " Comment Letter ")
with respect to the Registration Statement on Form F-4 filed with the Commission on December 23, 2024 (the " Registration Statement ")
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 Registration Statement where the language addressing a particular comment appears. Capitalized
terms used but not defined herein have the meanings set forth in Amendment No. 4.

 The
Company has revised the Registration Statement in response to the Staff's comments and is concurrently submitting Amendment No.1
to Registration Statement on Form F-4 (the " Amended F-4 ") with this letter, which reflects these revisions and updates
and clarifies certain other information.

 Registration
Statement on Form F-4 filed December 23, 2024

 Background
of the Business Combination, page 119

 1.
 We note your response to prior comment 2. Please address the following:

 ●
 We
 note that as of March 31, 2024, Alps has not commenced operations for its Car-T, NK Cells and blood testing segments. Please disclose
 if and when these operations have started subsequent to March 31, 2024;

 Response:
 In response to the Staff's comment, we respectfully advise the Staff that Alps has not commenced operations for its Car-T,
 NK Cells and blood testing services subsequent to March 31, 2024. We have revised our disclosure on page 122 of the Amended F-4
 accordingly.

 ●
 Please
 specifically disclose on page 122 your basis for assuming that the NK Cell, Car-T and Mesenchymal Stem Cells treatments can be utilized
 under compassionate use at your projected scale and growth rate, as well as the current status of the pending regulatory approval.

 Response:
 In response to the Staff's comment, we have revised our disclosure on page 122 of the Amended F-4 to clarify and provide the
 basis for assuming that NK Cell, Car-T, and Mesenchymal Stem Cell treatments can be utilized under compassionate use at the projected
 scale and growth rate. Alps reiterates that this assumption is based on Alps' interpretation of Malaysia's regulatory
 framework, which permits the use of unregistered medicinal products under compassionate use, to address unmet medical needs. NK Cell,
 Car-T, and Mesenchymal Stem Cell treatments fall within the defined scope of CGTPs under the Malaysia's regulatory framework.
 The projected scale and growth rates are premised on Alps' understanding that compassionate use may proceed within this framework,
 subject to ongoing compliance with all applicable laws and regulations.

 Additionally,
 we have included the disclosure regarding the current status of the regulatory approval applications for NK Cell, Car-T and Mesenchymal
 Stem Cells treatments on page 122 of the Amended F-4.

 Executive
Compensation

 Globalink,
page 266

 2.
 Please
 update your executive compensation disclosure to include compensation for Globalink's most recently completed fiscal year.
 Refer to Item 402 of Regulation S-K.

 Response:
In response to the Staff's comment, we revised our disclosure on page 267 of Amendment No. 1 to the Form F-4 to disclose executive
compensation for Globalink's most recently completed fiscal year.

 Note
9. Investment in Associates, page F-83

 3.
 We
 note your response to prior comment 4. Please revise and ensure that each column of the restated financial statements are labeled
 as "restated" on the face of each respective financial statement. In addition, please tell us what consideration you
 gave to providing financial information pursuant to Rule 3-09 of Regulation S-X in regards to your investment in Cilo Cybin Holdings
 Limited.

 Response:
 In response to the Staff's comment, we had revised the financial statement by labelling "restated" on the face
 of each respective financial statement.

 Rule
 3-09 of Regulation S-X, under the Securities and Exchange Commission (SEC) rules, mandates that a company must include separate audited
 financial statements for "significant" equity investments that are accounted for using the equity method in their consolidated
 financial statements. Investment in Cilo Cybin is significant, hence included the audited financial statement of Cilo Cybin from
 pages F-180 to F-209.

 Exhibit
23.2, page EX-23

 4.
 If
 your auditor uses one consent to cover all three sets of financial statements for three entities, please have your auditor revise
 to clearly and separately refer to each entity name, the related financial statement periods consistent with the auditor's
 report, and specific dates of auditor's report including both original and updated report dates.

 Response:
 In response to the Staff's comment, we had revised the consent to clearly and separately refer to each entity name, the related
 financial statement periods consistent with the auditor's report, and specific dates of auditor's report including both
 original and updated report dates.

 General

 5.
 We
 note your response to prior comment 7 and reissue the comment in part. Your disclosure states that you are "no longer in compliance
 with Nasdaq listing rules" and that "[f]ollowing the desilting of [y]our securities from the Nasdaq, PubCo may face increased
 difficulties and uncertainties in meeting the initial and continued listing requirement of Nasdaq..." You also disclose that
 Globalink's units, common stock, public warrants and public rights are traded on the OTC Pink. Please revise to update your
 disclosure to clearly disclose that Globalink's securities have been delisted from Nasdaq and whether you believe it is possible
 for Globalink to regain compliance with the continued listing requirements of Nasdaq. Additionally, because one of the conditions
 to the consummation of the business combination is the listing by Nasdaq of the PubCo ordinary shares and PubCo warrants and satisfaction
 of initial and continued listing requirements as disclosed on page 29, please update your disclosure to address whether you expect
 to be able to satisfy the conditions to the consummation of the business combination. If you plan to seek a waiver or amendment of
 this closing condition, please explain this clearly along with the associated risks.

 Response:
 In response to the Staff's comment, we have revised the disclosure in the risk factor titled " Our securities were
 suspended from trading and delisted from Nasdaq on December 17, 2024, following receipt of a delisting determination letter from
 Nasdaq on December 10, 2024. This could have significant material adverse consequences on us and our securities, including that it
 will negatively impact our ability to complete a Business Combination, will limit investors' ability to make transactions in
 our securities and could subject us to additional trading restrictions " on page 77 of Amendment No. 1 to the Form F-4
 and revised the cover page and throughout Amendment No. 1 Form F-4 to clearly disclose that (i) Globalink's securities have
 been delisted from Nasdaq and we do not believe it is possible for Globalink to regain compliance with the continued listing requirements
 of Nasdaq or otherwise get listed on Nasdaq again prior to the Closing, and (ii) we expect to be able to satisfy the conditions to
 the consummation of the Business Combination and do not expect to seek a waiver or amendment of these closing conditions.

 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

January 17, 2025
Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Re:Alps Global Holding Pubco
Registration Statement on Form F-4
Filed December 23, 2024
File No. 333-284035
Dear Say Leong Lim and Tham Seng Kong:
            We have reviewed your registration statement and have the following comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our November 22,
2024 letter.

January 17, 2025
Page 2

Registration Statement on Form F-4 filed December 23, 2024
Background of the Business Combination, page 119
1.We note your response to prior comment 2. Please address the following:
•We note that as of March 31, 2024, Alps has not commenced operations for its
Car-T, NK Cells and blood testing segments. Please disclose if and when these
operations have started subsequent to March 31, 2024; and
•Please specifically disclose on page 122 your basis for assuming that the NK Cell,
Car-T and Mesenchymal Stem Cells treatments can be utilized under
compassionate use at your projected scale and growth rate, as well as the current
status of the pending regulatory approval.
Executive Compensation
Globalink, page 266
2.Please update your executive compensation disclosure to include compensation for
Globalink's most recently completed fiscal year. Refer to Item 402 of Regulation S-K.
Note 9. Investment in Associates, page F-83
3.We note your response to prior comment 4. Please revise and ensure that each column
of the restated financial statements are labeled as “restated” on the face of each
respective financial statement. In addition, please tell us what consideration you gave
to providing financial information pursuant to Rule 3-09 of Regulation S-X in regards
to your investment in Cilo Cybin Holdings Limited.

Exhibit 23.2, page EX-23
4.If your auditor uses one consent to cover all three sets of financial statements for three
entities, please have your auditor revise to clearly and separately refer to each entity
name, the related financial statement periods consistent with the auditor's report, and
specific dates of auditor's report including both original and updated report dates.
General
We note your response to prior comment 7 and reissue the comment in part. Your
disclosure states that you are "no longer in compliance with Nasdaq listing rules" and
that "[f]ollowing the desilting of [y]our securities from the Nasdaq, PubCo may face
increased difficulties and uncertainties in meeting the initial and continued listing
requirement of Nasdaq..." You also disclose that Globalink’s units, common stock,
public warrants and public rights are traded on the OTC Pink. Please revise to update
your disclosure to clearly disclose that Globalink’s securities have been delisted from
Nasdaq and whether you believe it is possible for Globalink to regain compliance with
the continued listing requirements of Nasdaq. Additionally, because one of the
conditions to the consummation of the business combination is the listing by Nasdaq
of the PubCo ordinary shares and PubCo warrants and satisfaction of initial and 5.

January 17, 2025
Page 3
continued listing requirements as disclosed on page 29, please update your disclosure
to address whether you expect to be able to satisfy the conditions to the consummation
of the business combination. If you plan to seek a waiver or amendment of this
closing condition, please explain this clearly along with the associated risks.
            Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391 if you have
questions regarding comments on the financial statements and related matters. Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Jenny Chen-Drake, Esq.

CORRESP
1
filename1.htm

VIA
EDGAR

December
23, 2024

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. 4 to Draft Registration Statement on Form F-4

    Submitted
    November 6, 2024

    CIK
    No. 0002025774

Dear
Mr. Danberg:

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 Securities and Exchange
Commission (the “Commission”) in its letter dated November 22, 2024 (the “Comment Letter”) with
respect to the Amendment No. 4 to Draft Registration Statement on Form F-4 confidentially submitted to the Commission on November 6,
2024 (“Amendment No. 4”) 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 Amendment No.4 where the language addressing a particular comment appears. Capitalized terms used
but not defined herein have the meanings set forth in Amendment No. 4.

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

Amendment
No. 4 to Draft Registration Statement on Form F-4

Question:
What happens if the Business Combination is not consummated?, page 24

    1.
    Please
    revise to update your disclosure here and throughout with respect to the deadline to complete the initial business combination

    Response:
    In response to the Staff’s comment, we revised our disclosure on page 24 and throughout the Form F-4 to update the disclosure
    with respect to the deadline to complete the initial business combination.

Background
of the Business Combination, page 119

  2.
  We note your response
  to comment three. Given the limited actual revenues for Alps for the year ended March 31, 2024 of only $2.4 million compared to projected
  fiscal year 2025 revenues of $13.6 million, we would expect more detailed disclosures regarding the basis for such significant revenue
  growth assumptions. Please specifically address the following:

•
The majority of projected revenues appear to be associated with the NK Cell, Car-T and blood testing segments for which Alps has yet
to commence operations as of March 31, 2024. The disclosures indicate that the respective projected revenues have been determined based
on Alps’ management assessment of the current market outlook and future strategic business plans. Please give better insight as
to the basis for management’s assessment, including what specific information was used and any significant estimates and assumptions
used to arrive at projected revenues based on this information. Please also disclose whether Alps has subsequently started these operations;

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure in response to the Staff’s comment on pages 122
and 123 of Form F-4. The Registrant respectfully notes that the projections were prepared and provided to the Company on January
23, 2024, and therefore reflect the information and assumptions available as of that date.

Furthermore,
as of March 31, 2024, Alps has not commenced operations for its Car-T, NK Cells and blood testing segments. We have disclosed accordingly
on page 123 of the Form F-4.

•
In terms of regulatory approval, we note that Alps assumes that its NK Cell, Car-T and Mesenchymal Stem Cells treatments can be utilized
in the Malaysian market under compassionate use, pending regulatory approval. Please disclose your basis for assuming that these treatments
can be utilized under compassionate use as well as the current status of the pending regulatory approval. Specifically clarify whether
the entire current revenue projection is based on compassion use, and if not, revise to disclose your projected regulatory approval built
in the model; and

Response:
We acknowledge the Staff’s comments and would like to clarify that the Company assumes that its NK Cell, Car-T, and Mesenchymal
Stem Cell treatments can be utilized under compassionate and/or investigational use. To date, the National Pharmaceutical Regulatory
Agency (“NPRA”) has not promulgated any written notice to challenge such use of cell and gene therapy products (“CGTPs”)
under such conditions. At present, Alps is of the view that its NK Cell, Car-T, and Mesenchymal Stem Cell treatments fall within the
scope of CGTPs.

Alps’
assumptions regarding the utilization of CGTPs are
based on its current understanding and interpretation of applicable regulations. Alps intends to ensure continuous compliance to the
changing legal and regulatory framework applicable to CGTPs.

As
such, we have revised the disclosure on the risk factor on page 59 of Form F-4 accordingly.

In
response to the Staff’s comment regarding the status of the pending regulatory approval, the Company wish to reiterate the disclosure
on page 173 of Form F-4 and clarifies that the application for regulatory approval to NPRA and/or other relevant governmental authorities
as a registered product is underway. The following outlines the current status of the respective pipelines. For the avoidance of
doubt, the regulatory approval process is contingent upon fulfilling all necessary regulatory requirements.

  No

  Pipeline

    Current
    Phase

  1.

  Natural Killer (“NK”) Cell
  Therapy–MyImmune

    The POC for NK cell therapy
    comprises of discovery, optimization, and process validation phase. Celestialab has completed the optimization phase, which aimed
    at culturing NK cells to achieve high-yield and high-purity. Currently Celestialab is preparing to commence the process validation
    phase, which will include the completion of consecutive process replication and media-fill tests.

  2.

  Chimeric Antigen Receptor (“CAR”)-T
  Cell

    Celestialab has concluded
    the discovery phase of its POC, identifying (i) CD19, (ii) CD20, or (iii) dual targeting of CD19 and CD22, as key targets for B-cell
    acute lymphoblastic leukemia and B-cell lymphoma. Celestialab is now preparing to start the optimization phase, which will include
    creating plasmid DNA (“pDNA”) templates.

  3.

  Diabetes – MYCELEST

    Celestialab is completing
    the preclinical studies phase for MYCELEST and is currently preparing the preclinical data for submission of the dossier application
    to the NPRA.

Based
on the above discussion, the regulatory application process for these products is separate from the ongoing utilization of CGTP treatments
under compassionate and/or investigational use. Therefore, the Company wishes to inform the Staff that the current revenue projections
are based on the assumption that its NK Cell, Car-T, and Mesenchymal Stem Cell treatments can be utilized under compassionate and/or
investigational use.

•
The table at page 132 for actual revenue track records for the fiscal years ended March 31, 2021, 2022, 2023, and 2024 appears to have
omitted some revenue components in at least FY2023. Please ensure the balances presented here agree with your historical financial statements,
and/or clearly explain any differences if needed.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure in response to the Staff’s comment on pages 132
of Form F-4.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 236

    3.
    We
    note your response to comment seven. Please clearly disclose that you have excluded salaries and payroll costs for employees engaged
    in research activities from the research expenses component of administrative expenses and instead included them in the payroll costs
    component. Please also disclose your basis for this presentation.

    Response:
    The Company acknowledges the Staff’s comment and has revised the disclosure in response to the Staff’s comment. on page
    238 of Form F-4. It has not been Alps’ historical practice to track individually, salaries and payroll costs because these
    expenses are shared across multiple pipelines and Alps does not allocate a specific employee to a specific pipeline. In presenting
    its Management’s Discussion and Analysis of Financial Condition and Results of Operations, the Company assessed the relative
    significance of individually tracked salaries and payroll costs to specific pipelines. Based on this assessment, the Company determined
    that it is neither practical nor meaningful to attribute payroll costs to individual pipelines. Additionally, there is no significant
    link between payroll costs and any specific pipeline.  Accordingly, salaries and payroll costs for employees engaged in research
    activities have been excluded from the research expenses component of administrative expenses and included instead in the payroll
    costs component.

Note
1. Corporate Information, page F-68

    4.
    We
    note your response to comment 11. It remains unclear how you determined that you do not have significant influence in Cilo Sybin
    given your 40.5% stake, your representation on the board of directors, as well as the other factors noted. We note Cilo Sybin was
    incorporated for the purpose of being listed as a SPAC to pursue acquisitions of, and investments in, commercial enterprises operating
    in the biotech, biohacking or pharmaceutical sector. It appears that the primary activities this entity is engaged in at this time
    are raising capital and identifying a target company. Please tell us what role you have in these primary activities, including what
    influence you have in the final decision making process. Also tell us who determines the SPAC’s financial and operating policies,
    if not the board of directors, as indicated in your response.

    Response:
    The Company acknowledges the Staff’s comment, and Alps’ management has conducted a thorough reassessment regarding
    the investment in Cilo Cybin. Following this critical reassessment, Alps’ management has determined and concluded that Alps
    has significant influence over Cilo Cybin, and has revised the disclosures on pages F-60 to F-62, F-64, F-65, F-82 to F-83, F-85
    and F-100 of Form F-4 accordingly.

Note
13. Related Party Transactions, page F-85

    5.
    In
    a similar manner to your response, please further expand your disclosures pursuant to IAS 24.18 to disclose when you expect to settle
    these amounts and the nature of the consideration to be provided in settlement.

    Response:
    In response to the Staff’s comment, the Company has revised Note 13 to the financial statements on page F-85 of  Form
    F-4.

General

    6.
    You
    state in your response to prior comment nine that Alps Life Sciences Inc. is identified and designated as the primary operating company
    post completion of the Business Combination and that Alps Global Holding Berhad is now a wholly owned subsidiary of Alps Life Sciences
    Inc. Please revise to describe and identify the management team, including executive officers and directors, of Alps Life Sciences
    Inc. at effectiveness of the registration statement.

    Response:
                                            In response to the Staff’s comment, we have revised the disclosure on pages 261 of
                                            the Form F-4 to provide clarity.

    7.
    We
    note that Globalink’s initial public offering closed on December 9, 2021. We also note that you are currently listed on Nasdaq
    and that Nasdaq Rule 5815 was amended effective October 7, 2024 to provide for the immediate suspension and delisting upon issuance
    of a delisting determination letter for failure to meet the requirement in Nasdaq Rule IM 5101-2(b) to complete one or more business
    combinations within 36 months of the date of effectiveness of its IPO registration statement. Please include disclosure to state
    that your securities will face immediate suspension and delisting action once you receive a delisting determination letter from Nasdaq
    after the 36-month window ends. Please disclose the risks of non-compliance with this rule, including that under the new framework,
    Nasdaq may only reverse the determination if it finds it made a factual error applying the applicable rule. In addition, please also
    disclose the consequences of any such suspension or delisting, including that your stock may be determined to be a penny stock and
    the consequences of that designation, that you may no longer be attractive as a merger partner if you are no longer listed on an
    exchange, any potential impact on your ability to complete an initial business combination, any impact on the market for your securities
    including demand and overall liquidity for your securities, and any impact on securities holders due to your securities no longer
    being considered “covered securities.” We also note that you also disclose on page 29 that one of the conditions to consummation
    of the business combination is the listing by Nasdaq of the PubCo ordinary shares and PubCo warrants and satisfaction of initial
    and continued listing requirements. Please update your disclosure accordingly.

    Response:
    In response to the Staff’s comment, we included an additional risk factor titled “Our securities were suspended
    from trading and delisted from Nasdaq on December 17, 2024, following receipt of a delisting determination letter from Nasdaq on
    December 10, 2024. This could have significant material adverse consequences on us and our securities, including that it will negatively
    impact our ability to complete a Business Combination, will limit investors’ ability to make transactions in our securities
    and could subject us to additional trading restrictions” on page 77 of the Form F-4 and revised the cover page
    and throughout the Form F-4 to disclose that Globalink will be delisted from Nasdaq upon reaching the third anniversary of its IPO.

    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

November 22, 2024
Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Re:Alps Global Holding Pubco
Amendment No. 4 to Draft Registration Statement on Form F-4
Submitted November 6, 2024
CIK No. 0002025774
Dear Say Leong Lim and Tham Seng Kong:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our October 29, 2024 letter.

November 22, 2024
Page 2
Amendment No. 4 to Draft Registration Statement on Form F-4
Question: What happens if the Business Combination is not consummated?, page 24
1.Please revise to update your disclosure here and throughout with respect to the
deadline to complete the initial business combination.
Background of the Business Combination, page 119
2.We note your response to comment three. Given the limited actual revenues for Alps
for the year ended March 31, 2024 of only $2.4 million compared to projected fiscal
year 2025 revenues of $13.6 million, we would expect more detailed disclosures
regarding the basis for such significant revenue growth assumptions. Please
specifically address the following:
•The majority of projected revenues appear to be associated with the NK Cell, Car-
T and blood testing segments for which Alps has yet to commence operations as
of March 31, 2024. The disclosures indicate that the respective projected revenues
have been determined based on Alps’ management assessment of the current
market outlook and future strategic business plans. Please give better insight as to
the basis for management's assessment, including what specific information was
used and any significant estimates and assumptions used to arrive at projected
revenues based on this information. Please also disclose whether Alps has
subsequently started these operations;
•In terms of regulatory approval, we note that Alps assumes that its NK Cell, Car-
T and Mesenchymal Stem Cells treatments can be utilized in the Malaysian
market under compassionate use, pending regulatory approval. Please disclose
your basis for assuming that these treatments can be utilized under compassionate
use as well as the current status of the pending regulatory approval. Specifically
clarify whether the entire current revenue projection is based on compassion use,
and if not, revise to disclose your projected regulatory approval built in the model;
and
•The table at page 132 for actual revenue track records for the fiscal years ended
March 31, 2021, 2022, 2023, and 2024 appears to have omitted some revenue
components in at least FY2023. Please ensure the balances presented here agree
with your historical financial statements, and/or clearly explain any differences if
needed.
Management's Discussion and Analysis of Financial Condition and Results of Operations,
page 236
3.We note your response to comment seven. Please clearly disclose that you have
excluded salaries and payroll costs for employees engaged in research activities from
the research expenses component of administrative expenses and instead included
them in the payroll costs component. Please also disclose your basis for this
presentation.
Note 1. Corporate Information, page F-68
We note your response to comment 11. It remains unclear how you determined that 4.

November 22, 2024
Page 3
you do not have significant influence in Cilo Sybin given your 40.5% stake, your
representation on the board of directors, as well as the other factors noted. We note
Cilo Sybin was incorporated for the purpose of being listed as a SPAC to pursue
acquisitions of, and investments in, commercial enterprises operating in the biotech,
biohacking or pharmaceutical sector. It appears that the primary activities this entity is
engaged in at this time are raising capital and identifying a target company. Please tell
us what role you have in these primary activities, including what influence you have
in the final decision making process. Also tell us who determines the SPAC's financial
and operating policies, if not the board of directors, as indicated in your response.
Note 13. Related Party Transactions, page F-85
5.In a similar manner to your response, please further expand your disclosures pursuant
to IAS 24.18 to disclose when you expect to settle these amounts and the nature of the
consideration to be provided in settlement.
General
6.You state in your response to prior comment nine that Alps Life Sciences Inc. is
identified and designated as the primary operating company post completion of the
Business Combination and that Alps Global Holding Berhad is now a wholly owned
subsidiary of Alps Life Sciences Inc. Please revise to describe and identify the
management team, including executive officers and directors, of Alps Life Sciences
Inc. at effectiveness of the registration statement.
7.We note that Globalink's initial public offering closed on December 9, 2021. We also
note that you are currently listed on Nasdaq and that Nasdaq Rule 5815 was amended
effective October 7, 2024 to provide for the immediate suspension and delisting upon
issuance of a delisting determination letter for failure to meet the requirement in
Nasdaq Rule IM 5101-2(b) to complete one or more business combinations
within 36 months of the date of effectiveness of its IPO registration statement. Please
include disclosure to state that your securities will face immediate suspension and
delisting action once you receive a delisting determination letter from Nasdaq after
the 36-month window ends. Please disclose the risks of non-compliance with this rule,
including that under the new framework, Nasdaq may only reverse the determination
if it finds it made a factual error applying the applicable rule. In addition, please also
disclose the consequences of any such suspension or delisting, including that your
stock may be determined to be a penny stock and the consequences of that
designation, that you may no longer be attractive as a merger partner if you are no
longer listed on an exchange, any potential impact on your ability to complete an
initial business combination, any impact on the market for your securities including
demand and overall liquidity for your securities, and any impact on securities holders
due to your securities no longer being considered “covered securities.” We also note
that you also disclose on page 29 that one of the conditions to consummation of the
business combination is the listing by Nasdaq of the PubCo ordinary shares and
PubCo warrants and satisfaction of initial and continued listing requirements. Please
update your disclosure accordingly.
            Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391 if you have

November 22, 2024
Page 4
questions regarding comments on the financial statements and related matters. Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Jenny Chen-Drake, Esq.

October 29, 2024
Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Re:Alps Global Holding Pubco
Amendment No. 3 to Draft Registration Statement on Form F-4
Submitted October 2, 2024
CIK No. 0002025774
Dear Say Leong Lim and Tham Seng Kong:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our September 18, 2024 letter.

October 29, 2024
Page 2
Amendment No. 3 to Draft Registration Statement on Form F-4
Cover Page
1.We note your revised disclosure in response to previous comment 1. Please expand
your disclosure to note the $3.55 million in promissory notes Globalink issued to
PGM that are repayable upon consummation of an initial business combination. In
this regard, we note that you disclose elsewhere that PGM is an affiliate of the
Sponsor.
Escrow Agreement, page 114
2.We note your revised disclosure in response to previous comment 5 and your
statement that "[t]he Alps Holdco Shareholders will remain liable for any
indemnification claims made after the Escrow Expiry Date." On page 109, you note
that "[e]xcept for fraud claims, the maximum aggregate amount of indemnification
payments shall not exceed the amount of the Escrow Property in the Escrow Account
at such time." Assuming all of the Escrow Property is distributed to the Alps Holdco
Shareholders after the Escrow Expiry Date, it would appear that, other than fraud
claims, the maximum amount of indemnification payments would be zero given there
would no longer be any Escrow Property in the Escrow Account at such time. If true,
please note this in your disclosure and explain the impact it would have on the Alps
Holdco Shareholders indemnification liability after the Escrow Expiry Date.
Background of the Business Combination
Forecasted Discounted Cashflow, page 122
3.You disclose here that Alps used the estimated management accounts for the year
ended March 31, 2024 as the base for the forecast, while the percentages of revenue
and costs averages are from Alps' historical financial statements for the fiscal years
ended March 31, 2021, 2022 and 2023. Please provide a detailed explanation of your
basis for revenue growth in light of the significant revenue decline in fiscal 2024. You
also disclose under the Fairness Opinion at pages 128-133 that Alps Holdco was still
early-stage, and the revenue trajectory is based on key regulatory approval milestones
being achieved. Please expand your disclosures to provide the details of your revenue
growth assumptions including the related regulatory approval milestones expected. In
that regard, we note your disclosures that the forecasts represents the views of the
management and board of directors of Alps as of the date of this proxy
statement/prospectus. Refer to Item 1609(b) of Regulation S-K.
We note the disclosure that "The management and board of directors of Alps have
reviewed and affirmed the forecasts and that the forecasts represents the views of the
management and board of directors of Alps as of the date of this proxy
statement/prospectus." Revise to specifically disclose whether or not Alps has
affirmed to Globalink that its projections reflect the view of management or board of
directors (or similar governing body) about its future performance as of the most
recent practicable date prior to the date of the proxy statement/prospectus. If the
projections no longer reflect the views of Alps''s management or board of directors (or
similar governing body) regarding its future performance as of the most recent 4.

October 29, 2024
Page 3
practicable date prior to the date of the proxy statement/prospectus, clearly state the
purpose of disclosing the projections and the reasons for any continued reliance by the
management or board of directors (or similar governing body) on the projections.
Refer to Item 1609(c) of Regulation S-K.
Peer Price/Revenue Multiples, page 123
5.Despite the peer companies appearing to have reported significantly higher revenue
and earnings, Alps' market cap/revenue ratio appears to be significantly higher than
the peers listed here, and their average. Please disclose your basis for selecting the
peer companies, how management and the board used and relied on this financial
metric, and any potential limitation on its usefulness.
mRNA (Diagnostic), page 197
6.We note your response to previous comment 19 and the revised disclosure that the
"Panel is not a standalone diagnostic tool and does not detect the presence of such 31
diseases. Instead, the data and information provided by the Panel, when integrated
with additional bioinformatic data sequenced by MyGenome, will enhance its
predictive ability." You further disclose that in addition to using the Panel to develop
the mRNA diagnostic products, MyGenome also uses the Panel to provide genetic
screening services in its wellness clinic. Please revise your disclosure to clarify
whether you have any formal agreements with the manufacturer of the Panel.
Management's Discussion and Analysis of Financial Condition and Results of Operations of
Alps, page 225
7.We note your response to comment 21. Your disclosures continue to indicate that
certain expenses, particularly salaries and payroll costs, are not individually
tracked. However, we now note that total research expenses for all pipelines equals
the total research expenses amount as a component of Administrative expenses;
therefore it appears that these costs have been allocated or are included in another
component of Administrative expenses. Please advise and correspondingly clarify
your disclosures.
Unaudited Pro Forma Condensed Combined Financial Information, page 240
8.We note your response to comment 24. As discussed in your Anticipated Accounting
Treatment disclosures in the filing including on page 43, the deemed costs of the
shares issued by PubCo in excess of the net assets of Globalink will be accounted for
as stock-based compensation under IFRS 2. In this regard, it remains unclear why you
would not have also considered IFRS 2 in accounting for the corresponding earnout
shares. Please further advise. In regards to your reference to IAS 32, please help us
understand how you determined the earnout shares were not subject to a contingent
settlement feature ( i.e., a price adjustment mechanism) rather than a contractual
obligation to issue a variable number of equity instruments. Please also clarify if there
are any situations in which this earnout provision could be settled in cash or another
financial asset. Refer to paragraphs 20, 21, and 25 of IAS 32.

October 29, 2024
Page 4
Financial Statements, page F-1
9.We note your response to comment 27. Please address the following:
•Please help us understand how you determined that Alps Life Sciences Inc. rather
than Alps Global Holding Berhad is the operating company for purposes of Item
1601(d) of Regulation S-K and therefore included as the co-registrant. Refer to
General Instruction I to the Form F-4. Please also address what consideration was
given to providing the financial statements of Alps Life Sciences Inc. as the co-
registrant; and
•We note that Alps Life Sciences Inc. was incorporated in the Cayman Islands on
April 11, 2024. It appears that your response is indicating that the pro forma
financial information does reflect the common control transaction between Alps
Life Sciences Inc. and Alps Global Holding Berhad. Please further clarify in your
disclosures.
Alps Global Holding Berhad Consolidated Statement of Financial Position, page F-61
10.There appear to be revisions made to the audited balance sheet as of March 31, 2024
as well as the audited statement of cash flows for the year ended March 31, 2024. The
revised amounts include total current assets, total noncurrent assets, and total current
liabilities amounts. Please help us understand the nature of these revisions and
whether these represent corrections of errors as addressed in IAS 8.41 through 49. If
these adjustments are a correction of an error, please address your consideration of the
disclosures required by IAS 8.49. Please also have your auditor address the related
impact to their auditor report.
Note 1. Corporate Information, page F-68
11.We note your response to comment 28. As noted in IAS 28.5, it is presumed that an
entity has significant influence if it holds directly or indirectly 20 percent or more of
the voting power of the investee. In this regard, please provide us with a
comprehensive analysis addressing each of the factors listed under IAS 28.6
explaining how you determined that you do not have significant influence. We also
note that a director of the company also holds a 40.5% stake in Cilo Cybin. Please
address your consideration of this factor as well in your analysis.
Note 13. Related Party Transactions, page F-85
12.We note your response to comment 30. As previously requested, please also
address when you expect to settle any related party amounts due and the nature of the
consideration to be provided in settlement of any outstanding balances. Please also
address why there do not appear to be any disclosures in the notes to the financial
statements related to the patent license agreement with Dr. Tham Seng Kong as
disclosed at page 217.
            Please contact Nudrat Salik at 202-551-3692 or Li Xiao at 202-551-4391 if you have
questions regarding comments on the financial statements and related matters. Please contact
Conlon Danberg at 202-551-4466 or Lauren Nguyen at 202-551-3642 with any other

October 29, 2024
Page 5
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Jenny Chen-Drake, Esq.

September 18, 2024
Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Tham Seng Kong
Chief Executive Officer
Alps Life Sciences Inc
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Re:Alps Global Holding Pubco
Amendment No. 2 to Draft Registration Statement on Form F-4
Submitted August 21, 2024
CIK No. 0002025774
Dear Say Leong Lim and Tham Seng Kong:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do not believe an
amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
July 29, 2024 letter.

September 18, 2024
Page 2

Amendment No. 2 to Draft Registration Statement on Form F-4
Cover Page
1.We note your revised disclosure in response to previous comment 2. Please add
corresponding disclosure to the cover page of the prospectus or provide us an analysis
explaining why it is not required. Please refer to Item 1604(a)(3) of Regulation S-K.
Questions and Answers About the Special Meeting and the Proposals
Q: Do any of Globalink's directors or officers have interests that may conflict with my interests
with respect to the Business Combination, page 14
2.We note your disclosure in response to previous comment 8 that "[i]n connection with
funding the extensions, Globalink has issued an aggregate of more than US$3.5 million
in promissory notes to PGM." Please revise to state the actual aggregate amount of
promissory notes that have been issued to date instead of stating that the amount is over
US$3.5 million.
Parent Representative, page 28
3.We note your revised disclosure regarding the Parent Representative and Seller
Representative in response to previous comment 13. Please expand on these sections to
fully explain the roles of the Parent Representative and Seller Representative after the
closing of the Business Combination. In this regard, we note that pursuant to Section
13.20 of the Merger Agreement, the Sponsor will have the sole authority to handle
various matters relating to the Escrow Account and indemnifications under the Merger
Agreement. Please include disclosure regarding the ongoing role of the Sponsor when
discussing potential conflicts of interest. Finally, please expand on your statement that the
Sponsor "expects to act as the representative of the previous stockholders of Globalink"
to clarify if the Sponsor will have any specific fiduciary or contractual duties to the
previous stockholders of Globalink in its capacity as the Parent Representative.
Fairness Opinion, page 35
4.We note your disclosure that "[t]he Globalink Board received a draft of fairness opinion
from Morison Advisory Sdn. Bhd. in June 2024" but that "[t]he Globalink Board decided
not to rely on the fairness opinion for determining the valuation of Alps Holdco." You
further disclose that the "Globalink Board did not put much weight in considering the
draft fairness opinion in determining the valuation of Alps Holdco." It appears that the
Globalink Board received an opinion that is materially related to the transaction. Please
provide the disclosure required by Item 1607 of Regulation S-K or provide a detailed
analysis explaining why such disclosure is not required.
Escrow Agreement, page 114
We note your revised disclosure in response to previous comment 27 that the Escrow
Property will be distributed six months after the Closing Date. However, the
indemnification obligations pursuant to Article XII of the Merger Agreement appear to 5.

September 18, 2024
Page 3
run for twelve months after the Closing Date. Please clarify the relevant timeframes and
any potential impacts at the time when there is no Escrow Property remaining in the
Escrow Account.
Background of the Business Combination, page 119
6.We note your revised disclosure in response to previous comment 30. Please expand on
your disclosure regarding the negotiation of the Earnout Shares to discuss how the parties
arrived at the size of the earnout and the applicable milestones. Your disclosure should
include any discussions, proposals and counter-proposals made during the course of the
negotiations.
7.We note your response to previous comment 31 and reissue it in part. Please revise to
disclose the information reviewed by Globalink, which included "Alps’ forecasted
discounted cashflow and Price/price/revenue multiples." Also revise to briefly describe
the guidance of biotechnology companies’ valuation under Regulation 18a of Hong Kong
Stock Exchange to provide additional context for your disclosures.
Board's Discussion of Valuation and Reasons for the Approval of the Business Combination,
page 122
8.We note your response to previous comment 37 and reissue it in part as your disclosure
appears inconsistent with the response in the response letter. You disclose here that
the Board supported the decision to enter into the Merger Agreement based on the
Board’s evaluation of the above due diligence by Globalink’s management and the
investor presentation, and on the following qualitative and quantitative evaluations
regarding Alps, which included the financial projections prepared by Alps for the
upcoming five years until the fiscal year 2029. Please revise to reconcile the disclosure
with your response to us. We may have additional comments upon review of your
response. Refer to Item 1609 of Regulation S-K.
9.We note your response to previous comment 37 that you "did not disclose the projections
in the proxy statement/prospectus because the Globalink Board believes that the financial
projections may have contained estimates and assumptions that susceptible to changes
and uncertainties, and did not put much weight in considering the financial projections of
Alps in determining the valuation of Alps nor in the decision of recommending the
Business Combination for stockholders’ approval." We also note your statement on page
121 that the Globalink Board considered the PIPE Investment to be the primary basis for
the pre-money valuation of Alps of approximately $1.6 billion. Please tell us whether the
potential PIPE Investors received any financial projections of Alps. If so, please provide
us with your analysis of why disclosure of the projections is not required if they were
considered by the potential PIPE Investors, the valuation in the PIPE Investment was the
primary basis for the valuation in the Business Combination, and the availability and
terms of the PIPE Investment were given high significance by the Globalink Board in
approving the Business Combination.
We note your revised disclosure in response to previous comment 40 regarding the
matters the Board considered in determining that the terms of the PIPE Investment are
fair and reasonable to Globalink. Please expand on this disclosure to explain whether and
how the Board considered the $1.6 billion valuation for the PIPE Investment as part of its 10.

September 18, 2024
Page 4
determination that the terms of the PIPE Investment are fair and reasonable to Globalink.
Competition, page 123
11.We note your response to previous comment 15 and reissue in part. Please revise to
balance your disclosure by clarifying that you are considering companies significantly
larger than you, with significantly larger research & development plans and costs.
Material U.S. Federal Income Tax Consequences
U.S. Federal Income Tax Consequences of the Business Combination to U.S. Holders of
Globalink's Securities, page 145
12.We note your revised disclosure in response to previous comment 42 and reissue the
comment. The revised disclosure notes that the discussion constitutes an opinion with
respect to the Business Combination, including the Redomestication Merger and the
Acquisition Merger. However, the substantive discussion under the subheading " If the
Redomestication Merger Qualifies as a Reorganization " is still limited to a discussion of
the Redomestication Merger. Please revise the existing disclosure so that it is clear that
it also applies to the Acquisition Merger or add a separate discussion of the Acquisition
Merger.

Dilution to Globalink's Stockholders, page 152
13.Your revised disclosure appears to calculate dilution per share based on the difference
between the estimated issuance price per share of $10.00 and the net tangible book value
per share as of March 31, 2024. Item 1604(c) of Regulation S-K requires the disclosure
of the difference between the offering price of the securities in the initial registered
offering by the SPAC and the as adjusted net tangible book value per share. Please revise
your disclosure to include this presentation.
14.In footnotes (4) and (5) you note that because you are excluding the effect of the de-
SPAC itself, "the PIPE investment proceeds, net assets of Alps Holdco and transaction
cost attributed to Alps Holdco were excluded" and "the 4,000,000 ordinary shares to be
issued under PIPE Investment, 1,600,000 ordinary shares to be issued to IBDC Asia Sdn
Bhd as transaction cost and 160,000,000 ordinary shares to be issued to Alps Holdco
shareholders as Merger consideration shares were excluded." Please provide us with your
analysis of why such amounts should be excluded pursuant to Item 1604(c) of Regulation
S-K.
15.We reissue previous comment 43 in part. Outside of the dilution table, please describe
each material potential source of future dilution that non-redeeming shareholders may
experience by electing not to tender their shares in connection with the de-SPAC
transaction, including sources not included in the table with respect to the determination
of net tangible book value per share, as adjusted. These sources of future dilution should
include the Earnout Shares and outstanding public and private warrants to the extent their
exercise is assumed not to be probable. Please refer to Item 1604(c) of Regulation S-K.
We reissue previous comment 44. With respect to each redemption level, please state the
company valuation at or above which the potential dilution results in the amount of the
non-redeeming shareholders’ interest per share being at least the initial public offering 16.

September 18, 2024
Page 5
price per share of common stock. Additionally, to the extent applicable, please provide a
description of the model, methods, assumptions, estimates, and parameters necessary to
understand the tabular disclosure. Please refer to Items 1604(c)(1) and (2) of Regulation
S-K.
Agreement with Chardan, page 154
17.We note your revised disclosure regarding the February 2, 2024 amended agreement with
Chardan to "update certain commercial arrangements relating to the engagement,
including the inclusion of a future transaction arrangement post Business Combination."
Please revise to disclose the revisions to the agreement with Chardan, including whether
the commercial terms represent adjustments to the terms of the February 4, 2022 letter
agreement. Finally, please provide an estimate of the total fees and expenses you expect
to pay to Chardan in connection with the Business Combination and if such amounts are
included in the estimated transaction costs disclosed on pages 82, 152 and 241.
Our Pipeline, page 162
18.We reissue previous comment 50 in part. Please revise the arrows for each product
candidate to indicate the current status of such candidate and only put the arrow at the
end of the column if that phase of development has been completed. As examples, you
state that VaxBio "is moving to the preclinical stage" and that Celestialab "is now
focusing on commencing preclinical study."
mRNA (Diagnostic), page 189
19.We note your revised disclosure in response to previous comment 53. Please clarify what
it means for the biomarker laboratory to be equipped to detect up to 31 types of diseases.
Please explain the specific aspects of this group of 31 diseases that relate to your product.
Revise to provide a reasonable basis for your belief that your product may be able to
detect this specific group of diseases given your disclosure that you are still undergoing
the POC stage and data gathering phase of this product.
Intellectual Property, page 208
20.We note your response to previous comment 58 and your disclosure that Alps currently
does not own any patents and that Alps has in-licensed fifteen (15) foreign patents in
China. Please tell us what consideration you have given to updating your risk factor
section to describe the limitations of your patent license arrangements or revise.
Management's Discussion and Analysis of Financial Condition and Results of Operations of
Alps, page 225
We note your response to comment 59. Please reconcile the total of research expenses
incurred by each pipeline in the table presented on page 227 to the total research
expenses amounts as presented on page 227 which shows all of the components of the
Administrative expenses line item as presented on your statements of operations. Your
disclosures indicate that certain expenses, particularly salaries and payroll costs, are not
individually tracked. These expenses are shared across research and development of
various pipelines, and are not allocated to any specific pipeline. In this regard it is not
clear why the total research expenses incurred by each pipeline would be greater than the 21.

September 18, 2024
Page 6
total research expenses amount. For example for the year ended March 31, 2024, the total
research expenses for all pipelines was $286,537 whereas total research expenses as a
component of Administrative expenses was only $276,957. Please advise or revise your
disclosures as necessary.
22.We note your response to previous comment 60. Please address the following:
•Your response indicates that the main factor contributing to income tax expense in
2023 is derived from the under provision of income tax expense in TMC Global
Holdings Sdn. Bhd. in FY2022, by $118,113. Please help us understand whether this
under provision represents the correction of an error as addressed in IAS 8.41
through 49. If this adjustment is a correction of an error, please further explain how
you determined it was appropriate to record this adjustment in 2023 as well as your
consideration of the disclosures required by IAS 8.49. Please also advise how this
amount is reflected in your income tax reconciliation provided on page F-91; and
•In FY2024, income tax credit resulted from the derecognition of deferred tax
liabilities from TMC. TMC is in deferred tax assets position as of FY2024 resulting
from the unabsorbed business losses during the financial year. Please better clarify in
your disclosures how you determined it was appropriate to derecognize
these deferred tax liabilities and the corresponding effect it had on your
considerations regarding the realizability of the corresponding deferred tax assets.
Cost of sales, page 226
23.We reissue previous comment 61. We note your reference to "profit sharing on hair
implant services." Please clarify the profit sharing agreements you enter into and how
they relate to your business.
Unaudited Pro Forma Condensed Combined Financial Information, page 231
24.We note your response to comment 64. Please address the following:
•Please provide a summary of the key terms of the earnout provisions in your
disclosures

July 29, 2024
Say Leong Lim
Chief Executive Officer and Chairman of the Board of Directors
Alps Global Holding Pubco
Unit E-18-01 & E-18-02, Level 18, Icon Tower (East)
No. 1, Jalan 1/68F, Jalan Tun Razak
50400 Kuala Lumpur
Wilayah Persekutuan, Malaysia
Re:Alps Global Holding Pubco
Amendment No 1. to Draft Registration Statement on Form F-4
Submitted July 1, 2024
CIK No. 0002025774
Dear Say Leong Lim:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do not believe an
amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No 1. to Draft Registration Statement on Form F-4
Cover Page
1.We note your disclosure that "[t]he Globalink Board does not plan to obtain a fairness
opinion related to the Business Combination." You further state on page 35 in the
prospectus summary that "[t]he Board has unanimously determined that the Business
Combination is in the best interests of, and advisable to, the Globalink stockholders and
recommends that the Globalink stockholders adopt the Merger Agreement and approve
the Business Combination." Please also include the disclosure here.
We note your disclosure that the Sponsor, its affiliates and promoters are not receiving
compensation in connection with the Business Combination and the PIPE Investment. We
further note disclosure on page 221 reflecting outstanding advances due to an affiliate of
the Sponsor. Please revise to provide all the disclosures pursuant to Item 1603(a)(6) of 2.

July 29, 2024
Page 2
Regulation S-K. Please also revise your Conflicts of Interests disclosures on page 42 and
throughout your proxy statement/prospectus as applicable.
3.We note the disclosure that the Sponsor, its affiliates and promoters will not receive any
securities of Globalink or PubCo in connection with the Business Combination and the
PIPE Investment. Please clarify to disclose that the Sponsor will have an equity interest in
the Combined Company after completion of the Business Combination. We note your
disclosure on page 16.
4.We note your disclosure that "if Globalink does not consummate the Business
Combination and fails to complete an initial business combination by July 9, 2024 (or up
to December 9, 2024 if Globalink’s time to complete a business combination is extended
pursuant to the Globalink Charter), Globalink will be required to dissolve and liquidate."
Please revise to clarify that if Globalink anticipates that it may not be able to consummate
its initial business combination in time, Globalink may, by resolutions of its Board, if
requested by its Sponsor, extend the period of time to consummate a business
combination on a monthly basis to until December 9, 2024, subject to its Sponsor
depositing additional funds into the Trust Account.
5.We note that certain shareholders agreed to waive their redemption rights with respect to
any shares of Globalink common stock they may hold in connection with the
consummation of the Business Combination. Please disclose any consideration provided
in exchange for these waivers. Refer to Item 1603(a)(8) of Regulation S-K.
6.Please revise the cover page of your proxy statement/prospectus to disclose the number of
securities being registered on this registration statement. See Item 501(b) of Regulation S-
K.
Share Calculations and Ownership Percentages, page 6
7.We note the assumption here that the number of PubCo ordinary shares to be issued in
connection with conversion of Globalink’s public and private rights is 1,207,000.
However, elsewhere in the proxy statement/prospectus, you note that Globalink Rights
Holders are expect to own 1,150,000 shares of PubCo common stock. Please reconcile
these disclosures or advise.
Questions and Answers About the Special Meeting and the Proposals
Q: Do any of Globalink's directors or officers have interests that may conflict with my interests
with respect to the Business Combination, page 13
8.Please revise your disclosure to discuss the number of extensions of the period of time
Globalink has to consummate the initial business combination that have been exercised
and the corresponding amounts that have been deposited into the Trust Account by the
Sponsor.
Questions and Answers About the Special Meeting and the Proposals
Q: What equity stake will current Globalink stockholders, Alps Holdco Shareholders and PIPE
Investors hold, page 13
We note your statement here that the maximum redemption scenario "represents the
maximum redemptions that may occur, which would still allow Globalink to have
consolidated net tangible assets of at least $5,000,001" and similar statements for other 9.

July 29, 2024
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redemption scenarios presented in the proxy statement/prospectus. In light of the $40
million PIPE Investment entered into with certain investors on June 4, 2024 and June 5,
2024, please clarify why there is any level of redemptions that would result in Globalink
failing to satisfy the net tangible asset requirement.
10.Please expand the table in this Question & Answer to show the 25%, 50% and 75%
redemption scenarios presented on page 16 and elsewhere in the proxy
statement/prospectus. We also note your inclusion of the term "Maximum Contractual
Redemptions" here. Please revise your tabular dilution information throughout your filing
to present the information consistently.
11.Here and in the other presentations of share ownership that assume that no Earnout Shares
are issued, please clarify that subject to achieving certain revenue milestones the
maximum number of Earnout Shares that could be issued is 48,000,000 and that investors
would experience additional dilution to the extent any Earnout Shares are issued.
Summary of the Proxy Statement/Prospectus
Alps Holdco, page 27
12.Please revise the summary to provide a balanced presentation of Alps Holdco's current
operations by disclosing that Alps Holdco currently has no product candidates approved
for commercial sale and has not generated any revenue from the sale of product
candidates. Please also clarify that Alps Holdco primarily generates revenues from
general healthcare and other wellness services.
Parent Representative, page 28
13.We note your statement that the Sponsor "is acting as the Parent Representative for the
purpose of representing, from and after the Effective Time, the stockholders of
Globalink." Please clarify the role of the Parent Representative or otherwise explain the
way in which the Parent Representative will represent the previous stockholders of
Globalink after the Business Combination. Please provide corresponding disclosure for
the Seller Representative.
Summary of the Proxy Statement/Prospectus
Termination, page 29
14.Please clarify if the Outside Closing Date and related provisions are measured from the
January 30, 2024 execution of the initial Merger Agreement or from the May 20, 2024
execution of the amended and restated Merger Agreement.
Globalink Board's Reasons for the Approval of the Business Combination, page 34
Please provide the source or basis for your claims in this section. For example, we note
your statements regarding various industry trends on page 34 and statements regarding the
growth potential of Southeast Asia on page 35. We also note your statement on page 35
that Alps' "skilled, multilingual and cost-effective labor force contributes to a low burn
rate relative to many typical biotech companies solely focused on R&D, giving Alps a
longer runway and without compromising on quality, which enables Alps to have a
competitive advantage and pursue its pipeline developments" and on page 122 that "Alps
adopts a business model that generates revenue through multiple revenue streams with 15.

July 29, 2024
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relatively low overhead costs." Please substantiate these statements, including a
quantification of Alps' low burn rate relative to other biotech companies.
16.Please revise to provide the information required by Item 1606(c) of Regulation S-K.
Fairness Opinion, page 35
17.We note your statement that the Globalink Board does not plan to obtain a fairness
opinion in connection with the Business Combination. Receipt of a fairness opinion
appears to be a condition to Globalink's obligation to close the transaction pursuant to
Section 10.2(k) of the Amended and Restated Merger Agreement. Please revise your
disclosure to explain what consideration the Globalink Board gave to seeking a fairness
opinion, including any steps taken to seek a fairness opinion and if any financial advisors
declined or were otherwise unable or unwilling to provide a fairness opinion. To the
extent the Board has, or intends to, waive the fairness opinion closing condition, please
include appropriate disclosure throughout the proxy statement/prospectus.
Implication of Being an Emerging Growth Company, page 39
18.Please clearly state your election under Section 107(b) of the JOBS Act. If you do not
believe the election would impact the PubCo as an IFRS filer, please revise to disclose
that effect.
Interests of Certain Persons in the Business Combination, page 42
19.We note your disclosure on page 221 regarding various promissory notes between the
Company and PGM noting that such notes are repayable upon consummation of an initial
Business Combination. We further note your disclosure on page F-13 regarding "a
familial relationship between the Sponsor and a 95% shareholder of Public Gold
Marketing Sdn. Bhd" and your disclosure on page F-14 that "[a]s of March 31, 2024 and
December 31, 2023, the total of the promissory notes are reflected on the consolidated
balance sheets as $2,640,649 and $1,757,255, respectively." Please revise your disclosure
in this section and throughout your proxy statement/prospectus as applicable to disclose
the outstanding promissory notes and familial relationship as an interest of the Sponsor.
Dividend Policy, page 51
20.Please reconcile your statement here that it is presently intended that the Combined
Company "retain most," if not all, of its available funds and any future earnings for use in
business operations and expansion with your statement on page 87 that "[t]he Combined
Company intends to retain future earnings, if any, for future operations, expansion and
debt repayment and there are no current plans to pay any cash dividends for the
foreseeable future." Please clarify the intended dividend policy of the Combined
Company, including whether you intend to distribute any portion of available funds to
shareholders. Additionally, please clarify if you intend to use retained earnings for debt
repayment.
Risk Factors
Risks Related to Development of Our Product Candidates
Our current product candidates are in preclinical development and have never been tested in
humans..., page 57

July 29, 2024
Page 5
21.We note your statement that "the joint development of oral Cholera vaccine cannot be
carried out in a geographical location with close proximity to where we operate." Please
explain why this is the case either here or elsewhere in the prospectus/proxy statement.
The manufacturing operations of our potential product candidates including but not limited to
cosmetics products infused with exosomes..., page 62
22.We note your disclosure that you are not capable of manufacturing the finished cosmetics
products such as facial masks and face serum infused with exosomes in-house and that
you rely on a single supplier. At an appropriate section of your filing, please describe this
supplier and the material terms of any agreement with this supplier or provide an analysis
explaining why you are not required to do so.
Alps relies on intellectual property that is jointly developed with third parties which exposes Alps
to risks..., page 64
23.Please revise the risk factor disclosure to disclose that Alps' Research Collaboration
Agreement with University Science Malaysia for cancer data and related research and
development has expired. We note your disclosure on page 189.
Risk Factors
Risk Related to Government Regulation
Fluctuations in exchange rates could adversely affect Alps' business and the value of its
securities., page 67
24.We note your statement that "[t]o the extent the USD increases in value relative to the
RM, our margins may be adversely affected." Please provide a more detailed explanation
of how changes in the value of the RM and USD impact your business, financial
condition, results of operations and liquidity.
You may experience difficulties in effecting service of legal process, enforcing foreign judgments
or bringing actions against PubCo..., page 91
25.Please revise to tailor the risk factor disclosure to your facts and circumstances
and clarify, if applicable, that a majority of the Combined Company's officers and
directors are located outside of the United States.
Board of Directors and Management Following the Business Combination, page 114
26.You state on page 24 that upon the Closing of the Business Combination, all of the
officers of Alps Holdco will become the initial officers of PubCo and shall hold office
until their respective successors are duly elected or appointed and qualified. Based on this
disclosure here, it does not appear that you expect to appoint a Chief Financial Officer
following the Business Combination. Please clarify if you intend to appoint a Chief
Financial Officer upon the Closing of the Business Combination. If not, please revise your
risk factor disclosure on page 54 to note that you expect to continue operating without a
Chief Financial Officer for the foreseeable future.

July 29, 2024
Page 6
Escrow Agreement, page 114
27.Please expand on this section to explain why five percent of the Merger Consideration
will be held in escrow following the closing of the Business Combination. Your
disclosure should explain the conditions and timeframe under which such Escrow Shares
may be disbursed from escrow.
The Sponsor, its Affiliates, and Promoters , page 115
28.Please expand on your description of the material roles and responsibilities of the
Sponsor, its affiliate and promoters to describe the specific roles of the controlling person
and two promoters. We also note your statement that "[a] promoter of the Sponsor, Lin
Ding Jie, who holds 22.5% of the equity interest in the Sponsor, has previous experience
in organizing special purpose acquisition companies." Please revise to briefly describe the
previous experience noted here. Refer to Item 1603(a)(3) of Regulation S-K.
29.We note your statement that "[n]o agreement, arrangement, or understanding has been
made between the Sponsor and Globalink or Globalink’s officers, directors, and affiliates
with respect to determining whether to proceed with a de-SPAC transaction, including the
Business Combination." Please revise this statement to discuss the Insider Letter and file
such agreement as an exhibit to your registration statement or provide an analysis
explaining why it is not necessary. Refer to Item 1603(a)(5) and Item 601(b) of
Regulation S-K.
Background of the Business Combination, page 119
Please significantly expand the disclosure in this section to explain how the transaction
structure and consideration evolved during the negotiations, including any discussions,
proposals and counter-proposals made during the course of the negotiations with respect
to the material terms of the transaction. Please revise the section to address, including but
not limited to, the following:

•include a description of the negotiation of the Earnout Shares, Insider Letter, Escrow
Agreement and the G