SecProbe.io

CORRESP
 1
 filename1.htm

 Univest Securities, LLC

 75 Rockefeller Plaza, Suite 18C

 New York, NY, 10019

 June 23, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Globavend Holdings Limited

 Registration Statement on Form S-1, as amended (File No. 333-287533)

 Request for Acceleration of Effective Date

 Requested Date:
 Tuesday, June 24, 2025

 Requested Time:
 5:00 PM Eastern Time

 Ladies and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Securities Act"), Univest
Securities, LLC, as placement agents of the above-captioned proposed offering, hereby joins the request of Globavend Holdings Limited
that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it may become effective at 5:00
p.m., Eastern Time, on Tuesday, June 24, 2025, or as soon thereafter as practicable.

 The undersigned is aware
of its responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public
offering of the securities referred to in the captioned registration statement.

 A copy of a letter from
the Financial Industry Regulatory Authority ("FINRA") dated June 18, 2025, to the effect that FINRA has no objection to the
underwriting compensation arrangements, is attached.

 Very truly yours,

 UNIVEST SECURITIES, LLC

 By:
 /s/ Bradley Richmond

 Name:
 Bradley Richmond

 Title:
 Chief Operating Officer and
co-Head Investment Banking

 Public Offering: Communications

 June 18, 2025

 Lucosky Brookman LLP

 101 Wood Avenue South

 Woodbridge,
NJ 08830

 Attn: Peter Campitiello

 Re: No Objections Letter

 FINRA Filing ID: 2025-04-21-8116306

 Globavend Holdings Limited

 CIK #: 0001978527

 SEC Reg. #: 333-287533

 Dear Sir/Madam:

 In connection with the above-referenced filing,
the Corporate Financing Department (Department) has reviewed the information and documents submitted through FINRA's public offering
filing system.

 This letter confirms that based on such information
and documents, the Department raises no objections with respect to the fairness and reasonableness of the proposed underwriting terms
and arrangements.

 You should note that the Department also requires
to be filed on a timely basis for review: (1) any amendments to documents that impact the underwriting terms and arrangements, including
an increase or decrease to the offering proceeds, (2) changes in the public offering price, and (3) a copy of the final
prospectus. If such changes indicate a modification of the terms and arrangements of the proposed offering, further review may
result in a change in the Department's no objections decision.

 The Department's decision to raise no objections
is based on the information as presented to FINRA in connection with this offering and should not be deemed a precedent with respect
to the fairness and reasonableness of the underwriting terms and arrangements of any other offering. Please be advised that, in raising
no objections, FINRA has neither approved nor disapproved of the issuer's public offering and neither this letter nor any communication
from FINRA should be construed or represented as FINRA approval. In addition, this letter does not constitute any approval or disapproval
regarding the issuer that is the subject of the above-referenced submission, including the legality of such issuer's activities. This
decision to raise no objections relates solely to the FINRA rules governing underwriting terms and arrangements and does not purport to
express any determination of compliance with any federal or state laws, or other regulatory or self-regulatory requirements.

 If you have questions regarding this letter, please call
the undersigned at (240) 386-4623.

 Regards,

 Michael Reilly

 First Reviewer

 Kenny Walters

 Second Reviewer

 Corporate Financing Department

 https://ext.cobra.finra.org/filer-ui/deals/8116306/communications

CORRESP
 1
 filename1.htm

 June 23, 2025

 Via EDGAR

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C., 20549

 Re:
 Globavend Holdings Limited

 Registration Statement on Form F-1

 File No. 333-287533

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, Globavend Holdings Limited, hereby respectfully requests acceleration of the effectiveness
of the above-referenced Registration Statement so that such Registration Statement will become effective as of 5:00
p.m. Eastern Time, on Tuesday, June 24,
2025, or as soon as practicable thereafter.

 Very truly yours,

 /s/ Wai Yiu Yau

 Name:
 Wai Yiu Yau

 Title:
 Director and CEO

 c.c.:
 Aaron M. Schleicher, Esq.

CORRESP
 1
 filename1.htm

 June 9, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Energy & Transportation

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C., 20549

 Re:
 Globavend Holdings Limited

 Registration Statement on Form F-1

 Response to the Staff's Comments Dated
June 6, 2025

 File No. 333-287533

 Dear Ms. Barberena-Meissner and Mr. Morris:

 We, Globavend Holdings Limited (the " Company "),
a foreign private issuer incorporated in the Cayman Islands, submit to the staff (the " Staff ") of the U.S. Securities
and Exchange Commission (the " Commission ") this letter setting forth the Company's responses to the comments
contained in the Staff's letter dated as of June 6, 2025 in response to the Company's registration statement on Form F-1 filed
on May 22, 2025. Concurrently with the submission of this letter, the Company is filing its amendment no. 1 to the registration statement
on Form F-1 (the " Amendment No. 1 to the Registration Statement ") and certain exhibits via EDGAR to the Commission.

 The Staff's comments from its letter dated June 6, 2025 are repeated
below in bold and followed by the Company's responses. We have included page numbers to refer to the location in the Amendment No.
1 to the Registration Statement where the language addressing the comments appears. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the Amendment No. 1 to the Registration Statement.

 Registration Statement on Form F-1 filed
May 23, 2025

 Cover Page

 1.
 Please revise your cover page caption to clearly disclose all the securities being registered. In this regard, we note that your fee table indicates that the Series A Warrants, Series B Warrants, and Pre-Funded Warrants are being registered in addition to the Ordinary Units, Pre-Funded Units, and Ordinary Shares underlying the Ordinary Units, Pre-Funded Warrants, Series A Warrants, and Series B Warrants.

 In response to the Staff's comment, the Company has included
the referenced disclosure on the cover page caption of the Amendment No. 1 to the Registration Statement.

 Risk Factors

 This offering may result in an immediate
trading halt or delisting of our Ordinary Shares, page 14

 2.
 We note your response to prior comment 1. To contextualize your disclosure regarding the risk of an immediate trading halt or delisting, please revise to clarify whether to your knowledge Nasdaq has found a public interest concern related to other offerings that include warrants with zero exercise or similar features. In addition, revise your prospectus summary disclosure to provide appropriate discussion.

 In response to the Staff's comment, the Company has revised the
prospectus summary and the risk factor on page 15 of the Amendment No. 1 to the Registration Statement accordingly.

 Exhibits

 3.
 We note that the legal opinion filed as Exhibit 5.1 states that Conyers acted as special Cayman Islands legal counsel to you in connection with this registration statement for the offering of (i) up to 16,176,471 ordinary units ("Ordinary Units") whereby each Ordinary Unit consists of one ordinary share, par value US$0.001 per share of the Company (the "Ordinary Share"), one Series A warrant to purchase one Ordinary Share (each a "Series A Warrant", and, collectively, the "Series A Warrants"), and one Series B warrant to purchase one Ordinary Share (each a "Series B Warrant", and, collectively, the "Series B Warrants"); and (ii) up to 16,176,471 pre-funded units ("Pre-Funded Units" and collectively with the Ordinary Units, the "Units"), each consisting of one pre-funded warrant to purchase one Ordinary Share (each a "Pre-Funded Warrant," and, collectively, the "Pre-Funded Warrants") (the Pre-Funded Warrants, Series A Warrants and Series B Warrants collectively, the "Warrants"), one Series A Warrant and one Series B Warrant in lieu of the Ordinary Units where purchase of the Ordinary Units in the Offering would result in the relevant purchaser, together with its affiliates, beneficially owning more than 4.99% (or, at the election of the purchaser, 9.99%) of the outstanding Ordinary Shares immediately following the consummation of the Offering, if they so choose. However, we note that the Series A Warrants, Series B Warrants, Pre-Funded Warrants, and Ordinary Shares underlying the Ordinary Units, Series A Warrants, Series B Warrants, and Pre-Funded Warrants are also being registered. Please have counsel revise the legal opinion to reflect all the securities being registered in this registration statement or advise.

 In response to the Staff's comment, the Company has included
a revised legal opinion as exhibit 5.1 of the Amendment No. 1 to the Registration Statement, which reflects all the referenced securities
being registered.

 2

 4.
 Please also have counsel revise the legal opinion to opine that the Ordinary Shares underlying the Units will be validly issued, fully paid and non-assessable when issued upon exercise of the Units. Refer to Section II.B.1.a and h. of Staff Legal Bulletin No. 19.

 In response to the Staff's comment, the Company has included
a revised legal opinion as exhibit 5.1 of the Amendment No. 1 to the Registration Statement, which reflects the requested disclosure.

 5.
 Please file an opinion of counsel that opines that the Units and Warrants constitute binding obligations of the company. For guidance, please refer to Section II.B.1.f and h. of Staff Legal Bulletin No. 19.

 In response to the Staff's comment, the Company has included
an additional legal opinion as exhibit 5.2 of the Amendment No. 1 to the Registration Statement, which reflects the requested disclosure.

 If you have any questions
or further comments regarding the Registration Statement, please contact me via email at project@globavend.com.

 Very truly yours,

 /s/ Wai Yiu Yau

 Name:
 Wai Yiu Yau

 Title:
 Director and CEO

 c.c.:
 Aaron M. Schleicher, Esq.

 3

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 6, 2025

Wai Yiu Yau
Chairman of the Board and Chief Executive Officer
Globavend Holdings Limited
Office 1401, Level 14, 197 St Georges Tce
Perth, WA 6000
Australia

 Re: Globavend Holdings Limited
 Registration Statement on Form F-1
 Filed May 22, 2025
 File No. 333-287533
Dear Wai Yiu Yau:

 We have conducted a limited review of 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.

Registration Statement on Form F-1 filed May 23, 2025
Cover Page

1. Please revise your cover page caption to clearly disclose all the
securities being
 registered. In this regard, we note that your fee table indicates that
the Series A
 Warrants, Series B Warrants, and Pre-Funded Warrants are being
registered in
 addition to the Ordinary Units, Pre-Funded Units, and Ordinary Shares
underlying the
 Ordinary Units, Pre-Funded Warrants, Series A Warrants, and Series B
Warrants.
 June 6, 2025
Page 2
Risk Factors
This offering may result in an immediate trading halt or delisting of our
Ordinary Shares,
page 14

2. We note your response to prior comment 1. To contextualize your
disclosure
 regarding the risk of an immediate trading halt or delisting, please
revise to clarify
 whether to your knowledge Nasdaq has found a public interest concern
related to
 other offerings that include warrants with zero exercise or similar
features. In
 addition, revise your prospectus summary disclosure to provide
 appropriate discussion.
Exhibits

3. We note that the legal opinion filed as Exhibit 5.1 states that Conyers
acted as special
 Cayman Islands legal counsel to you in connection with this registration
statement for
 the offering of (i) up to 16,176,471 ordinary units ( Ordinary Units
) whereby each
 Ordinary Unit consists of one ordinary share, par value US$0.001 per
share of the
 Company (the Ordinary Share ), one Series A warrant to purchase one
Ordinary
 Share (each a Series A Warrant , and, collectively, the Series A
Warrants ), and
 one Series B warrant to purchase one Ordinary Share (each a Series B
Warrant , and,
 collectively, the Series B Warrants ); and (ii) up to 16,176,471
pre-funded units
 ( Pre-Funded Units and collectively with the Ordinary Units, the
Units ), each
 consisting of one pre-funded warrant to purchase one Ordinary Share
(each a Pre-
 Funded Warrant, and, collectively, the Pre-Funded Warrants )
(the Pre-Funded
 Warrants, Series A Warrants and Series B Warrants collectively, the
Warrants ), one
 Series A Warrant and one Series B Warrant in lieu of the Ordinary Units
where
 purchase of the Ordinary Units in the Offering would result in the
relevant purchaser,
 together with its affiliates, beneficially owning more than 4.99% (or,
at the election of
 the purchaser, 9.99%) of the outstanding Ordinary Shares immediately
following the
 consummation of the Offering, if they so choose. However, we note that
the Series A
 Warrants, Series B Warrants, Pre-Funded Warrants, and Ordinary Shares
underlying
 the Ordinary Units, Series A Warrants, Series B Warrants, and Pre-Funded
Warrants
 are also being registered. Please have counsel revise the legal opinion
to reflect all the
 securities being registered in this registration statement or advise.
4. Please also have counsel revise the legal opinion to opine that the
Ordinary Shares
 underlying the Units will be validly issued, fully paid and
non-assessable when issued
 upon exercise of the Units. Refer to Section II.B.1.a and h. of Staff
Legal Bulletin No.
 19.
5. Please file an opinion of counsel that opines that the Units and
Warrants constitute
 binding obligations of the company. For guidance, please refer to
Section II.B.1.f and
 h. of Staff Legal Bulletin No. 19.

 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.
 June 6, 2025
Page 3

 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 Irene Barberena-Meissner at 202-551-6548 or Daniel Morris
at 202-
551-3314 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Aaron M. Schleicher, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 May 22, 2025

 Via EDGAR

 Division of Corporate Finance

 Officer of Energy & Transportation

 U.S. Securities and Exchange Commission

 100 F Street NE

 Washington, D.C., 20549

 Re: Globavend Holdings Limited

 Draft Registration on Form F-1

 Response to the Staff's Comments Dated
May 6, 2025

 CIK No.0001978527

 Dear Ms. Barberena-Meissner and Mr. Morris:

 We, Globavend Holdings Limited
(the " Company "), a foreign private issuer incorporated in the Cayman Islands, submit to the staff (the " Staff ")
of the U.S. Securities and Exchange Commission (the " Commission ") this letter setting forth the Company's responses
to the comments contained in the Staff's letter dated as of May 6, 2025 on the Company's draft registration statement on Form
F-1 confidentially submitted on April 15, 2025. Concurrently with the submission of this letter, the Company is filing its registration
statement on Form F-1 (the " Registration Statement ") and certain exhibits via EDGAR to the Commission.

 The Staff's comments
from its letter dated May 6, 2025 are repeated below in bold and followed by the Company's responses. We have included page numbers
to refer to the location in the Registration Statement where the language addressing the comments appears. Capitalized terms used but
not otherwise defined herein have the meanings set forth in the Registration Statement.

 Draft Registration Statement on Form F-1
submitted April 15, 2025

 Risk Factors

 We have received a deficiency letter from
Nasdaq relating to our non-compliance with Nasdaq's continued listing requirements, page 15

 1. Please revise your risk factor disclosure here and elsewhere as appropriate to disclose that this offering
could cause the price of your Ordinary Shares to fall below the minimum bid price, which could result in your Ordinary Shares being delisted
from Nasdaq.

 In response to the Staff's
comment, the Company has included the referenced disclosure on pages 14 of the Registration Statement.

 If you have any questions
or further comments regarding the Registration Statement, please contact me via email at project@globavend.com.

 Very truly yours,

 /s/ Wai Yiu Yau

 Name:
 Wai Yiu Yau

 Title:
 Director and CEO

 c.c.: Aaron M. Schleicher, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 6, 2025

Wai Yiu Yau
Chairman of the Board and Chief Executive Officer
Globavend Holdings Limited
Office 1401, Level 14, 197 St Georges Tce
Perth, WA 6000
Australia

 Re: Globavend Holdings Limited
 Draft Registration Statement on Form F-1
 Submitted April 15, 2025
 CIK 0001978527
Dear Wai Yiu Yau:

 We have reviewed your 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.

Draft Registration Statement on Form F-1 submitted April 15, 2025
Risk Factors
We have received a deficiency letter from Nasdaq relating to our non-compliance
with
Nasdaq s continued listing requirements, page 15

1. Please revise your risk factor disclosure here and elsewhere as
appropriate to disclose
 that this offering could cause the price of your Ordinary Shares to fall
below the
 minimum bid price, which could result in your Ordinary Shares being
delisted from
 Nasdaq.
 May 6, 2025
Page 2

 Please contact Irene Barberena-Meissner at 202-551-6548 or Daniel Morris
at 202-
551-3314 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Energy &
Transportation
cc: Aaron M. Schleicher, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

 November
4,  2024

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:

    Claudia
    Rios

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-280554

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4pm ET on November 7, 2024, or as soon as thereafter practicable.

The
Company understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement
as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed
public offering of the securities specified in the Registration Statement.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

July 10, 2024
Wai Yiu Yau
Chief Executive Officer
Globavend Holdings Ltd
Office 1401, Level 14, 197 St Georges Tce,
Perth, WA 6000
Australia
Re:Globavend Holdings Ltd
Registration Statement on Form F-1
Filed June 28, 2024
File No. 333-280554
Dear Wai Yiu Yau:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that
the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Claudia Rios at 202-551-8770 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Clayton Parker, Esq.

CORRESP
1
filename1.htm

VIA
EDGAR

November
2, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
    HOLDINGS LIMITED

    File
    No. 333 – 274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), R.F. Lafferty & Co., Inc., acting as representative of the underwriters, hereby joins
GLOBAVEND HOLDINGS LIMITED in requesting acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective on November 2, 2023, at 5:30 p.m. Eastern Time, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated
September 11, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

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

Very
truly yours,

    R.F. Lafferty & Co., Inc.

    By:
    /s/
    Robert Hackel

    Name:
    Robert
    Hackel

    Title:

    Chief
    Operating Officer

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

November
2, 2023

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:

    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-274166

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effectiveness at 5:30pm ET on November 2, 2023, or as soon as thereafter practicable.

The
Company understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement
as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed
public offering of the securities specified in the Registration Statement.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

VIA
EDGAR

October
19, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
    HOLDINGS LIMITED

    Withdrawal
    of Request for Acceleration

    File
    No. 333-274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

R.F.
Lafferty & Co., Inc., acting as representative of the underwriters, respectfully requests withdrawal of its acceleration request
letter filed as correspondence via EDGAR on October 16, 2023, which requested that the above-referenced Registration Statement become
effective on October 18, 2023, at 11:30 a.m. Eastern Time, or as soon thereafter as practicable. The undersigned is no longer requesting
that such Registration Statement be declared effective at this specific date and time and the undersigned hereby formally withdraws such
request for acceleration.

The
undersigned filed an acceleration request on October 18, 2023 which requested that the above-referenced Registration Statement become
effective on October 19, 2023, at 5:30 p.m. Eastern Time, or as soon thereafter as practicable.

Very
truly yours,

    R.F.
    Lafferty & Co., Inc.

    By:

    /s/
    Robert Hackel

    Name:

    Robert
    Hackel

    Title:
    Chief
    Operating Officer

CORRESP
1
filename1.htm

VIA
EDGAR

October
19, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
                                            HOLDINGS LIMITED

    Withdrawal
    of Request for Acceleration

    File
                                            No. 333-274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

R.F.
Lafferty & Co., Inc., acting as representative of the underwriters, respectfully requests withdrawal of its acceleration request
letter filed as correspondence via EDGAR on October 18, 2023, which requested that the above-referenced Registration Statement become
effective on October 19, 2023, at 5:30 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned is no longer requesting
that such Registration Statement be declared effective at this specific date and time and the undersigned hereby formally withdraws such
request for acceleration.

Very
truly yours,

    R.F.
    Lafferty & Co., Inc.

    By:

    /s/
    Robert Hackel

    Name:

    Robert
    Hackel

    Title:
    Chief
    Operating Officer

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

October
19, 2023

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-274166

Ladies
and Gentlemen:

The
Company hereby respectfully withdraws its request submitted on October 18, 2023, for acceleration of the effectiveness of the above referenced
Registration Statement pursuant to Rule 461 under the Securities Act of 1933, as amended, on October 19, 2023 at 5:30 p.m., Eastern Time.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

October
18, 2023

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-274166

Ladies
and Gentlemen:

The
Company hereby respectfully withdraws its request for acceleration that it filed with the Commission on October 16, 2023 with respect
to the above referenced Registration Statement and to hereby make a new request for acceleration.

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effectiveness at 5:30 p.m. ET on October 19, 2023, or as soon as thereafter practicable.

The
Company understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement
as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed
public offering of the securities specified in the Registration Statement.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

VIA
EDGAR

October
18, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
    HOLDINGS LIMITED

    File
    No. 333 – 274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), R.F. Lafferty & Co., Inc., acting as representative of the underwriters, hereby joins
GLOBAVEND HOLDINGS LIMITED in requesting acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective on October 19, 2023, at 5:30 p.m. Eastern Time, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated
September 11, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

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

Very
truly yours,

    R.F. Lafferty & Co., Inc.

    By:
    /s/
    Robert Hackel

    Name:
    Robert
Hackel

    Title:

    Chief
    Operating Officer

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

October
16, 2023

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:

    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-274166

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effectiveness at 11:30am ET on October 18, 2023, or as soon as thereafter practicable.

The
Company understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement
as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed
public offering of the securities specified in the Registration Statement.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

VIA
EDGAR

October
16, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
    HOLDINGS LIMITED

    File
    No. 333 – 274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), R.F. Lafferty & Co., Inc., acting as representative of the underwriters, hereby joins
GLOBAVEND HOLDINGS LIMITED in requesting acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective on October 18, 2023, at 11:30 a.m. Eastern Time, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated
September 11, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

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

Very
truly yours,

    R.F.
    Lafferty & Co., Inc.

    By:
    /s/
    Robert Hackel

    Name:
    Robert
    Hackel

Title:

    Chief
    Operating Officer

CORRESP
1
filename1.htm

VIA
EDGAR

October
5, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
                                            HOLDINGS LIMITED

    Withdrawal
    of Request for Acceleration

    File
                                            No. 333-274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

R.F.
Lafferty & Co., Inc., acting as representative of the underwriters, respectfully requests withdrawal of its acceleration request
letter filed as correspondence via EDGAR on October 3, 2023, which requested that the above-referenced Registration Statement become
effective on October 5, 2023, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned is no longer requesting
that such Registration Statement be declared effective at this specific date and time and the undersigned hereby formally withdraws such
request for acceleration.

Very
truly yours,

    R.F.
    Lafferty & Co., Inc.

    By:

    /s/
    Robert Hackel

    Name:

    Robert
    Hackel

    Title:
    Chief
    Operating Officer

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

October
5, 2023

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-274166

Ladies
and Gentlemen:

The
Company hereby respectfully withdraws its request submitted on October 3, 2023, for acceleration of the effectiveness of the above referenced
Registration Statement pursuant to Rule 461 under the Securities Act of 1933, as amended, on October 5, 2023 at 4:00 p.m., Eastern Time.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

VIA
EDGAR

October
3, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

    Attn.:
    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    GLOBAVEND
    HOLDINGS LIMITED

    File
    No. 333 – 274166

    Registration
    Statement on Form F-1, as amended

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), R.F. Lafferty & Co., Inc., acting as representative of the underwriters, hereby joins
GLOBAVEND HOLDINGS LIMITED in requesting acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective on October 5, 2023, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated
September 11, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

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

Very
truly yours,

    R.F.
    Lafferty & Co., Inc.

    By:
    /s/
    Robert Hackel

    Name:
    Robert
    Hackel

    Title:
    Chief
    Operating Officer

CORRESP
1
filename1.htm

Globavend
Holdings Limited

Office
1401, Level 14, 197 St Georges Tce

Perth,
WA 6000

Australia

October
3, 2023

VIA
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Attention:

    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:
    Globavend
    Holdings Ltd (the “Company”) (CIK No. 0001978527)

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-274166

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effectiveness at 4:00pm ET on October 5, 2023, or as soon as thereafter practicable.

The
Company understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement
as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed
public offering of the securities specified in the Registration Statement.

    Very
    truly yours,

    Globavend
    Holdings Ltd

    By:
    /s/
    Wai Yiu Yau

    Name:
    Wai
    Yiu Yau

    Title:
    Chairman
    and Chief Executive Officer

CORRESP
1
filename1.htm

September 29, 2023

Via
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Attention:

    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:

    Globavend
    Holdings Ltd (CIK No. 0001978527)

    Registration
    Statement on Form F-1

    Amended
    on September 29, 2023

    File
    No. 333-274166

Ladies
and Gentlemen:

On
behalf of our client, Globavend Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
we submit to the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s request for waiver and representation under Item 8.A.4 of Form 20-F. Concurrently with
the submission of this letter, the Company is filing its amendment no.2 to the Registration Statement on Form F-1 (the “Registration
Statement”) and certain exhibits via EDGAR to the Commission.

K&L
GATES, SOLICITORS

44th
Floor Edinburgh Tower The Landmark 15 Queen’s Road Central Hong Kong

高蓋茨律師事務所
香港中環皇后大道中15號 置地廣場公爵大廈44樓

T
+852 2230 3500 F +852 2511 9515 klgates.com

    Partners

    Neil
    CAMPBELL
    甘寶靈

    William
    Z. HO
    何志淵

    Virginia
    M.L. TAM
    譚敏亮

    Sook
    Young YEU

    呂淑榮

    Michael
    K.S. CHAN
    陳國淳

    Jay
    J. LEE
    李再浩

    Choo
    Lye TAN
    陳珠萊

    Eugene
    Y.C. YEUNG

    楊睿知

    Sacha
    M. CHEONG
    文錦明

    Iris
    M.K. LEUNG
    梁美琪

    Vincent
    S.K. TSO
    曹紹基

    Jay
    C. CHIU
    邱志藩

    Scott
    D. PETERMAN
    畢德民

    Christopher
    TUNG
    董彥華

    Paul
    R. HASWELL
    何
    威

    Carolyn
    H.L. SNG
    孫慧蓮

    Frank
    VOON
    溫匯源

    Registered
    Foreign Lawyer (PRC)

    Registered
    Foreign Lawyer (California (USA))

    Amigo
    L. XIE
    謝
    嵐

    Roberta
    A. CHANG
    張
    安

Financial
Statements

Item
8.A.4 of Form 20-F requires that in the case of a company’s initial public offering, the registration statement on Form F-1 shall
contain audited financial statements as of a date not older than 12 months from the date of the filing. Nevertheless, Instruction 2 to
Item 8.A.4 of Form 20-F provides that “[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.”

The
Company has included in the Registration Statement its audited consolidated financial statements, prepared in accordance with accounting
principles generally accepted in the United States of America, as of and for the years ended September 30, 2022 and 2021, and unaudited
interim condensed consolidated financial statements as of March 31, 2023 and for the six months ended March 31, 2023 and 2022. The Company
has included as Exhibit 99.8 to the Registration Statement Amendment No.1, a letter in which the Company makes the representations to
the Commission required by Instruction 2 to Item 8.A.4 of Form 20-F, which states that: (i) the Company is not currently a public reporting
company in any jurisdiction; (ii) the Company is not required by any jurisdiction outside the United States to comply with the 12-month
updating requirement; (iii) full compliance with Item 8.A.4 of Form 20-F at present is impracticable and involves undue hardship for
the Company; (iv) the Company does not anticipate that its audited financial statements for the fiscal year ended September 30, 2023
will be available until February 1, 2024; and (v) in no event will the Company seek effectiveness of the Registration Statement if its
audited financial statements are older than 15 months at the time of the Company’s initial public offering.

    Very
    truly yours,

    /s/
    Virginia Tam

    Name:
    Virginia
    Tam

    Title:

    Partner

CORRESP
1
filename1.htm

September
8, 2023

Via
EDGAR

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Attention:

    Steve
    Lo

    Kimberly
    Calder

    Liz
    Packebusch

    Timothy
    S. Levenberg

    Re:

    Globavend
                                            Holdings Ltd (CIK No. 0001978527)

    Registration
    Statement on Form F-1

    Amended
    on September 8, 2023

    File
    No. 333-274166

Ladies
and Gentlemen:

On
behalf of our client, Globavend Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
we submit to the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated September 6, 2023
on the Company’s registration statement on Form F-1 filed on August 23, 2023 (the “Registration Statement”).
Concurrently with the submission of this letter, the Company is filing its amendment no.1 to the Registration Statement on Form F-1 (the
“Registration Statement No.1”) and certain exhibits via EDGAR to the Commission.

K&L
GATES, SOLICITORS

44th
Floor Edinburgh Tower The Landmark 15 Queen’s Road Central Hong Kong

高蓋茨律師事務所
香港中環皇后大道中15號 置地廣場公爵大廈44樓

T
+852 2230 3500 F +852 2511 9515 klgates.com

    Partners

    Neil
    CAMPBELL
    甘寶靈

    William
    Z. HO
    何志淵

    Virginia
    M.L. TAM
    譚敏亮

    Sook
    Young YEU

    呂淑榮

    Michael
    K.S. CHAN
    陳國淳

    Jay
    J. LEE
    李再浩

    Choo
    Lye TAN
    陳珠萊

    Eugene
    Y.C. YEUNG

    楊睿知

    Sacha
    M. CHEONG
    文錦明

    Iris
    M.K. LEUNG
    梁美琪

    Vincent
    S.K. TSO
    曹紹基

    Jay
    C. CHIU
    邱志藩

    Scott
    D. PETERMAN
    畢德民

    Christopher
    TUNG
    董彥華

    Paul
    R. HASWELL
    何
    威

    Carolyn
    H.L. SNG
    孫慧蓮

    Frank
    VOON
    溫匯源

    Registered
    Foreign Lawyer (PRC)

    Registered
    Foreign Lawyer (California (USA))

    Amigo
    L. XIE
    謝
    嵐

    Roberta
    A. CHANG
    張
    安

Form
F-1 Filed August 23, 2023

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

Results
of Operations, page 60

    1.
    We
    note you revised your disclosure on page 59 in response to prior comment 1. We reissue the comment. Please revise your discussion,
    to the extent material to an understanding of your results of operations, to quantify for each period presented the impact that foreign
    currency movement had on specific line items of revenue and expenses. For example, discussions about changes in the price vs. volume
    mix should consider changes in foreign currency fluctuation and how they impacted revenue. Refer to Item 5.A.3. of Form 20-F.

    In
    response to the Staff’s comment, the Company has included the referenced disclosure on pages 61, 62, 64 and 65 of the Registration
    Statement No.1.

Exhibits

Exhibit
5.1

Opinion
of Conyers Dill & Pearman, page II-4

    2.
    If
    counsel intends to use the term “Resale Shares” in the legality opinion, please revise the opinion to define the term
    and to opine on the Resale Shares at Section 4.3.

    In
    response to the Staff’s comment, the Company respectfully advises the Staff that the Company is not registering any of its
    shares for resale in this offering. The Company has included a revised legality opinion as exhibit 5.1 of the Registration Statement
    No.1, which has removed any references to “Resale Shares”.

    3.
    At
    Section 3.3, counsel states that the legality opinion “is issued solely for the purposes of the filing of the Registration
    Statement and the offering of the IPO Shares by the Company and is not to be relied upon in respect of any other matter.” Please
    be advised that you may not limit reliance in a manner that excludes anyone entitled to rely on the opinion. Refer to Staff Legal
    Bulletin 19 at Section II.B.3.d.

    In
    response to the Staff’s comment, the Company has included a revised legality opinion as exhibit 5.1 of the Registration
    Statement No.1, which has removed the referenced limitation.

    4.
    Similarly,
    please ensure that the opinion includes no assumptions which are overly broad, that “assume away” the relevant issue,
    or that assume any of the material facts underlying the opinion or any readily ascertainable facts. For example, in connection with
    its Section 4.3 opinion that the shares offered by the selling shareholders “are validly issued, fully paid and non-assessable,”
    counsel may not assume that such shares “have been fully paid for and the issue price was at or above par value,” as
    it does in Section 2.9. Refer to Staff Legal Bulletin 19 at Sections II.B.2.h and II.B.3.a.

    In
    response to the Staff’s comment, the Company has included a revised legality opinion as exhibit 5.1 of the Registration
    Statement No.1, which has removed the referenced assumptions.

General

    5.
    We
                                            note the proposed offering by the selling shareholders of up to 1,680,210 Ordinary Shares.
                                            It appears that the transaction may be an indirect primary offering with the selling shareholders
                                            acting as a conduit in a distribution to the public. Please provide us with your detailed
                                            analysis as to why the proposed offering is not an indirect primary offering on your behalf
                                            and thus is appropriately characterized as a valid secondary offering under Securities Act
                                            Rule 415(a)(1)(i). For guidance, please see Interpretive Response 612.09 of our Compliance
                                            and Disclosure Interpretations for Securities Act Rules.

    In
    response to the Staff’s comment, the Company respectfully advises the Staff that the Company is not registering any of its
    shares for resale in this offering. The Company has removed the resale prospectus in the Registration Statement No.1.

    Very
    truly yours,

    /s/ Virginia Tam

    Name:
    Virginia
    Tam

    Title:

    Partner

United States securities and exchange commission logo
September 6, 2023
Wai Yiu Yau
Chief Executive Officer
Globavend Holdings Ltd
Office 1401, Level 14, 197 St Georges Tce,
Perth, WA 6000,
Australia
Re:Globavend Holdings Ltd
Registration Statement on Form F-1
Filed August 23, 2023
File No. 333-274166
Dear Wai Yiu Yau:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 18, 2023 letter.
Form F-1 Filed August 23, 2023
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 60
1.We note you revised your disclosure on page 59 in response to prior comment 1.  We re-
issue the comment. Please revise your discussion, to the extent material to an
understanding of your results of operations, to quantify for each period presented the
impact that foreign currency movement had on specific line items of revenue and
expenses. For example, discussions about changes in the price vs. volume mix should
consider changes in foreign currency fluctuation and how they impacted revenue. Refer to
Item 5.A.3. of Form 20-F.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 September 6, 2023 Page 2
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
September 6, 2023
Page 2
Exhibits
Exhibit 5.1
Opinion of Conyers Dill & Pearman, page II-4
2.If counsel intends to use the term "Resale Shares" in the legality opinion, please revise the
opinion to define the term and to opine on the Resale Shares at Section 4.3.
3.At Section 3.3, counsel states that the legality opinion "is issued solely for the purposes of
the filing of the Registration Statement and the offering of the IPO Shares by the
Company and is not to be relied upon in respect of any other matter."  Please be advised
that you may not limit reliance in a manner that excludes anyone entitled to rely on the
opinion.  Refer to Staff Legal Bulletin 19 at Section II.B.3.d.
4.Similarly, please ensure that the opinion includes no assumptions which are overly broad,
that “assume away” the relevant issue, or that assume any of the material facts underlying
the opinion or any readily ascertainable facts.  For example, in connection with its Section
4.3 opinion that the shares offered by the selling shareholders "are validly issued, fully
paid and non-assessable," counsel may not assume that such shares "have been fully paid
for and the issue price was at or above par value," as it does in Section 2.9.  Refer to Staff
Legal Bulletin 19 at Sections II.B.2.h and II.B.3.a.
General
5.We note the proposed offering by the selling shareholders of up to 1,680,210 Ordinary
Shares.  It appears that the transaction may be an indirect primary offering with the selling
shareholders acting as a conduit in a distribution to the public.  Please provide us with
your detailed analysis as to why the proposed offering is not an indirect primary offering
on your behalf and thus is appropriately characterized as a valid secondary offering under
Securities Act Rule 415(a)(1)(i).  For guidance, please see Interpretive Response 612.09
of our Compliance and Disclosure Interpretations for Securities Act Rules.
            You may contact Steve Lo, Staff Accountant, at (202) 551-3394 or Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding comments on the
financial statements and related matters. Please contact Liz Packebusch, Staff Attorney, at (202)
551-8749 or Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Virginia Tam

United States securities and exchange commission logo
August 18, 2023
Wai Yiu Yau
Chief Executive Officer
Globavend Holdings Ltd
Office 1401, Level 14, 197 St Georges Tce,
Perth, WA 6000,
Australia
Re:Globavend Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted August 4, 2023
CIK No. 0001978527
Dear Wai Yiu Yau:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by 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 our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments 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-1 submitted August 4, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 60
1.In response to prior comment 3, you disclosed the amounts of the foreign exchange gains
for the years ended September 30, 2021 and 2022.  We re-issue the comment.  Please
revise your discussion, to the extent material to an understanding of your results of
operations, to quantify for each period presented the impact that foreign currency
movement had on specific line items of revenue and expenses. Refer to Item 5.A.3. of
Form 20-F.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 August 18, 2023 Page 2
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
August 18, 2023
Page 2
Cash Flow
Operating Activities, page 66
2.We note the additional disclosure added in response to prior comment 7.  We re-issue the
comment. Please revise your discussion of operating cash flow to discuss the underlying
drivers for the material changes of the components of the operating cash flows between
periods. Refer to SEC Release No. 33-8350, Section IV for guidance.
Our Competitive Strengths, page 70
3.We note your response to prior comment 8. You indicate that you purchased shipping
solution software in 2019 that was modified internally to meet the company's internal
need. However, your disclosure on page 71 indicates that your software is "self-
developed" and you "have internally developed [your] own proprietary all-in-one shipping
solution." Please revise this disclosure to indicate that you purchased software and
internally modified such software.
Our Strategies, page 72
4.We note your response to prior comment 9 and reissue it in part. You state here that you
plan to further expand your "logistics network and business presence in Australia and
New Zealand" and at page 24 that you "intend to hire additional staff in Hong Kong and
Australia to facilitate [your] expansion plans."  Please further discuss your plans to expand
your business in Hong Kong and New Zealand.
MANAGEMENT
Employment Agreements and Indemnification Agreements, page 94
5.We note your response to prior comment 10, including your having filed, at Exhibit
10.2, the employment agreement entered with Mr. Wai Yiu Yau, your Chief Executive
Officer. Please update your disclosure in this section to reflect the agreement with Mr.
Wai Yiu Yau and describe its material terms.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 August 18, 2023 Page 3
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
August 18, 2023
Page 3
            You may contact Steve Lo, Staff Accountant, at (202) 551-3394 or Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding comments on the
financial statements and related matters. Please contact Liz Packebusch, Staff Attorney, at (202)
551-8749 or Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Virginia Tam

United States securities and exchange commission logo
July 18, 2023
Wai Yiu Yau
Chief Executive Officer
Globavend Holdings Ltd
Office 1401, Level 14, 197 St Georges Tce,
Perth, WA 6000,
Australia
Re:Globavend Holdings Ltd
Draft Registration Statement on Form F-1
Submitted June 20, 2023
CIK No. 0001978527
Dear Wai Yiu Yau:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by 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 our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted June 20, 2023
Summary of Key Risks
Risks Related to Doing Business in Hong Kong, page 9
1.Please revise your summary of risk factors to acknowledge any risks that any actions by
the Chinese government to exert more oversight and control over offerings that are
conducted overseas and/or foreign investment in Hong Kong or China-based issuers could
significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 July 18, 2023 Page 2
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
July 18, 2023
Page 2
RISK FACTORS
We are an emerging growth company..., page 43
2.Please revise your risk factor to identify any exemptions and scaled disclosures which
overlap with those available to you as both a foreign private issuer and an emerging
growth company, and to clarify that the described exemptions and scaled disclosures as a
result of your status as a foreign private issuer will be available to you even if you no
longer qualify as an emerging growth company.
Results of Operations, page 60
3.We note your disclosure regarding the fluctuations in foreign exchange rates on page 59.
Please revise your discussion, to the extent material to an understanding of your results of
operations, to quantify for each period presented the impact that foreign currency
movement had on your revenue and expenses.  Refer to Item 5.A.3. of Form 20-F.
4.We note your revenue from integrated cross-border logistics services increased 62.1% in
2022 and revenue from air freight forwarding services increased 262.5% in 2022.  Please
revise your discussions of revenues to describe if such changes are attributable to changes
in prices or other factors.  For example, disclose average daily package volume, average
daily freight pounds, average daily shipments, the number of air freight spaces sold for
each period, or any other metric, if available. Refer to Item 5.A.1. of Form 20-F.
Liquidity and Capital Resources, page 63
5.We note you discussed the working capital as of September 30, 2022 as compared to
September 30, 2021.  Please revise to discuss the underlying reasons for the significant
fluctuations of the components of the working capital between periods.  For example, but
not limited to, discuss the underlying reasons why your cash and cash equivalents
decreased significantly while your accounts payables increased significantly.
6.Please revise to analyze your ability to generate and obtain adequate amounts of cash to
meet your requirements and plans for cash in the short-term and separately in the long-
term.  Additionally, provide a statement that in management’s opinion the working capital
is sufficient for the company’s present requirements, or, if not, how you propose to
provide the additional working capital needed. Refer to Item 5.B.1(a) of Form 20-F.
Cash Flow
Operating Activities, page 66
7.Your discussion of net cash flows used in operating activities merely describes the items
identified on the face of the statement of cash flows.  Please revise your discussion of
operating cash flow to address material changes in the primary drivers and other material
factors.  Refer to SEC Release No. 33-8350 for guidance.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 July 18, 2023 Page 3
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
July 18, 2023
Page 3
Our Competitive Strengths, page 69
8.On pages 71 and 80, you detail your self-developed, all-in-one shipping solution. Tell us
your consideration of ASC 985-20. In this regard, ASC 985-20-55-3 indicates that the
costs of software that is marketed as part of a product or process are included in the scope
of this subtopic.
BUSINESS
Our Strategies, page 72
9.You state here that you plan to further expand your "logistics network and business
presence in Australia and New Zealand" and at page 24 that you "intend to hire additional
staff in Hong Kong to facilitate our expansion plans."  Please further discuss your plans to
expand your business and provide updated staffing information for each location.
MANAGEMENT, page 92
10.We note your disclosure that you intend to enter into employment agreements with each
of your executive officers, and that you intend to enter into agreements with all directors
whose service will begin upon the effectiveness of the registration statement. Please
update your exhibit index to include the employment contracts required by
Item 601(b)(10) of Regulation S-K, as contemplated by Item 8 of Form F-1, rather
than “forms of” employment agreement. In the alternative, confirm if true that these
agreements are not required to be publicly filed in your home country, are not otherwise
publicly disclosed, and therefore are not filed based on Item 601(b)(10)(iii)(C)(5)
of Regulation S- K.
General
11.We note your definition of “mainland China” includes the special administrative region of
Hong Kong. However, such inclusion appears inconsistent with disclosure elsewhere. For
instance, your cover page disclosure states that you are headquartered in Hong Kong, a
special administrative region of the People’s Republic of China (“China” or the “PRC”),
with its own governmental and legal system that is independent from mainland China, and
that the legal and operational risks associated with operating in mainland China may also
apply to your operations in Hong Kong. Please revise your definition or advise. In
addition, please clarify that all of the legal and operational risks associated with operating
in the PRC also apply to your operations in Hong Kong. Where appropriate, you may
describe PRC law and then explain how the law in Hong Kong differs from PRC law and
describe any risks and consequences to the company associated with those laws.

 FirstName LastNameWai Yiu Yau
 Comapany NameGlobavend Holdings Ltd
 July 18, 2023 Page 4
 FirstName LastName
Wai Yiu Yau
Globavend Holdings Ltd
July 18, 2023
Page 4
12.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
            You may contact Steve Lo, Staff Accountant, at (202) 551-3394 or Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding comments on the
financial statements and related matters.  Please contact Liz Packebusch, Staff Attorney, at (202)
551-8749 or Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Virginia Tam