SecProbe.io

CORRESP
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 filename1.htm

 Linkage
Global Inc

 2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022

 VIA EDGAR

 March 6, 2026

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:
 Scott Anderegg

 Re:
 Linkage Global Inc

 Request for Acceleration

 Registration Statement on Form F-3, as amended (File No. 333-293678)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the
General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended, Linkage Global Inc
hereby requests that the effectiveness of the above-referenced Registration Statement (the " Registration Statement ")
be accelerated to, and that the Registration Statement become effective at 4:00 p.m., Eastern Time on March 10, 2026, or as soon thereafter
as practicable.

 Please contact Tomer Magid
of Sichenzia Ross Ference Carmel LLP at (646) 693-6586, as soon as the Registration Statement has been declared effective, or if you have
any other questions or concerns regarding this matter.

 Very truly yours,

 Linkage Global Inc

 By:
 /s/ Yang (Angela) Wang

 Name:
 Yang (Angela) Wang

 Title:
 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 3, 2026

Angela Wang
Chief Executive Officer
Linkage Global Inc
2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022

 Re: Linkage Global Inc
 Registration Statement on Form F-3
 Filed February 24, 2026
 File No. 333-293678
Dear Angela Wang:

 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 Scott Anderegg at 202-551-3342 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>

CORRESP
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 filename1.htm

 Linkage Global Inc

 2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022

 July 31, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Linkage Global Inc

 Registration Statement on Form F-1, as
amended

 File No. 333-288089

 Ladies and Gentlemen:

 Pursuant to Rules 460 and
461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the " Act "), Linkage Global
Inc (the " Company ") respectfully requests that the effective date of the registration statement referred to above (the
" Registration Statement ") be accelerated so that it will become effective at 5:00 p.m., Eastern Time, on Monday, August
4, 2025, or as soon thereafter as possible. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities
under the Act.

 Once the Registration Statement
is effective, please orally confirm the event with our counsel, Sichenzia Ross Ference Carmel LLP by calling Shane Wu at (202) 322-8852.
We also respectfully request that a copy of the written order from the Securities and Exchange Commission verifying the effective time
and date of the Registration Statement be sent to our counsel, Sichenzia Ross Ference Carmel LLP, Attention: Shane Wu, Esq, by email at
swu@srfc.law and Tomer Magid, by email at tmagid@srfc.law.

 If you have any questions
regarding this request, please contact Shane Wu, Esq. of Sichenzia Ross Ference Carmel LLP, at (202) 322-8852.

 Very Truly Yours,

 By:
 /s/ Yang (Angela) Wang

 Name:
 Yang (Angela) Wang

 Title:
 Chief Executive Officer

 cc:
 Shane Wu, Sichenzia Ross Ference Carmel LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 25, 2025

Yang Wang
Chief Executive Officer
Linkage Global Inc
2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022

 Re: Linkage Global Inc
 Registration Statement on Form F-1
 Filed June 16, 2025
 File No. 333-288089
Dear Yang Wang:

 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 Rucha Pandit at 202-551-6022 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Huan Lou
</TEXT>
</DOCUMENT>

CORRESP
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Linkage Global Inc

December 31, 2024

Via EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Cara Wirth

    Re:
    Linkage Global Inc

    Registration Statement on Form F-1, as amended

    Initially Filed on November 27, 2024

    File No. 333-283495

Dear Ms. Wirth:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Linkage Global Inc hereby requests that the effectiveness
of the above-referenced Registration Statement on Form F-1, as amended, be accelerated to and that the Registration Statement become
effective at 5:00 p.m., Eastern Time, on December 31, 2024, or as soon thereafter as practicable.

    Very truly yours,

    Linkage Global Inc

    By:
    /s/ Zhihua Wu

    Name:
    Zhihua Wu

    Title:
    Chief Executive Officer

December 5, 2024
Zhihua Wu
Chief Executive Officer
Linkage Global Inc
2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022
Re:Linkage Global Inc
Registration Statement on Form F-1
Filed November 27, 2024
File No. 333-283495
Dear Zhihua Wu:
            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 Cara Wirth at 202-551-7127 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Joan S. Guilfoyle

CORRESP
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Linkage Global Inc

December 13, 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:
    Rucha Pandit

    Dietrich King

    Re:
    Linkage Global Inc

    Registration Statement on Form F-1, as amended

    Initially Filed on September 1, 2023

    File No. 333-274326

Ladies and Gentlemen:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Linkage Global Inc hereby requests that the effectiveness
of the above-referenced Registration Statement on Form F-1, as amended, be accelerated to and that the Registration Statement become
effective at 4:30 p.m., Eastern Time, on December 18, 2023, or as soon thereafter as practicable.

    Very truly yours,

    Linkage Global Inc

    By:
    /s/ Zhihua Wu

    Name:
    Zhihua Wu

    Title:
    Chief Executive Officer

CORRESP
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EF Hutton, division of Benchmark Investments,
LLC

590 Madison Avenue, 39th Floor

New York, New York 10022

December 13, 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:
    Rucha Pandit

    Dietrich King

    Re:
    Linkage Global Inc

    Registration Statement on Form F-1, as amended

    Initially Filed on September 1, 2023

    File No. 333-274326

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”), EF Hutton,
division of Benchmark Investments, LLC, acting as representative of the underwriters, hereby joins Linkage Global Inc in requesting acceleration
of the effective date of the above-referenced Registration Statement, so that it will become effective on December 18, 2023, at 4:30 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 15, 2023, to selected dealers,
institutions, and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

The undersigned confirms 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,

    EF Hutton, division of Benchmark Investments, LLC

    By:
    /s/ Sam Fleischman

    Name:
    Sam Fleischman

    Title:
    Supervisory Principal

CORRESP
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Linkage Global Inc

September 15, 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:
    Keira Nakada

    Lyn Shenk

    Rucha Pandit

    Dietrich King

    Re:
    Linkage Global Inc

    Registration Statement on Form F-1

    Filed September 1, 2023

    File No. 333-274326

Ladies and Gentlemen:

This letter is in response to the letter dated
September 12, 2023 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Linkage Global Inc (the “Company,” “we,” and “our”). For ease of
reference, we have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 1 to the Registration
Statement on Form F-1 (the “Amendment No. 1 to the Registration Statement”) is being filed to accompany this letter.

Registration Statement on Form F-1

Since we are a “controlled company”
within the meaning of the Nasdaq listing rules . . ., page 32

    1.
    We note your disclosure on the cover page as well as page 14 that upon the completion of the offering, the controlling shareholders “will beneficially own approximately 66.51% of the aggregate voting power” of your issued and outstanding ordinary shares. Please revise your disclosure here to identify the percentage of voting power to be held by the controlling shareholders following the offering. Additionally, please disclose, if true, that the controlling shareholders will have the ability to determine all matters requiring approval by stockholders in the event that you rely on the controlled company exemptions under the Nasdaq listing rules.

Response: In response to the Staff’s
comment, we revised our disclosure on page 32 of Amendment No. 1 to the Registration Statement to identify the percentage of voting power
to be held by the controlling shareholders following the offering. Additionally, we revised the cover page, page 15 and page 32 of Amendment
No. 1 to the Registration Statement to disclose that, following the completion of this offering, the controlling shareholders will have
the ability to determine any matter required to be passed by an ordinary resolution, which will be adopted when approved by a simple majority
of votes cast by the shareholders of the Company, and that our controlling shareholders will have the ability to at least significantly
influence, or in certain cases, control the outcome of a matter required to be passed by a special resolution, which will be adopted when
approved by not less than two-thirds of votes cast by the shareholders of the Company.

Dilution, page 66

    2.
    Please tell us how you calculated adjusted net tangible book value of $8,413,684 as of March 31, 2023 based on net tangible book value of $4,761,844 and $5,481,170 in net proceeds from the sale of 1,500,000 ordinary shares from this offering, after deducting the underwriting discounts and estimated offering expenses.

Response: In response to the Staff’s
comment, we revised the disclosure in the dilution section on page 66 of Amendment No. 1 to the Registration Statement. The adjusted net
tangible book value of $9,090,475 as of March 31, 2023 derives from the net tangible book value of $3,609,305, plus net proceeds of $5,481,170
from the sale of 1,500,000 ordinary shares from this offering, after deducting the underwriting discounts and estimated offering expenses.

In responding to your comments, the Company acknowledges
that:

    ●
    the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

    ●
    the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Zhihua Wu

    Name:
    Zhihua Wu

    Title:
    Chief Executive Officer, Director, and

Chairman of the Board of Directors

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
September 12, 2023
Zhihua Wu
Chief Executive Officer
Linkage Global Inc
2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022
Re:Linkage Global Inc
Registration Statement on Form F-1
Filed September 1, 2023
File No. 333-274326
Dear Zhihua Wu:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Since we are a "controlled company" within the meaning of the Nasdaq listing rules . . ., page 32
1.We note your disclosure on the cover page as well as page 14 that upon the completion of
the offering, the controlling shareholders "will beneficially own approximately 66.51% of
the aggregate voting power" of your issued and outstanding ordinary shares.  Please revise
your disclosure here to identify the percentage of voting power to be held by the
controlling shareholders following the offering.  Additionally, please disclose, if true, that
the controlling shareholders will have the ability to determine all matters requiring
approval by stockholders in the event that you rely on the controlled company exemptions
under the Nasdaq listing rules.

 FirstName LastNameZhihua Wu
 Comapany NameLinkage Global Inc
 September 12, 2023 Page 2
 FirstName LastName
Zhihua Wu
Linkage Global Inc
September 12, 2023
Page 2
Dilution, page 66
2.Please tell us how you calculated adjusted net tangible book value of $8,413,684 as of
March 31, 2023 based on net tangible book value of $4,761,844 and $5,481,170 in net
proceeds from the sale of 1,500,000 ordinary shares from this offering, after deducting the
underwriting discounts and estimated offering expenses.
            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.
            You may contact Keira Nakada at (202) 551-3659 or Lyn Shenk at (202) 551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Rucha Pandit at (202) 551-6022 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li

CORRESP
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Linkage Global Inc

September 1, 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:
    Keira Nakada

    Lyn Shenk

    Rucha Pandit

    Dietrich King

    Re:
    Linkage Global Inc

    Amendment No. 2 to Draft Registration Statement on Form F-1

    Submitted August 4, 2023

    CIK No. 0001969401

Ladies and Gentlemen:

This letter is in response to the letter dated
August 23, 2023 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Linkage Global Inc (the “Company,” “we,” and “our”). For ease of
reference, we have recited the Commission’s comments in this response and numbered them accordingly. A Registration Statement on
Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

Amendment No. 2 to Draft Registration Statement
on Form F-1

Cover Page

    1.
    We note your response to comment 1 and reissue in part. In this regard, we note your disclosure here as well as on pages 11 and 12 that “[t]here are currently no restrictions on foreign exchange and [y]our ability to transfer cash among [y]our Cayman Islands holding company and [y]our principal subsidiaries in Hong Kong and Japan.” Please revise your disclosure here and elsewhere as appropriate to address whether there are any limitations on your ability to transfer cash to investors.

Response: In response to the Staff’s
comment, we revised our disclosure on the cover page, page 11 and page 12 of the Registration Statement to disclose the restrictions
on our ability to issue dividends or make distributions to investors.

Notes to Unaudited Condensed Consolidated
Financial Statements

3. Segment Information, page F-16

    2.
    We note the disclosure you provided in response to comment 15. Please revise this disclosure to include right-of-use assets by geography.

Response: In response to the Staff’s
comment, we revised disclosure on page F-16 of the Registration Statement.

2. Summary of Significant Accounting Policies

Revenue Recognition

Integrated E-Commerce Services, page F-39

    3.
    We note the disclosure you revised in response to comment 14. Please tell us how the billing reports received from social media platforms directly correspond with the value transferred to the customers. In this regard, tell us how you consider the revenue adjustments that occur following the reconciliation process during the month following each quarter-end, including the materiality of such adjustments.

Response: We respectfully acknowledge the
Staff’s comment. The Company introduces new Merchants to social media platforms and continuously operates ad accounts on behalf
of Merchants introduced by the Company. The billing reports record the names of Merchants and their corresponding consumption of ads for
each quarter on social media platforms, which directly correspond with the value transferred from the Group to social media platforms.

The Company first books the estimated revenue
based on the billing report received for the preceding quarter, and trues-up the revenue amount based on the billing report for the current
quarter upon receipt in the following quarter. Generally, the Company receives the quarterly billing report within three months after
each quarter end. Since the filing dates of both the audit financial statement and interim financial statement were more than three months
after the fiscal year-end and interim period-end, the revenue as presented in the financial statements were already adjusted based on
the current billing report. The Company assessed that such adjustments is immaterial. The amount of adjustments were less than 1% and
17% of the digital marketing services for the years ended September 30, 2021 and 2022, respectively, and were less than 1% and 3% of the
total revenues for the years ended September 30, 2021 and 2022, respectively.

In responding to your comments, the Company acknowledges
that:

 ● the
Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 ● Staff
comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to
the filing; and

 ● the
Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

    2

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Zhihua Wu

    Name:
    Zhihua Wu

    Title:
    Chief Executive Officer, Director, and

 Chairman of the Board of Directors

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

3

United States securities and exchange commission logo
August 23, 2023
Zhihua Wu
Chief Executive Officer
Linkage Global Inc
2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022
Re:Linkage Global Inc
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted August 4, 2023
CIK No. 0001969401
Dear Zhihua Wu:
            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. 3 to Draft Registration Statement on Form F-1
Cover Page
1.We note your response to comment 1 and reissue in part.  In this regard, we note your
disclosure here as well as on pages 11 and 12 that "[t]here are currently no restrictions on
foreign exchange and [y]our ability to transfer cash among [y]our Cayman Islands holding
company and [y]our principal subsidiaries in Hong Kong and Japan."  Please revise your
disclosure here and elsewhere as appropriate to address whether there are any limitations
on your ability to transfer cash to investors.

 FirstName LastNameZhihua Wu
 Comapany NameLinkage Global Inc
 August 23, 2023 Page 2
 FirstName LastName
Zhihua Wu
Linkage Global Inc
August 23, 2023
Page 2
Notes to Unaudited Condensed Consolidated Financial Statements
3. Segment Information, page F-16
2.We note the disclosure you provided in response to comment 15.  Please revise this
disclosure to include right-of-use assets by geography.
2. Summary of Significant Accounting Policies
Revenue Recognition
Integrated E-Commerce Services, page F-39
3.We note the disclosure you revised in response to comment 14.  Please tell us how the
billing reports received from social media platforms directly correspond with the value
transferred to the customers.  In this regard, tell us how you consider the revenue
adjustments that occur following the reconciliation process during the month following
each quarter-end, including the materiality of such adjustments.
            You may contact Keira Nakada at (202) 551-3659 or Lyn Shenk at (202) 551-3380 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Rucha Pandit at (202) 551-6022 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li

United States securities and exchange commission logo
June 5, 2023
Zhihua Wu
Chief Executive Officer
Linkage Global Inc
2-23-3 Minami-Ikebukuro, Toshima-ku
Tokyo, Japan 171-0022
Re:Linkage Global Inc
Draft Registration Statement on Form F-1
Submitted May 9, 2023
CIK No. 0001969401
Dear Zhihua Wu:
            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
Cover Page
1.Please discuss whether there are limitations on your ability to transfer cash between you,
your subsidiaries or investors.  Provide a cross-reference to your discussion of this issue in
your prospectus summary, summary risk factors and risk factors sections, as well.  Please
additionally amend your disclosure here as well as in the summary risk factors and risk
factors sections to state that, to the extent cash in the business is in the PRC/Hong Kong or
a PRC/Hong Kong entity, the funds may not be available to fund operations or for other
use outside of the PRC/Hong Kong due to interventions in or the imposition of restrictions
and limitations on the ability of you or your subsidiaries by the PRC and Hong
Kong governments to transfer cash.  On the cover page, provide cross-references to these

 FirstName LastNameZhihua Wu
 Comapany NameLinkage Global Inc
 June 5, 2023 Page 2
 FirstName LastName
Zhihua Wu
Linkage Global Inc
June 5, 2023
Page 2
other discussions.  Lastly, to the extent you have cash management policies that dictate
how funds are transferred between you, your subsidiaries or investors, summarize the
policies on your cover page, and disclose the source of such policies (e.g., whether they
are contractual in nature, pursuant to regulations, etc.); alternatively, state on the cover
page that you have no such cash management policies that dictate how funds are
transferred.  Provide a cross-reference on the cover page to the discussion of this issue in
the prospectus summary.
Prospectus Summary
Summary of Risk Factors, page 6
2.Please revise your disclosure so that each summary risk factor related to your operations
in Hong Kong and China includes a cross-reference to the individual detailed risk factor,
including the title and page, of the relevant risk factor.
Risk Factors, page 16
3.Please revise your disclosure here and in your summary risk factors section to include a
risk factor discussing your related party transactions with Qi Xiaoyu, Fuyunishiki
Ryo, Wu Zhihua, Wu Shunyu and Ishiyama Real Estate Co. Ltd.  In this regard, the
disclosure on page 118 appears to suggest that the value of transactions related to the
aforementioned individuals and entity is material to the company.
If HQT NETWORK fails to maintain the relationship with Google . . ., page 18
4.It appears you rely on Google's rebate and incentive structure to generate all of your
digital marketing operations revenue as well as a substantial portion of your total revenue.
Please expand your disclosure here and elsewhere in the prospectus as appropriate to
discuss in greater detail your relationship, including the material terms of any agreements
or arrangements with Google.  In this regard, we note your reference to an agency
agreement as well as a detailed discussion of the rebate and incentive structure on page
88.  Additionally, please file the agency agreement with Google as an exhibit to the
registration statement or tell us why you believe you are not required to do so.  Refer to
Item 601(b)(10) of Regulation S-K.
The Operating Entities rely on third-party manufacturers to produce their private label smart
products . . ., page 18
5.It appears you rely on partnerships with third parties to manufacture the Operating
Entities' private label smart products.  To the extent your business is materially dependent
on such partnerships, please expand your disclosure here to identify these third parties and
disclose the material terms of any agreements or arrangements with them.  Additionally,
please file any such agreements as exhibits to the registration statement or tell us why you
believe you are not required to do so.  See Item 601(b)(10) of Regulation S-K.

 FirstName LastNameZhihua Wu
 Comapany NameLinkage Global Inc
 June 5, 2023 Page 3
 FirstName LastName
Zhihua Wu
Linkage Global Inc
June 5, 2023
Page 3
Since we are a "controlled company" within the meaning of the Nasdaq listing rules . . ., page 27
6.Please identify and disclose the percentage of voting power to be held by the controlling
shareholders following the offering.  Additionally, please disclose, if true, that the
controlling shareholders will have the ability to determine all matters requiring approval
by stockholders in the event that you rely on the controlled company exemptions under
the Nasdaq listing rules.
Recent greater oversight by the CAC over data security, particularly for companies seeking to
list on a foreign exchange . . ., page 37
7.Please affirmatively state whether or not you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.
Business
Further Strengthen our Supply Chain Integration, page 84
8.Please revise your disclosure here as well as the summary risk factors and risk
factors sections to disclose whether you are subject to material cybersecurity risks in your
supply chain based on third-party products, software, or services used in your products,
services, or business and how a cybersecurity incident in your supply chain could impact
your business.  Discuss the measures you have taken to mitigate these risks.
Management, page 112
9.We note your disclosure on page 16 that your business relies on the availability of the
Operating Entities' marketplace and software and as a result, is vulnerable to system
interruptions and performance failures in technology infrastructures.  Please describe the
extent and nature of the role of the board of directors in overseeing cybersecurity risks,
including in connection with the company's data protection and supply chain.
Where You Can Find Additional Information, page 152
10.Please update your disclosure to include your internet address.  Refer to Item 4(e) of Form
F-1.
1. Organization and Principal Activities
Reorganization, page F-7
11.We note that your reorganization involved acquisition of entities under common control,
which you reflect as if the post-reorganization structure existed throughout the periods
presented.  Based on this information, your financial statements appear to be more
appropriately described as “combined,” rather than as “consolidated.”  Please revise your
presentation or advise us why you believe you are not required to do so.  Refer to ASC
810-10-45-10.

 FirstName LastNameZhihua Wu
 Comapany NameLinkage Global Inc
 June 5, 2023 Page 4
 FirstName LastName
Zhihua Wu
Linkage Global Inc
June 5, 2023
Page 4
2. Summary of Significant Accounting Policies
Revenue Recognition
Cross-Border Sales, page F-12
12.You state that you consider yourself the principal in the cross-border sales transactions
because you are in control of establishing the transaction price, arranging the whole
process of transactions and bearing inventory risk.  You also state on page 80 that certain
orders are shipped directly from the suppliers to the customers.  For those transactions that
are shipped directly by the suppliers to the customers, please clarify your disclosure to
also state when and how you take control of the goods being sold and bear inventory
risks.  Refer to ASC 606-10-55-37A.
13.We note that the timing of the control transfer is different depending on whether the sales
are made internationally or domestically.  Please revise your disclosure to explain how
this difference impacted your freight cost accounting.  Refer to ASC 606-1025-18A and
25-18B.
Integrated E-Commerce Services, page F-12
14.Please revise your disclosure to clarify whether you recognize revenues based on
estimated amount (e.g. of Advertiser spend) and how you determined that it is probable
that a significant revenue reversal will not occur.  Refer to ASC 606-10-32-11.
3. Segment Information, page F-16
15.Please disclose the disaggregation of long-lived assets other than financial instruments by
geography as required under ASC 280-10-50-41(b).
Notes to the Consolidated Financial Statements
10. Long-term Debts, page F-19
16.Please tell us what the amounts in the column labeled "Principal" represent and clarify in
your disclosure how to correlate with the amounts in the "long-term" and "current portion"
columns.
19. Subsequent Events
Share Split, page F-27
17.Please tell us what consideration you gave to retroactively reflecting the stock split that
occured after year-end but before issuance of the financial statements.  Refer to SAB
Topic 4.C.

 FirstName LastNameZhihua Wu
 Comapany NameLinkage Global Inc
 June 5, 2023 Page 5
 FirstName LastName
Zhihua Wu
Linkage Global Inc
June 5, 2023
Page 5
General
18.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.  Please contact the staff member associated with the review of this filing
to discuss how to submit the materials, if any, to us for our review.
19.Please define or include descriptions of what it means to be an "authorized agent" as it
relates to your partnership with Google.
            You may contact Keira Nakada at (202) 551-3659 or Lyn Shenk at (202) 551-3380 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Rucha Pandit at (202) 551-6022 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li