December 19, 2024

Zhizhuang Miao
Chief Executive Officer
Global Lights Acquisition Corp
Room 902, Unit 1, 8th Floor, Building 5
No. 201, Tangli Road
Chaoyang District, Beijing 100123
The People   s Republic of China

       Re: Global Lights Acquisition Corp
           Form 10-K for the fiscal year ended December 31, 2023
           File No. 001-41865
Dear Zhizhuang Miao:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2023
Part I
Item 1. Business, page 4

1.     Please provide disclosure about the legal and operational risks
associated with being
       based in or having the majority of the company   s operations in China.
Your disclosure
       should make clear whether these risks could result in a material change
in your
       operations and/or the value of your securities or 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. Your
       disclosure should address how recent statements and regulatory actions
by China   s
       government, such as those related to data security or anti-monopoly
concerns, have or
       may impact the company   s ability to conduct its business, accept
foreign investments,
       or list on a U.S. or other foreign exchange.
2.     Please disclose the location of your auditor   s headquarters and
whether and how the
       Holding Foreign Companies Accountable Act, as amended by the
Consolidated
 December 19, 2024
Page 2

       Appropriations Act, 2023, and related regulations will affect your
company.
3.     Please provide a clear description of how cash is transferred through
your
       organization. State whether any transfers, dividends, or distributions
have been made
       to date between the company and its investors, and quantify the amounts
where
       applicable. Describe any restrictions on foreign exchange and your
ability to transfer
       cash between entities, across borders, and to U.S. investors. Describe
any restrictions
       and limitations on your ability to distribute earnings from the company
to U.S.
       investors.
4.     Where you discuss PRC regulations concerning mergers and acquisitions,
please
       expand to address any impact PRC law or regulation may have on the cash
flows
       associated with the business combination, including shareholder
redemption rights.
5.     Please include a separate section on enforcement of liabilities
addressing the
       enforcement risks related to civil liabilities due to you, your sponsor,
and your officers
       and directors being located in China or Hong Kong. For example, revise
to discuss
       more specifically the limitations on investors being able to effect
service of process
       and enforce civil liabilities in China, lack of reciprocity and
treaties, and cost and time
       constraints. Additionally, please identify each officer and director
located in China or
       Hong Kong and disclose that it will be more difficult to enforce
liabilities and enforce
       judgments on those individuals.
General

6.     Please disclose the risks that your corporate structure and being based
in or having the
       majority of the company's operations in China poses to investors. In
particular,
       describe the significant regulatory, liquidity, and enforcement risks.
For example,
       specifically discuss risks arising from the legal system in China,
including risks and
       uncertainties regarding the enforcement of laws and that rules and
regulations in
       China can change quickly with little advance notice; and the risk that
the Chinese
       government may intervene or influence your operations at any time, or
may exert
       more control over offerings conducted overseas and/or foreign investment
in China-
       based issuers, which could result in a material change in your
operations and/or the
       value of your securities. 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 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.
        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.
 December 19, 2024
Page 3

        Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related
matters. Please contact Benjamin Holt at 202-551-6614 or Jeffrey Gabor at
202-551-2544
with any other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Real Estate
& Construction