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                            September 14, 2023

       Dana Green
       Chief Executive Officer
       GlobalTech Corp
       3550 Barron Way, Suite 13a
       Reno, NV 89511

                                                        Re: GlobalTech Corp
                                                            Amendment No. 4 to
Form 10-K for the Fiscal Year Ended December 31, 2022
                                                            Amendment No. 3 to
Form 10-Q for the Quarterly Period Ended March 31,
                                                            2023
                                                            File No. 000-56482

       Dear Dana Green:

              We have reviewed your filing 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Amendment No. 4 to Form 10-K for the fiscal year ended December 31, 2022

       Notes to Consolidated Financial Statements
       Note 2. Basis of Preparation of Consolidated Financial Statements
       Restatement of Prior Balances, page F-13

   1.                                                   We note the revisions
in response to prior comment 1. Please revise the amounts included
                                                        in the column labeled
as    as presented    to agree to the December 31, 2021 balances as
                                                        originally reported in
the Form 10-K for the fiscal year ended December 31, 2022, filed on
                                                        March 31, 2023.
Alternatively, if the financial statements in the subsequent amendments
                                                        are being restated,
please clarify your disclosure.
 Dana Green
FirstName
GlobalTechLastNameDana   Green
           Corp
Comapany 14,
September NameGlobalTech
              2023         Corp
September
Page 2    14, 2023 Page 2
FirstName LastName
2.       Please explain how you computed the adjustment amount related to
restatement (c). That
         is, we note that you reversed a bargain purchase gain of $7.3M
previously recognized on
         the acquisition of Ferret and recognized a bargain purchase of $407K
on the reverse
         merger. As such, it appears the restatement should result in an
adjustment to other income
         of $6.9M. Please explain or revise.
Amendment No. 3 to Form 10-Q for the quarterly period year ended March 31, 2023

Notes to Consolidated Financial Statements
Note 2. Basis of Preparation of Consolidated Financial Statements
Restatement of Prior Balances, page 14

3.       Please revise to provide the disclosures required by ASC 250-10-50-7
for each of the
         periods presented in the filing. In this regard, we note that you have
disclosed the impact
         of the restatements on the balance sheet as of December 31, 2021, the
statements of
         operations for the year ended December 31, 2021 and 2022, and the
statement of cash
         flows for the year ended December 31, 2021. Please also make
applicable changes to the
         disclosures in Amendment No. 1 to Form 10-Q for the quarterly period
ended June 30,
         2023.
        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.

       You may contact Melissa Walsh, Senior Staff Accountant, at (202)
551-3224 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact Kyle
Wiley, Staff
Attorney, at (202) 344-5791 or Larry Spirgel, Office Chief, at (202) 551-3815
with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Sean Neahusan