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.
 Zhihua Wu
FirstName LastNameZhihua Wu
Linkage Global Inc
Comapany
August 23, NameLinkage
           2023        Global Inc
August
Page 2 23, 2023 Page 2
FirstName LastName
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