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                             October 13, 2023

       Kenneth Teck Chuan Tan
       Chief Executive Officer
       BeLive Holdings
       29 Media Circle
       Mediapolis 09-06
       Singapore 138565

                                                        Re: BeLive Holdings
                                                            Amendment No.1 to
Draft Registration Statement on Form F-1
                                                            Submitted September
28, 2023
                                                            CIK No. 0001982448

       Dear Kenneth Teck Chuan Tan:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              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. Unless we note otherwise, our references to prior comments are
to comments in our
       August 31, 2023 letter.

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

       Management's Discussion and Analysis of Financial Condition and Results
of Operation, page
       43

   1.                                                   We note your response
to prior comment 1. Because you identify your customer's ability
                                                        to increase their own
customer base as a key performance metric, please revise to quantify
                                                        those increases for the
periods presented. In addition, provide a more detailed discussion
                                                        regarding the analytics
and A.I. utilized in providing your customer's insights for their
                                                        marketing campaigns.
 Kenneth Teck Chuan Tan
FirstName LastNameKenneth Teck Chuan Tan
BeLive Holdings
Comapany
October 13,NameBeLive
            2023       Holdings
October
Page 2 13, 2023 Page 2
FirstName LastName
Liquidity and Capital Resources, page 47

2.       We note your revised disclosure indicates that current Singapore
regulations permit your
         Singapore subsidiary to pay dividends to its respective shareholders
only out of its
         accumulated profits, if any, and that as of December 31, 2022, your
Singapore
         subsidiary   s accumulated losses were S$19,264,424. You further
disclose that none of the
         net assets of your subsidiary in Singapore were restricted net assets.
Considering that
         your Singapore subsidiary does not have accumulated profits, it
appears that its net assets
         are restricted from the payment of dividends to the parent. Please
revise your disclosure
         or advise why you believe none of the net assets of your subsidiary in
Singapore are
         restricted.
Our Customers, page 67

3.       We note your response to prior comment 4. Please tell us what
consideration you gave to
         filing any contracts you may have with your major three customers as
exhibits. Refer
         to Item 601(b)(10) Regulation S-K.
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
2. Summary of Significant Accounting Policies
(q) Revenue Recognition,
Consultancy fee, Installation fee, and Source code, page F-30

4.       Revise your disclosures to clarify the specific products and services
included in revenue
         from source code and describe how the services or milestone
obligations are performed
         over time.
5.       You disclose that the transaction price is allocated based on the
price stated in the
         contracts with customers. Clarify the specific products and services
that are included
         in the same contract for which you allocate the transaction price.
Please also clarify how
         the prices stated in the contract are representative of standalone
selling price. That is,
         clarify if these are the same price for which the good or service is
sold separately. If the
         good or service is not sold separately, clarify how you estimated the
standalone selling
         price. Refer to ASC 606-10-32-28 through 606-10-32-35. Revise your
disclosures
         accordingly.
22. Financial Risk Management and Fair Value of Financial Instruments, page
F-51

6.       Please provide your response to prior comment 10. We note your revised
disclosure that if
         amounts are greater than 365 days past due, your basis for recognized
expected credit
         losses is Lifetime ECL - credit impaired. Please clarify how you
determine expected credit
         losses for amounts that are greater than 90 days past due and describe
the specific factors
         you considered in determining that no loss allowance is required for
the $586,603 trade
         receivables that are greater than 90 days past due as of December 31,
2022, including how
 Kenneth Teck Chuan Tan
BeLive Holdings
October 13, 2023
Page 3
       you considered the past due status. Also, tell us how much of this past
due balance has
       been received subsequent to December 31, 2022 through the current date.
Item 7. Recent Sales of Unregistered Securities, page II-1

7.     We note that, in response to prior comment 6, you provided disclosure of
prior issuances
       of redeemable, convertible, and cumulative preference stock. Please
provide disclosure of
       all recent issuances of unregistered securities under "Item 7. Recent
Sales of Unregistered
       Securities" and ensure that all required disclosure is included. Refer
to Item 701 of
       Regulation S-K.
       Please contact Laura Veator at 202-551-3716 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Lauren Pierce at 202-551-3887 or Matthew Derby at 202-551-3334 with any
other
questions.



                                                             Sincerely,
FirstName LastNameKenneth Teck Chuan Tan
                                                             Division of
Corporation Finance
Comapany NameBeLive Holdings
                                                             Office of
Technology
October 13, 2023 Page 3
cc:       Henry Schlueter
FirstName LastName