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                             December 18, 2023

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

                                                        Re: BeLive Holdings
                                                            Amendment No.2 to
Draft Registration Statement on Form F-1
                                                            Submitted December
4, 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 October 13,
       2023 letter.

       Draft Registration Statement filed December 4, 2023

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

   1.                                                   We note your response
to prior comment 1 and reissue in part. Because you identify your
                                                        customer's ability to
increase their own customer base as a key performance metric, please
                                                        revise to quantify
increases and discuss historical trends in your customers' customer
                                                        bases for the periods
presented. To the extent such data is not tracked, please clarify how
                                                        management uses
increases in your customers' customer bases as a key performance
                                                        metric in the
evaluation of your business.
 Kenneth Teck Chuan Tan
FirstName LastNameKenneth Teck Chuan Tan
BeLive Holdings
Comapany18,
December  NameBeLive
              2023     Holdings
December
Page 2    18, 2023 Page 2
FirstName LastName
Liquidity and Capital Resources, page 49

2.       We note your revised disclosure indicates that none of the net assets
of your subsidiary in
         Singapore were restricted net assets as such net assets do not form
part of the dividends (if
         any) to be distributed to its respective shareholders. Clarify if you
can currently distribute
         the net assets of your Singapore subsidiary to the parent company
through dividends or
         other means. If not, it does not appear that they should be described
as unrestricted. Please
         revise your disclosure to describe the specific restrictions with
respect to your ability to
         distribute the net assets to the parent company.
Consolidated Financial Statements for the Years Ended December 31, 2022 and
2021
Notes to the Consolidated Financial Statements
2. Summary of Significant Accounting Policies
(q) Revenue Recognition, page F-28

3.       Clarify how you determine it is probable that you will collect the
consideration to which
         you are entitled and it is appropriate to recognize revenue. Refer to
paragraph 9(e) of
         IFRS 15. Further, based on your response to prior comment 6, it
appears that there may
         have been significant changes in your customers    ability to pay.
Clarify why it is
         appropriate to continue to recognize revenue for any customers who are
in default, rather
         than recognize a liability until it is probable that you will collect
the consideration. Refer
         to paragraph 13 of IFRS 15.
Consolidated Financial Statements for the Six Months Ended June 30, 2023 and
2022
12. Trade and Other Receivables, page F-78

4.       Your response to prior comment 6 indicates that the entire balance
that was greater than
         90 days past due as of December 31, 2022 remains uncollected through
the current date
         and has been fully reserved. Clarify your disclosures to describe how
you took into
         account this default rate in determining your loss allowance for your
remaining
         receivables. Clarify whether your remaining receivables include sales
to the same
         customers that are included in the fully reserved balances and, if so,
why it is appropriate
         that these balances are not fully reserved. Please also disclose your
trade receivables by
         aging category as of the end of the most recent reporting period and
the associated loss
         allowance for each category. Clarify how you determined your expected
credit loss for
         each category taking into consideration your historical default rates
and past due status.
       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,
 Kenneth Teck Chuan Tan
BeLive Holdings
December 18, 2023
Page 3

FirstName LastNameKenneth Teck Chuan Tan
                                           Division of Corporation Finance
Comapany NameBeLive Holdings
                                           Office of Technology
December 18, 2023 Page 3
cc:       Henry Schlueter
FirstName LastName