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                                                            April 10, 2025

Marriana Henares Yulo
Chief Executive Officer
Hotel101 Global Holdings Corp.
20 Cecil Street #04-03
Plus Building
Singapore 049705

Marriana Henares Yulo
Chief Executive Officer
Hotel101 Global Pte. Ltd.
20 Cecil Street #04-03
Plus Building
Singapore 049705

       Re: Hotel101 Global Holdings Corp.
           Hotel101 Global Pte. Ltd.
           Amended Draft Registration Statement on Form F-4
           Submitted March 31, 2025
           CIK No. 0002054507
Dear Marriana Henares Yulo and Marriana Henares Yulo:

     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, any references to prior comments are to
comments in
our March 25, 2025 letter.
 April 10, 2025
Page 2



Amended Draft Registration Statement on Form S-4
Risk Factors
JVSPAC is not required to, and did not, obtain a third-party valuation, page 62

1.     We note your revised disclosure in response to prior comment 7 that the
reliance on a
       fragmented ownership structure, where units are owned by third party
real estate unit
       owners, forms a core similarity between you and Airbnb. Please expand
your risk
       factor disclosure to address your valuation and disclose clearly the
differences in your
       business model compared to that of Airbnb.
Provide competitive returns to Unit Owners to establish a diversified and
satisfied buyer
population., page 162

2.     We note your revised disclosure in response to prior comment 11. Please
clarify that
       the Unit Owners' Yield on the Phillipine hotels should not be taken as
an indication of
       future financial performance of properties of Hotel101 Global.
       Please contact Kellie Kim at 202-551-3129 or Isaac Esquivel at
202-551-3395 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with any
other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   James Grandolfo, Esq.
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