Executive compensation

We respectfully acknowledge the Staff’s comment and note that our 10-K for the fiscal year ended June 30, 2025, was filed on September 23, 2025. Given we meet the requirements to incorporate by reference according to General Instruction VIII on Form S-1, our executive compensation disclosure for the fiscal year ended June 30, 2025, is incorporated by reference in our Form S-1 filed with the SEC on September 30, 2025. Information We Incorporate by Reference, page 28

In response to the Staff’s comment, the Company has expanded the referenced disclosure on page 350 of Amendment No. 1 to describe the nature of the executive compensation that is being attributed to the Three Party Agreement.

The Offering Statement has been amended per the Staff’s comment and the 2022 Equity Incentive Plan has been filed as an exhibit. Security Ownership of Certain Beneficial Owners and Management, page 66

The Registrant has amended its disclosures to state the following: The portfolio manager receives base and discretionary bonus cash compensation . The bonus that is not directly linked to account performance and is subject to the Adviser’s profitability . Part C Financial Statements and Exhibits Kim McManus, Esq. June 18, 2025 Page 11

We respectfully advise the Staff that we have revised page 107 of the Amended F-1. Index to Financial Statements, page F-1

The executive compensation table has been updated for the fiscal year ended December 31, 2024. Should you have any questions regarding the foregoing, please do not hesitate to contact Jonathan Leinwand at (954) 903-7856. Very Truly Yours, JONATHAN D. LEINWAND, P.A. By: Jonathan Leinwand, Esq. J ONATHAN D. L EINWAND , P.A. 18305 Biscayne Blvd. • Suite 200 • Aventura, FL 33160 • Tel: (954) 903-7856 • Fax: (954) 252-4265 www.jdlpa.com

We believe the analysis of material ESG issues as part of our fundamental research can help us understand long-term risks and opportunities of an investment. As indicated in the disclosure, “The investment adviser may consider environmental, social and governance (‘ESG’) factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument.” We believe the current disclosure is clear that ESG factors may be considered where such factors are material to the value of an investment. b. Explain whether an investment could be made in a company that scores poorly on ESG if it scores strongly on other non-ESG factors.

The relevant disclosures on page 66 of Amendment No. 1 have been revised in response to the Staff’s comment. We thank you for your review of the foregoing. If you have further comments, please feel free to contact to our counsel, Wei Wang, Esq., at wwang@egsllp.com or by telephone at (212) 370-1300. Sincerely, /s/ Zhou Ou Zhou Ou Chief Executive Officer cc: Wei Wang, Esq. Ellenoff Grossman & Schole LLP

We have revised the F-1/A in accordance with the Staff’s comment. Please see the disclosure on page 55 of the F-1/A for further information. White Lion Transaction, page 92

In response to the Staff’s comment, the Company has updated the disclosure beginning on page 236 regarding ReShape’s executive compensation and the disclosure beginning on page 245 regarding Vyome’s executive compensation for the fiscal year ended 12/31/2024. * * * * * Thank you for your review of the submissions. If you should have any questions regarding the response letter, please do not hesitate to contact the Company’s outside legal counsel, Brett Hanson of Fox Rothschild LLP, at (612) 607-7330. Sincerely, /s/ Paul Hickey Paul Hickey cc: Brett Hanson, Fox Rothschild LLP

The Company acknowledges the Staff’s comment and respectively advises the Staff that the Company incurred tax expense of $3.6 million for fiscal 2024 as compared to $5.9 million tax expense for 2023. The primary reason for the $2.3 million change in tax expense during fiscal 2024 as compared to 2023 was due to the $2.3 million difference in foreign tax differentials, which was what the Company explained and disclosed in the MD&A on Page 52 of the Form 10-K. The dollar amount differences in tax credits and non-deductible executive compensation for both fiscal years were immaterial. The reason for the large percentage differences in the effective tax rate reconciliation in Note 12 was primarily due to the smaller amount of pretax book loss of $2.6 million as the denominator in the calculation of effective tax rate reconciliation in fiscal 2024, as compared to the larger amount of pretax…

The Company acknowledges the Staff’s comment. The compensation disclosure for Fusemachines Inc. has been revised to include the fiscal year ended December 31, 2024, in accordance with Item 402(m) of Regulation S-K. See page 285 of the Amendment. General

The Company respectfully advises the Staff that it has revised the disclosure on page 358 of Amendment No. 1 in response to the Staff’s comment. 15 U.S. Securities and Exchange Commission April 21, 2025 Directors and Executive Officers of New Semnur after the Business Combination Executive Officers and Directors after the Business Combination, page 339

In response to the Staff’s comment, we revised our disclosure on page 267 of Amendment No. 1 to the Form F-4 to disclose executive compensation for Globalink’s most recently completed fiscal year. Note 9. Investment in Associates, page F-83

The disclosure on page 40 is correct in that the company has paid 2024 executive salaries of $4,000 and $1,000, and we have revised the Risk Factor accordingly. PAGE 7 SCOTT D. OLSON ESQ. Cautionary Note Regarding Forward-Looking Statements, page 17

In response to the Staff’s comment, we have revised the disclosure in Amendment No. 2. Unaudited Pro Forma Condensed Combined Financial Statements, page 189

The Company acknowledges the Staff’s comment and advises the Staff that it has revised the Executive Compensation Section of the Registration Statement to address the Staff’s comment. If you have any questions, please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter. Sincerely, /s/ Michael J. Blankenship Michael J. Blankenship cc: Patrick NJ Schnegelsberg, Chief Executive Officer, Picard Medical, Inc.

We have revised our disclosure in accordance with the Staff’s comments. Signatures, page 29 16.

The Executive Compensation table has been updated to include full year 2024 information. See pages 87 and 89. On behalf of the Company, we appreciate your attention to this matter. If you have any questions or wish to discuss any matters with respect to this filing, please do not hesitate to contact me at (303) 868-3382 (email: hfs@schlueterintl.com) or my colleague Celia Velletri at (303) 907-4842 (email: cv@schlueterintl.com). Regarding accounting matters, you may contact Chia Lei Kuan of Onestop Assurance PAC at +65 9499 3768 (email: leikuanchia@one-stop-ca.com) in respect of any accounting issues. Thanks in advance for your cooperation in connection with this matter. Sincerely, /s/ Henry F. Schlueter cc: BeLive Holdings R.F. Lafferty & Co., Inc. Lucosky Brookman LLP Onestop Assurance PAC

In response to the Commission’s comment, the Company respectfully refers the Staff to the revised “Executive Compensation” section, which now includes executive compensation for the fiscal year ended December 31, 2024. 2 Exhibits Exhibit Number 5.1, page II-4

In response to Comment #5, we have added additional disclosure reflecting information required by Item 11 of Form S-1 to be given as of December 31, 2024 and so cannot be incorporated by reference from prior filings. If you require any further information or have additional questions, please contact me at (818) 613-0151 or our counsel, Carol W. Sherman of Kelley Drye & Warren LLP, at (212) 808-5038. Sincerely, /s/ Faith Zaslavsky Faith Zaslavsky Chief Executive Officer cc: Carol W. Sherman

We note the Staff’s comment, and in response hereto, respectfully advise the Staff that we have removed “the table below” to avoid confusion and have updated the executive compensation disclosure for the most recently completed fiscal year. Consolidated Financial Statements, page F-1

We respectfully advise the staff that we have revised the disclosure to include the executive compensation for fiscal year ending 2024. We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal. Sincerely, /s/ Darren Hoo Wei Sern Darren Hoo Wei Sern Chairman

The Company acknowledges the Staff’s comments and has updated the Executive and Director Compensation section to include information as of December 31, 2024. Exhibits

In response to the Staff’s comment, the Company has revised the Form S-4 to include executive compensation disclosures for fiscal year 2024.

In response to the Staff’s comment, the Company updated its executive compensation disclosure for the fiscal year ended 2024. Please call me at (212) 407-4000 if you would like additional information with respect to any of the foregoing. Thank you. Sincerely, /s/ Xiaoqin ("Sherry") Li Xiaoqin ("Sherry") Li Senior Counsel

The Company acknowledges the Staff’s comment and respectfully submits that the Company has revised its disclosure on page 96 of the Post-Effective Amendment No. 2 to Form F-1. General

In response to the Staff’s comment, we have updated the executive compensation for the year ended December 31, 2024. Index to Consolidated Financial Statements, page F-1

In response to the Staff’s comment, the Company has revised its disclosure on page 208 of the Amended Registration Statement to provide compensation disclosure for Heidmar for 2024 and has updated disclosures about Heidmar’s business in the section entitled “Information About Heidmar.” If you have any questions or comments concerning the enclosed, please feel free to contact the undersigned at (212) 574-1275 (billotti@sewkis.com) or Holt Goddard at (212) 574-1250 (goddard@sewkis.com). Sincerely, /s/ Keith J. Billotti Keith J. Billotti 2

The Company has amended page 81 of the Amendment in response to the Staff’s comments. Exhibits and Financial Statement Schedules, page II-2

As the disclosure provides, each of the Adviser and Sub-Adviser considers ESG factors on a case-by-case basis, and only to the extent they are material to the investment case, as determined by the Adviser or Sub-Adviser, as applicable (see, e.g., the reference in the excerpted statement above to “may consider” and “depending on the facts and circumstances.”) We believe the above referenced disclosure is sufficiently clear on this point and respectfully decline to expand the disclosure as suggested. (b) Explain whether an investment could be made in a company that scores poorly on ESG if it scores strongly on other non-ESG factors.

The Company acknowledges the Staff’s comment and has revised the disclosure on page 211 of the Registration Statement. 4 Management’s Discussion and Analysis, page 205

The Company intends to amend its form 10-K for the Fiscal Year Ended January 31, 2024 once it clears comments with the Commission for its Registration Statement filed on Form S-1 (File No. 333-280762) such that the financial statement, footnotes and all disclosure will align in accordance with the Comments of the Staff. Form 8-K Filed October 8, 2024 Item 4.01 Changes in Registrant’s Certifying Accountant, page 1

The Company respectfully acknowledges the Staff’s comment and in the Company’s Annual Report on Form 10-K for the year ended December 31, 2024, as well as future filings, if applicable, the Company will provide a brief explanation as to why application of the Company’s recovery policy resulted in no recovery of erroneously awarded compensation in connection with the restatement of the Company’s financials on the 2023 Form 10-K. Please contact me at (415) 693-2177 with any questions or further comments regarding our responses to the Staff’s comments. Sincerely, /s/ David Peinsipp David Peinsipp cc: Susan Echard, WM Technology, Inc. Brian Camire, WM Technology, Inc. Kristin VanderPas, Cooley LLP Peter Byrne, Cooley LLP Cooley LLP 3 Embarcadero Center 20th Floor San Francisco, CA 94111-4004 t: +1 415 693 2000 f: +1 415 693 2222 cooley.com

We believe the analysis of material ESG issues as part of our fundamental research can help us understand long-term risks and opportunities of an investment. As indicated in the disclosure, “The investment adviser may consider environmental, social and governance (‘ESG’) factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument.” We believe the current disclosure is clear that ESG factors may be considered where such factors are material to the value of an investment. b. Explain whether an investment could be made in a company that scores poorly on ESG if it scores strongly on other non-ESG factors.

In response to the Staff’s comment, the Company has added the relevant disclosures on page 81 of the Amendment. General

The Company can confirm that the salary was accrued and unpaid, not waived. 1 Principal Shareholders, page 30

The Company respectfully acknowledges the Staff’s comment. The interactive data for the recovery analysis was inadvertently excluded. The Company agrees and has noted for future filings that the interactive data should be included for recovery analysis in accordance with Rule 405 of Regulation S-T. We hope the foregoing is responsive to your comment. Please do not hesitate to contact me by telephone at (850) 402-8450 with any questions or comments regarding this correspondence. Sincerely, /s/ Jeptha E. Larkin Jeptha E. Larkin, EVP and CFO of Capital City Bank Group, Inc.

In response to the Staff’s comment, the Company has revised the disclosure to provide disclosure of executive compensation paid for fiscal year ending June 30, 2024, on page 101. If you have any questions regarding this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com. Thank you again for your time and attention. Yours sincerely, /s/ Lan Lou Lan Lou Partner Jun He Law Offices LLC cc: Muchun Zhu, Chairman of the Board and Chief Executive Officer, Intercont (Cayman) Limited Michael Burke, Partner, UHY LLP Jason Ye, Ortoli Rosenstadt LLP

The Amended Registration Statement has been revised in accordance with the comments of the Staff on page F-13. U.S. Securities and Exchange Commission Division of Corporation Finance September 18, 2024 Page 7 Note 10 - Subsequent Events, page F-20

We confirm that in future filings our Definitive Proxy Statement on Schedule 14A will (i) include disclosure that the Company is using non-GAAP diluted EPS as its Company-Selected Measure pursuant to Item 402(v)(2)(vi) of Regulation S-K and disclose with sufficient detail and clarity how such measure is calculated from our audited financial statements, and (ii) ensure that the amount disclosed in the Company-Selected Measure column of our pay versus performance table for each covered fiscal year will be calculated using the Company-Selected Measure as that used for the most recently completed fiscal year.

In the Peer Group Total Shareholder Return column of the pay versus performance table, the Company references the health care REITs in the FTSE NAREIT All Equity REITs Index (the “Index”). Health care REITs are a component of the Index that is separately identified by the producer of the Index, FTSE Russell. The same group of companies is listed as the peer group on page 24 of the Proxy Statement for disclosures pursuant to Item 402(b) of Regulation S-K. In future filings, the Company will separately identify each company in the calculation of the Peer Group Total Shareholder Return column of the pay versus performance table by cross reference to the peer group disclosures pursuant to Item 402(b) of Regulation S-K. We will also include the Company’s results in the cumulative return for the peer group in the pay versus performance table. Comment:

We believe the analysis of material ESG issues as part of our fundamental research can help us understand long-term risks and opportunities of an investment. As indicated in the disclosure, “The investment adviser may consider environmental, social and governance (‘ESG’) factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument.” We believe the current disclosure is clear that ESG factors may be considered where such factors are material to the value of an investment. b. Explain whether an investment could be made in a company that scores poorly on ESG if it scores strongly on other non-ESG factors.

In response to the Staff’s comment, we have revised the disclosures on page 137 of the Registration Statement. Related Party Transactions, page 140

We note the Staff’s comment and have included the executive compensation information for the year ended June 30, 2024 on page 136. Related Party Transactions, page 140

In response to the Staff’s comment, the Company respectfully advises the Staff that it has revised the executive compensation table to reflect the fiscal year ended March 31, 2024, on page 48 of the Amendment, as requested by the Staff. Executive Compensation, page 49

In response to the Staff’s comment, the Company has revised the disclosure on page 82 of the Amended Form S-1. Additionally, the Company confirms that it has not entered into a definitive employment agreement with Mr. Pang. Exhibits

We have revised the Amended S-1 to include executive compensation information for the fiscal year ended April 30, 2024, the most recently completed fiscal year, in accordance with Item 402 of Regulation S-K and C&DI 217.11 (Regulation S-K). Please see the section, “Executive Compensation”, which starts on page 15 of the Amended S-1. * * * Should you have any questions regarding the foregoing, please do not hesitate to contact the undersigned at (844) 722-6333 or our General Counsel, Henry Nisser at (646) 650-5044. Very truly yours, /s/ Stephan Jackman Stephan Jackman Chief Executive Officer

In response to this comment, the Company advises the Staff that it has updated the section titled Executive Compensation in accordance with the Staff’s request. Certain Relationships and Related Party Transactions, page 39

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has amended its disclosure on pages 192 and 194 of the Registration Statement to remove the reference to Digital Ally’s Annual Report on Form 10-K filed on March 31, 2023. Kustom Entertainment Financial Statements Note 1. Nature of Business and Summary of Significant Accounting Policies Nature of Operations, page F-32

The Company respectfully acknowledges and has complied with the Staff’s comment by revising the Registration Statement in Amendment No. 1 to include updated executive compensation disclosure for Ceapro for the fiscal year ended December 31, 2023 under the heading “Information Concerning Ceapro—Executive Compensation Statement” beginning on page 110 of Amendment No. 1. The Company has also included updated executive compensation disclosure for the Company in its Annual Report on Form 20-F for the year ended December 31, 2023 (the “ Form 20-F ”) filed with the Commission on March 27, 2024, which is incorporated by reference into the Registration Statement in Amendment No. 1. See Part I, Item 6.B “Directors, Senior Management and Employees—Compensation” beginning on page 74 of the Form 20-F. See also the second, third and fourth paragraphs under the heading “About This Prospectus” on page…

The Registrant acknowledges the Staff’s comment and has added disclosure on page 182 of Amendment No. 2. Principal and Selling Shareholders, page 202

The Company acknowledges the Staff’s comment and has provided the requested disclosure on page 158 of the Amended Registration Statement. Information About Abpro Overview, page 165

The Company acknowledges the Staff’s comment and respectfully advises the Staff that disclosure with respect to Arvind Nithrakashyap is not required in the section of the Registration Statement titled “Executive Compensation” pursuant to Item 402 of Regulation S-K. Due to the Company’s qualification as an “emerging growth company,” as defined in Rule 405 under the Securities Act of 1933, as amended, the Company may rely on paragraphs (l) and (m) of Item 402 of Regulation S-K to provide scaled compensation disclosure for the last completed fiscal year for the Company’s principal executive officer and the Company’s two other most highly compensated executive officers serving at the end of the last completed fiscal year. For the fiscal year ended January 31, 2024, the Company’s last completed fiscal year, Mr. Nithrakashyap was not one of the two most highly compensated executive officers,…

We have amended the Executive Compensation section to reflect the compensation paid to Jeff Kim for the fiscal year ended February 29, 2024, since Saeb Jannoun, the former President, resigned on March 22, 2023. Experts, page 58 Eranga Dias, Esq. March 25, 2024 Page 2 of 2

The Company has revised the offering circular to reflect the compensation paid to officers of Terra Mint who rendered services to the Company. The Company has added disclosure regarding the sourcing fees earned to date by Terra Mint. No asset management fees, property management fees, or sourcing fees were paid to Terra Mint as of December 31, 2023. Security Ownership of Management and Certain Security Holders, page 52

Executive has been updated to include fiscal year 2023 for Rhonda Keaveney. Certain Relationships and Related Transactions, page 48

In response to the Staff’s comment, the Company has revised page 132 of Amendment No. 1. * * * 55 Hudson Yards, New York, New York 10001-2157 t: +1 212 479 6000 f: +1 212 479 6275 cooley.com If you have any questions regarding the response letter, please contact the undersigned by phone at +852-3758-1210 or via e-mail at wcai@cooley.com. Very truly yours, /s/ Will H. Cai Will H. Cai cc: Mark S. Shearman, Chief Executive Officer, APRINOIA Therapeutics Inc. Brian Achenbach, Chief Financial Officer, APRINOIA Therapeutics Inc. Lana Gladstein, General Counsel, APRINOIA Therapeutics Inc. Timothy Pitrelli, Esq., Cooley LLP Reid S. Hooper, Esq., Cooley LLP Leah Gonzales, Audit Partner, MaloneBailey, LLP Michael J. Blankenship, Winston & Strawn LLP

In response to the Staff’s comment, we have revised the registration statement to include the executive compensation disclosures required for the fiscal year ended December 31, 2023. Selling Stockholders, page 92

We have revised the executive compensation disclosure for the fiscal year ended December 31, 2023 in accordance with Item 402 of Regulation S-K. Narrative Disclosure to Compensation Summary Table, page 198 41. Staff’s