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                             March 3, 2023

       Jayesh Chandan
       Chief Executive Officer
       Gorilla Technology Group Inc.
       7F, No.302, Ruey Kuang Road
       Neihu, Taipei 114720, Taiwan, R.O.C.

                                                        Re: Gorilla Technology
Group Inc.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed February 22,
2023
                                                            File No. 333-267838

       Dear Jayesh Chandan:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 1, 2022 letter.

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

       Risk Factors
       Changes to the current regulations and currency restrictions in Hong
Kong could materially and
       adversely affect Gorillas business ...., page 29

   1.                                                   We note your response
to prior comment 29 regarding your Hong Kong operations, sales
                                                        and regulatory risks.
You differentiate the regulatory environment in Hong Kong
                                                        for foreign-owned
entities operating in the People's Republic of China. Please expand
                                                        your discussion to
describe the more restrictive regulatory, liquidity, and enforcement
                                                        risks for foreign-owned
entities operating in China, and clarify that such rules and
                                                        regulations can change
quickly with little advance notice. Further, your risk factor should
                                                        highlight that the
Chinese government may intervene or influence your Hong Kong
 Jayesh Chandan
Gorilla Technology Group Inc.
March 3, 2023
Page 2
      operations in similar ways to how it regulates its mainland China
activities, and such
      actions may lead to negative consequences to your Hong Kong operations.
Contingent Value Rights, page 98

2.    We note your cross-reference    [f]or more information about the
milestones and conditions
      triggering each of these types of protections, see    The Business
Combination Agreement
      and Ancillary Agreements     Amended and Restated PIPE Subscription
Agreements.
      This disclosure does not appear in your Form F-1. Please clarify the
vesting/forfeiture
      formula for the ordinary shares underlying the Contingent Value Rights
for both Class A
      and B. In particular, please provide the following information:
          How you calculated the 1,137,577 forfeited amount of ordinary shares
for the 2022
           Price Protection formula for your stock price falling below $5 for
five consecutive
           days.
          How you calculated the 1,384,951 forfeited amount of ordinary shares
for the 2022
           Price Protection formula for your stock price as of December 31,
2022.
          Describe how the gross margins and filing requirements may impact
these
           calculations, and specify the 2021 gross margins threshold needed to
be surpassed in
           2022.
          Clarify if the illustrative example for the 2022 Revenue Protection
formula assumes
           December 31, 2022 revenue of $55 million.
          Provide an example where your 2022 Revenue Protection formula is
based on an
           estimated December 31, 2022 revenue of less than $51 million, unless
you are
           currently aware your fiscal year 2022 revenue will exceed $51
million.

       You may contact Edwin Kim, Staff Attorney, at (202) 551-3297 or Larry
Spirgel,
Office Chief, at (202) 551-3815 with any questions.



                                                            Sincerely,
FirstName LastNameJayesh Chandan
                                                            Division of
Corporation Finance
Comapany NameGorilla Technology Group Inc.
                                                            Office of
Technology
March 3, 2023 Page 2
cc:       David Bartz, Esq.
FirstName LastName