December 12, 2024

VIA EDGAR AND OVERNIGHT DELIVERY

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

On behalf of Gary R. Garrabrant (the “Reporting Person”), we are submitting this letter in response to the comment of the staff of the Division of Corporate Finance (the “Staff’) of the Securities and Exchange Commission (the “Commission”), conveyed by letter dated December 3, 2024 (the “Comment Letter”), with respect to the above-referenced Schedule 13D (the “Schedule 13D”).

For the convenience of the Staff, the numbering of the paragraph below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated into this response letter in italicized type and which is followed by our responses on the Reporting Person’s behalf.

General

Response: The Schedule 13D was not timely filed under Rule 13d-1(a) of Regulation 13D-G due to an oversight on the part of the Reporting Person. The oversight was the result of numerous factors, including, but not limited to, the time commitments imposed by serving as an executive officer of Captivision Inc. (the “Company”), which has an extremely small managerial staff and ongoing publicly disclosed liquidity issues. Upon the Reporting Person becoming aware of the oversight, he caused the Schedule 13D to be promptly filed. The failure to meet the deadline was not deliberate on the part of the Reporting Person, and the Reporting Person does not believe he gained any advantage as a result of the filing of the Schedule 13D past the deadline, particularly as the information required by the Schedule 13D filing was otherwise disclosed in the Company’s public filings, including on the Beneficial Ownership of Securities section of the Registration Statement on Form F-1 filed on June 18, 2024 (File No. 333-280297). The Reporting Person respectfully advises the Staff that future filings with respect to his beneficial ownership in the Company will be timely made in accordance with Rule 13d-1(a) of Regulation 13D-G.

Response: The Reporting Person respectfully advises the Staff that the Reporting Person disclosed his beneficial ownership over the ordinary shares of the Company reported in the Schedule 13D (the “Ordinary Shares”) in the Schedule 13D filed jointly with Jaguar Global Growth Partners I, LLC (“JGG”) on January 2, 2024 (File No. 005-94238) (the “JGG Schedule 13D”). Pursuant to the JGG Schedule 13D, the Reporting Person disclosed his shared voting power and shared dispositive power in the Ordinary Shares by virtue of his position as the managing member of JGG SPAC Holdings LLC, which was the managing member of JGG.

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We hope the foregoing answer is responsive to your comment. Please do not hesitate to contact the undersigned at (713) 860-7352 (willburns@paulhastings.com) of this firm with any questions or comments regarding this correspondence.