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                             October 4, 2023

       Roger James Hamilton
       Chief Executive Officer
       Genius Group Ltd
       8 Amoy Street, #01-01
       Singapore 049950

                                                        Re: Genius Group Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed September 25,
2023
                                                            File No. 333-273841

       Dear Roger James Hamilton:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our September 11,
2023 letter.

       Amendment No. 1 to Registration Statement on Form F-1 filed September
25, 2023

       General

   1.                                                   We note disclosure
throughout the prospectus (see, e.g., page S-122) that you intend to
                                                        spinoff your
subsidiary, Entrepreneur Resorts Ltd, by the end of September 2023 and then
                                                        list securities of
Entrepreneur Resorts Ltd on the Upstream platform.

                                                              Please tell us
the date when the spinoff occurred and update your disclosure
                                                            accordingly.

                                                              Please tell us
how you structured the spinoff to comply with the federal securities
                                                            laws. Please
provide us with a detailed legal and factual analysis. In doing so, please
                                                            explain to us
whether your believe the spinoff constituted a sale under Section 2(a)(3)
                                                            of the Securities
Act such that the spinoff would need to be either registered under
 Roger James Hamilton
Genius Group Ltd
October 4, 2023
Page 2
              Section 5 of the Securities Act or conducted pursuant to an
exemption from such
              registration. You may wish to refer to Staff Legal Bulletin No. 4
(September 16,
              1997) for guidance on the staff's views regarding whether Section
5 applies to a
              spinoff and related matters.

                Please tell us whether you anticipate Entrepreneur Resorts Ltd
needing to register any
              class of its securities under the Securities Exchange Act of
1934, as amended, and
              explain to us the basis for your view.
2.       We note your response dated September 25, 2023, in which you
represented that you
         expect to have completed the process to delist your securities from
the Upstream platform
         "on or about September 30, 2023." As of the date hereof, the Upstream
platform continues
         to disclose that it lists your common equity. Further, we do not see
any current reports on
         Form 6-K, company press releases or other public announcements
confirming the
         aforementioned delisting. As such, it appears your common equity is
still listed on the
         Upstream platform. Please tell us the status of your plans to delist
from the Upstream
         platform and update your disclosure accordingly. If your plans to
delist have changed,
         please note that the concerns articulated in our comment letter dated
September 11, 2023,
         would remain outstanding and, in such case, we would expect you to
address such
         concerns by responding to the comment letter.
       Please contact Kate Beukenkamp at 202-551-3861 or Dietrich King at
202-551-8071
with any questions.



FirstName LastNameRoger James Hamilton                        Sincerely,
Comapany NameGenius Group Ltd
                                                              Division of
Corporation Finance
October 4, 2023 Page 2                                        Office of Trade &
Services
FirstName LastName