[RW] International Land Alliance Inc. SEC Filing

December 18, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street NE

Washington, D.C. 20549

Re: International Land Alliance, Inc. Request to Withdraw Registration Statement on Form S-1 Filed January 10, 2025 File No. 333-284194

Ladies and Gentlemen:

International Land Alliance, Inc. (the “Company”) respectfully requests, pursuant to Rule 477(a) under the Securities Act of 1933, as amended (the “Act”), the immediate withdrawal of its Registration Statement on Form S-1 (File No. 333-284194), filed with the Securities and Exchange Commission (the “Commission”) on January 10, 2025, together with all exhibits thereto (collectively, the “Registration Statement”).

The Company has determined to withdraw the Registration Statement as it no longer plans to consummate the offering described in the Registration Statement. The Registration Statement has not been declared effective by the Commission and the Company confirms that no securities have been sold pursuant to the Registration Statement. Therefore, withdrawal of the Registration Statement is consistent with the public interest and the protection of investors as contemplated by Rule 477(a).

The Company also requests that, in accordance with Rule 457(p) of the Act, all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.

If you have any questions or require further information regarding this application for withdrawal, please do not hesitate to contact the Company’s legal counsel, Scott Linsky of Lucosky Brookman LLP at (732) 395-4408.

Very truly yours,

/s/ Jason Sunstein

Jason Sunstein

Chief Financial Officer and Director

International Land Alliance, Inc.

cc: Scott Linsky, Lucosky Brookman LLP