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         SKADDEN, ARPS, SLATE, MEAGHER & FLOM (SINGAPORE)
                          LLP                       AFFILIATE OFFICES

                             6 BATTERY ROAD, SUITE 23-02
                     BOSTON

                    CHICAGO
                                  SINGAPORE 049909

                    HOUSTON
                                        ____
                  LOS ANGELES

                   NEW YORK
                                    TEL: (65) 6434-2900
                   PALO ALTO
                                    FAX: (65) 6434-2988
                WASHINGTON, D.C.
                                     www.skadden.com
                  WILMINGTON

                     BEIJING

                   BRUSSELS

                  FRANKFURT

                     LONDON

                    MOSCOW

                     MUNICH

                      PARIS

                   S  O PAULO

                      SEOUL

                   SHANGHAI

                   SINGAPORE

                      TOKYO

                    TORONTO

January 29, 2021

Confidential
Ms. Kathryn Jacobsen
Mr. Edwin Kim
Mr. Robert Littlepage
Ms. Jan Woo
Division of Corporation Finance
Office of Technology
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re: TDCX (KY) PTE LTD
Response to the Staff   s Comments dated March 12, 2020 on the Draft
Registration Statement Submitted
February 14, 2020
CIK No. 0001803112

Dear Ms. Jacobsen, Mr. Edwin Kim, Mr. Littlepage and Ms. Woo:

      On behalf of our client, TDCX (KY) PTE LTD, a company organized under the
laws of the Cayman Islands
(the    Company   ), we submit to the staff (the    Staff   ) of the Securities
and Exchange Commission (the
   Commission   ) this letter setting forth the Company   s responses to the
comments contained in the Staff   s letter
dated March 12, 2020 on the Company   s draft registration statement on Form
F-1 confidentially submitted on
February 14, 2020 (the    Draft Registration Statement   ).

      Concurrently with the submission of this letter, the Company is
submitting its revised draft registration
statement on Form F-1 (the    Revised Draft Registration Statement   ) and
certain exhibits via EDGAR to the
Commission for confidential review pursuant to the Jumpstart Our Business
Startups Act (the    JOBS Act   ). The
Company confirms that it will include its audited financial statements for the
year ended December 31, 2020 in a
 subsequent filing. In addition to adding and revising disclosure in response
to the Staff   s comments, the Company
has updated the Revised Draft Registration Statement to remove its audited
consolidated financial statements for the
year ended December 31, 2017 and include its audited consolidated financial
statements for the year ended
December 31, 2019 and related financial information.
                                                          1

     To facilitate your review, we have separately delivered to you today four
courtesy copies of the Revised Draft
Registration Statement, marked to show changes to the Draft Registration
Statement, and four copies of the
submitted exhibits.

      The Staff   s comments are repeated below in italics and are followed by
the Company   s responses. We have
included page references in the Revised Draft Registration Statement where the
language addressing a particular
comment appears. Capitalized terms used but not otherwise defined herein have
the meanings set forth in the
Revised Draft Registration Statement.

Draft Registration Statement on Form F-1 submitted February 14, 2020
Prospectus Summary, page 1
1.   You refer to your leading clients such as Facebook and Airbnb on page 3 of
your prospectus summary. In light
     of the risk factor on page 19 and the concentration of your business
related to Facebook and Airbnb, please
     disclose here that 52.1% of your revenue in fiscal year 2018 is derived
from these two clients.
      In response to the Staff   s comment, the Company has revised the
disclosure on pages 3 and 118 of the Revised
      Draft Registration Statement.
2.   On page 2, you reference that more than half of your employees are
tertiary school graduates, including
     employees with master   s degrees and/or doctorates.    Please clarify
what you mean by tertiary school
     graduates, as that term may differ as to region. For example, please
clarify whether over half of your
     employees are graduate school graduates with advanced college or
university degrees. Further, please clarify
     if the tertiary school graduates are concentrated in certain markets.
      In response to the Staff   s comment, the Company has revised the
disclosure on pages 2, 117 and 133 of the
      Revised Draft Registration Statement. The Company further notes that, for
each of its offices, over half of our
      employees are college or university graduates (i.e. post high school),
including employees with master   s
      and/or doctorate degrees.
3.   You reference deepening your relationships with your existing clients is
part of your growth strategy and that
     as you expand your services throughout your clients    businesses and
processes, that it encourages client
        stickiness    and discourages clients from turning to other providers.
We further note per page 19, however,
     that you are not exclusive providers to your clients generally. Please
explain how you measure client retention
     and advise us whether such measures would be considered key performance
indicators.
      The Company respectfully submits that exclusive arrangements with clients
in its industry are not standard
      practice due to clients    own desires to mitigate their reliance on any
single third-party vendor. The Company
      believes, however, that as it expands and deepens its relationship,
service offerings and touch points with a
      client,    stickiness    with, and loyalty from, that client increases
because, among other things, the client will
      consider favorably the convenience and efficiency afforded by obtaining
the services from the Company,
      consider the benefits it derives from obtaining a wider range of services
from the Company, and have a deeper
      engagement with the Company, which allows the Company more opportunities
to demonstrate its value to
      them, even though the Company would not be an exclusive provider to the
client.
      The Company measures client retention on an annual basis based on
percentage of clients who remain active
      clients in any period compared to any previous period. The Company does
not believe that this measure is a
      key performance indicator because the Company has decided to focus on
attracting clients by providing
      solutions that attract a mix of new economy clients as well as
traditional clients undergoing digital
      transformation rather than focus solely on other traditional clients to
whom it historically provided services.
                                                          2

4.   You reference fixed price contracts based on statements of work as part of
master service agreements with your
     clients. It appears that these agreements are generally 12 month
agreements that are renewable on a yearly
     basis. Please clarify whether the prices paid for services are revised on
a yearly basis to reflect changes in
     market conditions for your respective labor markets.
      The Company respectfully submits that while the master service agreements
are generally for 12-month terms,
      the client may or may not, depending on the terms of the agreements, have
the right to extend the term and/or
      revise the pricing from the original 12-month term. Accordingly, prices
paid for services are not always
      revised on a yearly basis and, depending on the agreement, the Company
may not be able to re-
      negotiate pricing terms after any primary or renewal term.
      The Company has revised the disclosure on page 20 of the Revised Draft
Registration Statement accordingly.

Management   s Discussion and Analysis of Financial Condition and Results of
Operations Non-IFRS Financial
Measurements, page 76
5.   Please revise the caption for the Debt/EBITDA ratio to indicate that Debt
includes only Bank Loans. Refer to
     Item 10(e)(ii)(E) of Regulation S-K.
      The Company respectfully submits that Debt was defined as bank loans and
Debt/EBITDA ratio as bank loans
      divided by EBITDA on page 76 of the Draft Registration Statement and is
defined on pages 16, 66, 80 and
      121 of the Revised Draft Registration Statement.
6.   Please disclose here, and elsewhere as applicable, that EBITDA and EBITDA
margin may not be comparable
     to similarly titled measures since your calculation of EBITDA includes
depreciation on the right-of-use assets
     and finance costs on lease liabilities following your early adoption of
IFRS 16.

      In response to the Staff   s comment, the Company has revised the
disclosure on pages 16, 66, 80 and 121 of the
      Revised Draft Registration Statement.
                                                         3

History and Corporate Structure, page 85
7.   You provide a chart of your expected corporate structure as the date of
the prospectus following your
     reorganization, which you have not yet completed. Please briefly describe
the current corporate structure of
     your future subsidiaries and operations and the steps necessary to
complete your reorganization.
      The Company respectfully submits that the reorganization has been
completed on December 16, 2020 and that
      the corporate structure included on pages 7 and 90 of the Revised Draft
Registration Statement reflects the
      current corporate structure of the Company.

Industry Overview, page 87
8.   Please clarify the relevance of the market and industry data to your
business, particularly as it relates to
     geographic regions. For example, you provide certain market data based on
delivery locations, but with the
     markets served including all major global end markets. On the other hand,
on page 71 you refer to the
     Southeast Asia, Global English and Europe end-markets. In order to
understand how the data relates to your
     business, please clarify how market data on delivery markets relates to
your end-markets. For example, clarify
     the extent to which your clients, their customers, and your employees are
located in particular regions such as
     Southeast Asia and the extent to which your revenues are attributable to
those regions.
      The Company respectfully submits that many of the outsourced business
services providers, including the
      Company, have global operations with delivery locations around the world
and serve clients and our clients
      customers that are located both in the same country as the delivery
location (onshore) and in countries
      different from the delivery location (offshore). Therefore, market sizing
has been conducted by segmenting
       revenue based on the delivery location, which includes both onshore and
offshore data. For instance,
      Southeast Asia market revenue represents the service providers
earnings associated with customer
      interactions that are delivered from their delivery locations in
Southeast Asia, regardless of where the
      customers are physically located. Revenue includes fulfillment models
such as onshore, offshore, home-agent,
      automated and technology-enabled solutions. As a popular offshore
destination, Southeast Asia delivery
      centers cater to offshore North American, European and Australian markets
as well as onshore domestic
      markets.
9.   We note that the Frost & Sullivan report that you commissioned contains
various CAGR projections through
     2024. Please provide more details of how these projections were
determined, including any material
     assumptions.
      In response to the Staff   s comment, the Company has attached the
requested material in Exhibit A.

                                                          4

EBITDA Margins, page 103
10. Please tell us if you believe the EBITDA margins of your peers are
calculated on a comparable basis. In this
    regard, we note that your calculation of EBITDA includes depreciation on
right-of-use assets and finance costs
    on lease liabilities following your early adoption of IFRS 16.
      The Company respectfully advises the Staff that it has implemented an
early adoption of IFRS 16 and
      presented its financial statements consistently for each of the fiscal
years 2018 and 2019.
      Based on the Company   s review of the financial disclosure of its peers
that report under IFRS and as
      summarized below, the Company is not aware of any of its peers similarly
implementing an early adoption of
      IFRS 16 prior to fiscal year 2019. As such, EBITDA margins of its peers
reporting under IFRS may not be
      calculated on a comparable basis for 2018. However, the Company
respectfully submits that it believes that
      EBITDA margins for the majority of its peers that report under IFRS 16
have included depreciation on right-
      of-use assets and finance costs on lease liabilities and are calculated
on a comparable basis for 2019.
      Additionally, as it relates to the Company   s peers that report under US
GAAP, the Company respectfully
      advises the Staff that it has considered the joint meeting held between
the Centre for Audit Quality (CAQ)
      SEC Regulations Committee and the Staff on March 20, 2019 where committee
members observed an
      EBITDA measure presented after the adoption of ASC 842 under U.S. GAAP
may no longer be comparable to
      the same measure presented by an IFRS filer after the adoption of IFRS
16. Specifically, the Company
      understands that under ASC 842, the reduction in the right of use asset
relating to operating leases is recorded
      as part of lease expense rather than depreciation. As a result, EBITDA
margins of the Company   s peers
      adopting Topic 842 may also not be calculated on a comparable basis.
      As noted in our response to the Staff   s comment No. 6, the Company has
revised the disclosure on pages 16,
      66, 80 and 121 of the Revised Draft Registration Statement to clarify the
foregoing.
      The table below provides summary information on the Company and its
peers, each   s accounting standard and
      whether they have adopted the relevant new lease accounting standard.

                                                                     New Lease
Accounting Standard

Adopted?

                  Accounting
         Peers                                                FY2018    FY2019
      FY2020       Standard
         TDCX                                                 IFRS16
IFRS16                     IFRS
         Teleperformance
IFRS16                     IFRS
         Genpact                                                          Topic
842                   GAAP
         Concentrix
                        GAAP
         TTEC                                                             Topic
842                   GAAP
         EXLService                                                       Topic
842                   GAAP
         WNS
           IFRS16        IFRS
         Accenture
         Topic 842      GAAP
         Cognizant                                                        Topic
842                   GAAP
          Capgemini
IFRS16                     IFRS
         EPAM
Topic 842                   GAAP
         Globant
IFRS16                     IFRS
         Endava
IFRS16       IFRS16        IFRS
      In addition, the Company also respectfully advises the Staff that the
charts used for comparison analyses of
      (i) its EBITDA margins and (ii) its EBITDA per average employee