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November 29, 2022
Choon Pin Yeo
Chief Executive Officer
catTHIS Holdings Corp.
A-9-3, Northpoint Office, Mid Valley City, Lingkaran Syed Putra,
59200 Kuala Lumpur, Malaysia
Re:catTHIS Holdings Corp.
Amendment No. 2 to Registration Statement on Form S-1
Filed November 14, 2022
File No. 333-264963
Dear Choon Pin Yeo:
            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 August 26, 2022 letter.
Form S-1 filed November 14, 2022
Risk Factors
Malaysia is experiencing substantial inflationary pressures..., page 3
1.We note your risk factor indicating that inflation could affect your business, financial
condition, and results of operations. Please disclose whether inflationary pressures have
materially impacted you, and, if so, describe how your business has been affected.
Management’s Discussion and Analysis, page 9
2.We note your response to our prior comment 1. However, your disclosure still lacks detail
about how your operations generate, or will generate, revenue. Please describe how clients
pay for your catalogue management services; for example, disclose whether they pay a

 FirstName LastNameChoon Pin Yeo
 Comapany NamecatTHIS Holdings Corp.
 November 29, 2022 Page 2
 FirstName LastName
Choon Pin Yeo
catTHIS Holdings Corp.
November 29, 2022
Page 2
monthly subscription for access to your app or whether they pay a flat fee. Describe how
you intend to monetize your app users' data; for example, disclose whether you intend to
sell the data to third-party data brokers or whether you intend to sell targeted ads on your
app.
3.You disclose that part of your revenue from inception to December 31, 2021 was derived
from your "studio production services". Please describe what these services entail and
ensure that responsive disclosure appears where appropriate throughout your filing.
General
4.Please update your disclosure where needed. For example, on pages ii and 8, you identify
exhibitions "coming up" and "in the near future" that you will be attending. These
statements should be updated given that the dates of these exhibitions have passed.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Lauren Pierce, Staff
Attorney, at (202) 551-3887 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Jackson Morris