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CORRESP
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SAG
Holdings Limited

14
Ang Mo Kio Street 63

Singapore
569116

March
29, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Mr. Thomas Jones

    Re:

    SAG
                                            Holdings Limited

    Request
    for Acceleration

    Registration
    Statement on Form F-1 (as amended)

    File
    No. 333-267771

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), SAG Holdings Limited, a Cayman
Islands company (the “Company”), respectfully requests that the effective date of its Registration Statement on Form F-1
(File No. 333-267771) (the “Registration Statement”), be accelerated so that it will become effective at 4:30 p.m., Eastern
Time, on April 1, 2024, or as soon thereafter as possible.

In
making this acceleration request, the Company acknowledges that:

    (i)
    should
    the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare
    the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
    Statement;

    (ii)
    the
    action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

    (iii)
    the
    Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement
    as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Once
the Registration Statement is effective, please orally confirm the event with our counsel, TroyGould PC by calling David Ficksman at
(310) 789-1290 or Joilene Wood at (415) 305-4651. We also respectfully request that a copy of the written order from the Commission verifying
the effective time and date of the Registration Statement be sent to our counsel, TroyGould PC, Attention: David Ficksman, by facsimile
to (310)789-1290 or email at dficksman@troygould.com.

If
you have any questions regarding this request, please contact David Ficksman at (310) 789-1290.

    Very
    truly yours,

    By:
    /s/
    Chin Heng Neo

    Name:
    Chin
    Heng Neo

    Title:
    Chief
    Executive Officer

    cc:

    David
    Ficksman, TroyGould PC

    R.
    Joilene Wood, TroyGould PC