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CORRESP
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SAG
Holdings Limited

14
Ang Mo Kio Street 63

Singapore
569116

August
21, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Scott Anderegg

    Re:
    SAG
    Holdings Limited

    Amendment
    No. 19 to Registration Statement on Form F-1

    File
    No. 333-267771

Ladies
and Gentlemen:

SAG
Holdings Limited (the “Company”) has submitted the Company’s Amendment No. 19 to Registration Statement on Form F-1
today to respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter
dated August 20, 2024 with respect to the Company’s Registration Statement, as noted above. The text of the Staff’s comments
is set forth below, followed in each case by the Company’s responses.

Amendment
No. 18 to Registration Statement on Form F-1

General

    1.

    Please
    refer to the registration statement cover page. Please check the applicable check box on the cover page regarding the registration
    of securities pursuant to Rule 415 of the Securities Act of 1933.

We
have filed an amended cover page to check the applicable box regarding the registration of securities pursuant to Rule 415, along with
an explanatory note to clarify that no other amendments were made.

    2.

    Please
    refer to the Resale Prospectus Shareholders Plan of Distribution section on page Alt-3. We note your disclosure that the Resale Prospectus
    Shareholders may sell their Ordinary Shares through “purchases by a broker-dealer as principal and resale by the broker-dealer
    for its account” and that “any broker-dealers or agents that are involved in selling the Ordinary Shares may be deemed
    to be ‘underwriters’”. Please confirm your understanding that the retention by a Resale Prospectus Shareholder
    of an underwriter would constitute a material change to your plan of distribution requiring a post-effective amendment. Refer to
    your undertaking provided pursuant to Item 512(a)(1)(iii) of Regulation S-K.

We
confirm our understanding that the retention by a Resale Prospectus Shareholder of an underwriter would constitute a material change
to our plan of distribution requiring a post-effective amendment as provided pursuant to the undertakings we have set forth in Item 9
of Part II of the Registration Statement, which undertakings are made pursuant to Item 512(a)(1)(iii) of Regulation S-K.

If
you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com
or Joilene Wood at 415-305-4651 or jwood@troygould.com.

    Sincerely,

    SAG
    Holdings Limited

    /s/
    Jimmy Neo

    By:

    Jimmy
    Neo

    Chief
    Executive Officer & Executive Director

    cc:
    David
    L. Ficksman

    R.
    Joilene Wood