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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:

We
are filing this letter in order to provide the staff of the of the Securities and Exchange Commission sufficient time to perform its
customary screening and review of registration statements prior to their effectiveness.

Pursuant
to Rule 473(c) of the Securities Act of 1933 (the “Act”), the following delaying amendment, prescribed by Rule 473(a) of
the Act, is hereby incorporated into the facing page of the Registration Statement on Form F-1 (File No. 333-267771) filed by SAG Holdings
Limited on August 21, 2024:

“The
registrant hereby amends this registration statement on such date or dates as may be necessary to delay its effective date until the
registrant shall file a further amendment which specifically states that this registration statement shall thereafter become effective
in accordance with Section 8(a) of the Securities Act of 1933 or until the registration statement shall become effective on such date
as the Commission acting pursuant to said Section 8(a), may determine.”

If
you have any questions regarding this letter, 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