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CORRESP
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SAG
Holdings Limited

14
Ang Mo Kio Street 63

Singapore
569116

September
26, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Scott Anderegg

    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 (the
“Company”), a Cayman Islands company (the “Company”), respectfully requests that the effective date of its
Registration Statement on Form F-1 (File No. 333-281514) (the “Registration Statement”) be accelerated so that it will
become effective at 4:30 p.m., Eastern Time, on September 30, 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 Joilene Wood at (415)
305-4651 or David Ficksman at (310) 789-1290. 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: Joilene Wood, by email at
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