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August 29, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed August 14, 2023
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, 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 comment applies 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 this comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 28, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1
General
1.We note the changes you made to your disclosure appearing on the prospectus cover page,
Prospectus Summary and Risk Factor sections relating to legal and operational risks
associated with PRC laws and regulations and how they apply in Hong Kong.  It is unclear
to us that there have been changes in the regulatory environment in Hong Kong and the
PRC since the amendment that was filed on July 19, 2023, warranting revised disclosure
to mitigate the challenges you face and related disclosures. The Sample Letters to China-
Based Companies sought specific disclosure relating to the risk that the PRC government
may intervene in or influence your operations at any time, or may exert control over

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 August 29, 2023 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
August 29, 2023
Page 2
operations of your business, which could result in a material change in your operations
and/or the value of the securities you are registering for sale. We remind you that,
pursuant to federal securities rules, the term “control” (including the terms “controlling,”
“controlled by,” and “under common control with”) as defined in Securities Act Rule 405
means “the possession, direct or indirect, of the power to direct or cause the direction of
the management and policies of a person, whether through the ownership of voting
securities, by contract, or otherwise.”  The Sample Letters also sought specific disclosures
relating to uncertainties regarding the enforcement of laws and that the rules and
regulations in China can change quickly with little advance notice.  We do not believe that
your revised disclosure removing references to the PRC government conveys the same
risks.  Please restore your disclosures in these areas to the disclosures as they existed in
the registration statement as of July 19, 2023.
            You may contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336
if you have questions regarding comments on the financial statements and related
matters.  Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-
3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou