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April 3, 2024
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. 8 to Registration Statement on Form F-1
Filed March 22, 2024
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our January 26, 2024 letter.
Amendment No. 8 to Registration Statement on Form F-1 Filed March 22, 2024
Resale Prospectus, page Alt-1
1.We note the reduction of the primary offering from 2,000,000 Ordinary Shares to
1,250,000 Ordinary Shares. We also note that the Resale Prospectus accounts for
3,000,000 Ordinary Shares. As a result, with respect to the resale offering:
•Revise to delete references to the primary and secondary offerings being conducted
"concurrently," as it appears that the resale offering will begin only once your
Ordinary Shares are listed and the initial public offering is complete.
•Disclose any natural persons that control the selling shareholder and any position,
office, or other material relationship which the selling shareholder has had with the
registrant or any of its predecessors or affiliates within three years prior to the filing
of the registration statement. Refer to Item 507 of Regulation S-K.

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 April 3, 2024 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
April 3, 2024
Page 2
•Disclose in greater detail the circumstances under which the selling shareholder
received the shares covered by the resale offering, as well as how long the selling
shareholder has held such shares. Specifically, how long HSZ Holdings Limited held
the shares covered by the resale offering prior to transferring the shares to CHSZ
Holdings Limited.
•Advise why the resale offering is required to be registered at this time.
•Advise how you determined the number of Ordinary Shares being registered in
connection with the resale offering.
•Advise how the selling shareholder was selected to participate in this resale offering
and why the selling shareholder who is a greater than 5% shareholder has been
excluded from the lock-up.
•Lastly, advise why the resale offering should not be deemed an indirect primary
being conducted by or on behalf of the issuer. Refer to Question 612.09 of the
Securities Act Rules Compliance and Disclosure Interpretations.
            Please 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