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SEC Comment Letter for Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822) (CGTL) — Mar 30, 2026

Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822)
Date: March 30, 2026 · CIK: 0001967822 · Accession: 0000000000-26-003185

Regulatory Compliance Risk Disclosure Business Model Clarity

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
March 30, 2026
Author
Division of
Form
UPLOAD
Company
Creative Global Technology Holdings Ltd (CGTL) (CIK 0001967822)

Letter

Re: Creative Global Technology Holdings Ltd Form 20-F for Fiscal Year Ended September 30, 2025 File No. 1-42412 Dear Angel Siu:

March 30, 2026

Angel Siu Chief Executive Officer Creative Global Technology Holdings Ltd Unit 03, 22/F, Westin Centre 26 Hung To Road, Kwun Tong Kowloon, Hong Kong People s Republic of China

We have reviewed your filing and have the following comment(s).

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 20-F for Fiscal Year Ended September 30, 2025 General

1. Please revise future filings, as applicable, to provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. For additional guidance, please see the Division of Corporation Finance s Sample Letter to China-Based Companies issued by the Staff in December 2021 (the "CBI Sample Letter"). To the extent the CBI Sample Letter requests disclosure on the prospectus cover page or in the prospectus summary, please provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F; in addition, please include a discussion of the transfer of cash within the company in Item 5 of Form 20-F. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at 202-551-3651 if March 30, 2026 Page 2

you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at 202-551-7470 or Jason Drory at 202-551-8342 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Lan Lou

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 30, 2026

Angel Siu
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
People s Republic of China

 Re: Creative Global Technology Holdings Ltd
 Form 20-F for Fiscal Year Ended September 30, 2025
 File No. 1-42412
Dear Angel Siu:

 We have reviewed your filing and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for Fiscal Year Ended September 30, 2025
General

1. Please revise future filings, as applicable, to provide more specific
and prominent
 disclosures about the legal and operational risks associated with
China-based
 companies. For additional guidance, please see the Division of
Corporation Finance s
 Sample Letter to China-Based Companies issued by the Staff in December
2021 (the
 "CBI Sample Letter"). To the extent the CBI Sample Letter requests
disclosure on the
 prospectus cover page or in the prospectus summary, please provide such
disclosure in a
 separate section at the beginning of Item 3 of Form 20-F; in addition,
please include a
 discussion of the transfer of cash within the company in Item 5 of Form
20-F.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

 Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at
202-551-3651 if
 March 30, 2026
Page 2

you have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Jason Drory at 202-551-8342 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Lan Lou
</TEXT>
</DOCUMENT>