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CORRESP
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Morgan,
Lewis & Bockius

c/o
19th Floor,

Edinburgh
Tower, The Landmark

15
Queen’s Road Central, Hong Kong

Direct:
+852.3551.8500

Fax:
+852.3006.4346

www.morganlewis.com

WRITER’S
DIRECT LINE

+852.3551.8688

WRITER’S
EMAIL

louise.liu@morganlewis.com

 January
14, 2025

Confidential

Ms.
Chen Chen

Mr.
Chris Dietz

Mr.
Matthew Crispino

Mr.
Larry Spirgel

Division
of Corporation Finance

Office
of Technology

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Knorex
    Ltd. (CIK No. 0001982960)

    Registration
    Statement on Form F-1

Dear
Ms. Chen, Mr. Dietz, Mr. Crispino, and Mr. Spirgel:

On
behalf of our client, Knorex Ltd., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
we submit to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated November 18, 2024
on the Company’s registration statement on Form F-1 (the “Registration Statement”) initially filed on November
12, 2024 (the “Initial Filing Date”).

Concurrently
with the submission of this letter, the Company is filing herewith amendment No. 1 (“Amendment No. 1”) to the Registration
Statement and certain exhibits via EDGAR to the Commission. The Staff’s comments are repeated below in bold and are followed by
the Company’s responses. We have included page references in the Amendment No. 1 where the language addressing a particular comment
appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No. 1.

    Partners:

    Edwin
    Luk, June Chan, Connie Cheung, Keith Cheung*#,

    William
    Ho, David Liao, Charles Mo, Billy Wong, and Yan Zeng

    Registered
    Foreign Lawyers:

    Eli
    Gao (New York), Maurice Hoo (California),

    Alice
    Huang (California), Mathew Lewis (New York),

    Louise
    Liu (New York), Vivien Yu (New South Wales),

    and
    Ning Zhang (New York)

    *China-Appointed
    Attesting Officer

    #Notary Public of Hong Kong

    19th
    Floor, Edinburgh Tower

    The Landmark

    15 Queen’s Road Central

    Hong Kong

    +852.3551.8500

+852.3006.4346

     January
    14, 2025

    Page
    2

The
Company respectfully advises the Staff that, subject to market conditions, it plans to launch the road show for the proposed offering
as soon as possible but not earlier than 15 days after the Initial Filing Date. The Company would appreciate the Staff’s timely
assistance and support to the Company in meeting the proposed timetable for the offering.

Unaudited
Condensed Consolidated Financial Statements of Knorex Ltd.

Notes
to Unaudited Condensed Consolidated Financial Statements

Note
17 - Subsequent events, page F-29

    1.
    Please
    revise your disclosures here and on page F-54 to address the issuance of warrants on September 30, 2024 as discussed on page 41.
    As part of your response, please tell us whether the warrants were issued in connection with the issuance of debt. In this regard,
    we note that your disclosure on page 41 refers to “an aggregate principal amount.” Lastly, if debt was issued, revise
    your capitalization and dilution disclosures to reflect the pro forma impact.

In response to the Staff’s comment, the Company has revised the relevant
disclosures on pages 38, 41 81, F-29 and F-54 of the Amendment No. 1 to avoid possible confusion and to clarify that no debt was issued.
The Company respectfully submits that the warrants issued by the Company on September 30, 2024 were in exchange for warrants previously
issued by Knorex SG pursuant to the Restructuring Agreement.

Audited
Consolidated Financial Statements of Knorex Ltd.

Report
of Independent Registered Public Accounting Firm, page F-30

    2.
    Please
    revise to include the signature of the accounting firm. Refer to Rule 2-02(a) of Regulation S-X.

In response to the Staff’s comment, the Company has revised disclosure
on page F-30 of the Amendment No. 1.

If
you have any questions regarding the Amendment No. 1, please contact the undersigned by phone at +852.3551.8688 or via e-mail at louise.liu@morganlewis.com.

    Very
    truly yours

    By:

    /s/
    Louise L. Liu

    Louise
    L. Liu

    Partner

    cc:
    Khar
    Heng Choo, Director and Chief Executive Officer, KNOREX LTD.

    Joan
    Wu, Esq., Hunter Taubman Fischer & Li LLC