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January 12, 2024
Foo Chee Weng Desmond
Director, Chairman and Chief Executive Officer
Desfran Holdings Ltd
c/o 3 Shenton Way,
Shenton House, #23-01
Singapore 068805
Re:Desfran Holdings Ltd
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted December 26, 2023
CIK No. 0001982961
Dear Foo Chee Weng Desmond:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Draft Registration Statement on Form F-1
Cover Page
1.We note your disclosure on the prospectus cover page that you will be a "controlled
company" following the offering.  If true, please revise to disclose that Mr. Foo Chee
Weng Desmond will also have the ability to determine all matters requiring approval by
stockholders.

 FirstName LastNameFoo Chee Weng Desmond
 Comapany NameDesfran Holdings Ltd
 January 12, 2024 Page 2
 FirstName LastName
Foo Chee Weng Desmond
Desfran Holdings Ltd
January 12, 2024
Page 2
Consolidated Statements of Cash Flows, page F-8
2.We note your response to prior comment 17. Cash collected from customers by your
shareholder on your behalf appears to be a noncash transaction that does not represent
cash receipts or cash payments.  Please tell us why it is appropriate to reflect the noncash
items in your statement of cash flows. Refer to ASC 230.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition
License Application, page F-13
3.We note the disclosure you revised in response to our prior comment 18. However, it is
still not clear the nature and terms of the series of tasks which are distinct and separately
identifiable in your license application projects. Tell us what those tasks are and provide
an analysis of how those tasks are not separate performance obligations. Refer to ASC
606-10-25-14 through 25-22.
4.Please expand your disclosure to provide the information required by ASC 606-10-50-12
for the performance obligations for your license application contracts. Please also describe
the milestones on which you measure your output progress, how you determine the
achievement of the milestones, how the amount of revenues recognized for each milestone
are measured, and explain why the output method measured by milestones achieved
provides a faithful depiction of the transfer of services. Refer to ASC 606-10-50-18.
            Please contact Keira Nakada at 202-551-3659 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brian Fetterolf at 202-551-6613 or Donald Field at 202-551-3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Mathew Lewis