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March 6, 2024
Au Ho (Arthur) Chi
Chief Financial Officer
Wellchange Holdings Co Ltd
Unit E, 11/F, Billion Plaza 2, 10 Cheung Yue Street
Cheung ShaWan, Kowloon, Hong Kong
Re:Wellchange Holdings Co Ltd
Registration Statement on Form F-1
Filed February 8, 2024
File No: 333-276946
Dear Au Ho (Arthur) Chi:
            We have reviewed your amended registration statement and have the following
comments.
            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.
Form F-1 filed February 8, 2024
Our Customers, page 111
1.You disclosed that you had two customers that accounted for 32% of the company’s total
revenue for the six months ended June 30, 2023. Please disclose the material terms of any
agreements with these customers, including the identity, term and termination provisions
of any agreements.
Financial Statements - June 30, 2023 and 2022
Note 12. Shareholders' Equity, page F-52
2.We note on January 26, 2024 you implemented a 4,000-for-1 share split for ordinary
shares and that all per share amounts and numbers of ordinary shares have been
retrospectively adjusted. Please delete the reference to a "reverse" share split, as the 4,000-
for-1 split is not a reverse share split but a regular share split. Please also correct the
disclosure in Note 18 on page F-58 accordingly.

 FirstName LastNameAu Ho (Arthur) Chi
 Comapany NameWellchange Holdings Co Ltd
 March 6, 2024 Page 2
 FirstName LastName
Au Ho (Arthur) Chi
Wellchange Holdings Co Ltd
March 6, 2024
Page 2
Note 18. Subsequent Events, page F-58
3.We note that on February 7, 2024 you "proposed a 5-for-1 forward share split of ordinary
shares which was approved by existing shareholders and board of directors, pursuant to
which the Company is in the process of issuing additional shares." Please update your
disclosures to reflect the issuance and retrospective adjustment of per share and share
amounts in your next amendment, presuming that the issuance has occurred prior to your
next amended filing or expand the disclosure to explain the delay in the issuance of
shares.
Exhibit Index, page II-3
4.Please file an exhibit that includes the representations required by Instruction 2 to Item
8.A.4 of Form 20-F if you intend to comply with the 15-month requirement rather than the
12-month requirement for updating financial statements.
            Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Uwem Bassey at 202-551-3433 or Matthew Crispino at 202-551-3456 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yarona L. Yieh