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June 10, 2024

Via EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Uwem Bassey

    Matthew Crispino

    Claire DeLabar

    Robert Littlepage

    Re:
    Wellchange Holdings Co Ltd

    Amendment No 1 to Registration Statement on Form F-1

    Filed March 27, 2024

    File No. 333-276946

Ladies and Gentlemen:

This letter is being submitted in response to
the letter dated April 10, 2024 from the U.S. Securities and Exchange Commission (the “Commission”) in which the staff
of the Commission (the “Staff”) commented on the above-referenced Amendment No.1 to the Registration Statement on Form
F-1 filed on March 27, 2024. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, an amended Registration Statement
on Form F-1 (“F-1/A”) for filing with the Commission, which has been revised to reflect the Staff’s comments
as well as certain other updates to the F-1/A.

For the Staff’s convenience, each Staff’s
comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references
below in the Company’s responses are to the page numbers in F-1/A. Capitalized terms used but not otherwise defined herein have
the meanings set forth in the F-1/A.

Form F-1/A filed March 27, 2024

Dilution, page 68

    1

    Please complete the disclosure under
    Dilution and provide any missing information elsewhere in your filing like under Use of Proceeds in a pre-effective amendment to
    your Form F-1.

Response: In response to the Staff’s
comment, we have completed the requested disclosure under the Dilution and Use of Proceed sections in the F-1/A.

Financial Statements, page F-1

    2.

    Please provide audited financial statements
for the year ended December 31, 2023 in an amended filing.

Response: In response to the Staff’s
comment, we have provided the audited financial statements for the year ended December 31, 2023 in the F-1/A as required.

In responding to your comments, we acknowledge
that:

 ● the
Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 ● Staff
comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to
the filing; and

 ● the
Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq., or Yarona Yieh,
Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal, or yly@orllp.legal.

    Very truly yours,

    /s/ Shek Kin Pong

    Shek Kin Pong, Chief Executive Officer