SecProbe.io

CORRESP
1
filename1.htm

September
16, 2024

Via
Edgar Transmission

Mr.
Alan Campbell / Ms. Doris Stacey Gama

Division
of Corporation Finance

Office
of Life Sciences

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Re:
    Cuprina
    Holdings (Cayman) Limited

    Amendment
    No. 6 to Registration Statement on Form F-1

    Filed
    on September 9, 2024

    File
    No. 333-277731

Dear
SEC Officers:

On
behalf of our client, Cuprina Holdings (Cayman) Limited, a foreign private issuer organized under the laws of the Cayman Islands (the
“Company”), we are filing herewith the Company’s registration statement on Form F-1 (the “Registration
Statement”) and certain exhibits via EDGAR to the Securities and Exchange Commission (the “Commission”).

Concurrently
with the filing of the Registration Statement, the Company is hereby in this letter setting forth the Company’s responses to the
comments contained in the letter from the staff of the Commission (the “Staff”) dated September 13, 2024 on the Company’s
Registration Statement filed on September 9, 2024.

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. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed
timetable for the offering.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined
herein have the meanings set forth in the Registration Statement.

Amendment
No. 6 to Registration Statement on Form F-1

Prospectus
Summary

Corporate
History and Structure, page 7

    1.
    Please
    revise the chart in this section and on page 53 to show the post-offering ownership percentages.

Response:
In response to the Staff’s comment, the Company has amended the relevant disclosures on pages 7 and 53 of the Registration Statement.

Business

Licenses,
Permits, Registrations and Approvals, page 103

    2.
    Your
                                            disclosure on page 104 indicates that your Hong Kong import permit has expired. Please
                                            revise to clarify the status of this permit.

Response:
In response to the Staff’s comment, the Company has added the relevant disclosures on page 104 of the Registration Statement.

Underwriting,
page 160

    3.
    We
    note your disclosure that the underwriters will offer selected dealers shares at the initial public offering price less a selling
    concession not in excess of US$4.50 per share.

Response:
In response to the Staff’s comment, the Company has amended the relevant disclosures on page 160 of the Registration Statement.

General

    4.
    Please
    revise the legal opinion filed as Exhibit 5.1 to quantify the number of shares and warrants being registered.

Response:
In response to the Staff’s comment, the Company has filed an update Exhibit 5.1 in the Registration Statement.

If
you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852.5600.0188 or via email at
lvenick@loeb.com.

    Very truly yours

    By:
    /s/
    Lawrence Venick

    Lawrence Venick

    Partner

    cc:
    David
    Quek Yong Qi, Director and Chief Executive Officer, Cuprina Holdings (Cayman) Limited

    Chan
    Tat Jing, Financial Controller, Cuprina Holdings (Cayman) Limited

    Michael
    J. Blankenship, Esq., Winston & Strawn LLP