SecProbe.io

CORRESP
1
filename1.htm

February
14, 2025

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. 2 to Registration Statement on Form F-1

    Filed
    on February 4, 2025

    File
    No. 333-283643

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 February 13, 2025 on the Company’s
Registration Statement filed on February 4, 2025.

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. 2 to Registration Statement on Form F-1

Consolidated
Financial Statements, page F-1

    1.
    We
    note your registration statement includes audited financial statements that are older than 12 months. Since this represents an initial
    public offering of your ordinary shares, please update your financial statements pursuant to Item 8.A.4 of Form 20-F or provide the
    appropriate representations as to why such update is not necessary in an exhibit. Refer to Instruction 2 to Item 8.A.4.

Response:
In response to the Staff’s comment, the Company has filed the Request for Waiver and Representation under Item 8.A.4 of Form 20-F
as Exhibit 99.7.

If
you have any questions regarding the Registration Statement, please contact the undersigned by phone at +1 310 7285129 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