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May 29, 2024
Raymond Wai Man Cheung
Chief Executive Officer
Basel Medical Group Ltd
6 Napier Road
Unit #02-10/11 Gleneagles Medical Centre
Singapore 258499
Re:Basel Medical Group Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted May 8, 2024
CIK No. 0002004489
Dear Raymond Wai Man Cheung:
            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. Unless we note otherwise,
any references to prior comments are to comments in our April 15, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1
1.We note your response to prior comment 3 and reissue our comment. Please expand your
disclosure here and in the Business section to discuss the timeline for your plans to expand
your business across Singapore and the Southeast Asian region.
Business, page 54
2.We note your response to prior comment 15, which we reissue in part. We refer to your
disclosure throughout your registration statement of the rising aging population as a key
driver of growth in the orthopedic market in Singapore. We also note your prominent
disclosure of your corporate client base in the construction and oil & gas industries, which
accounted for approximately 25% of your revenue in the fiscal year ended June 30, 2023,

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and that you offer sub-specialties that include sports medicine and trauma. Please expand
your disclosure relating to your key client bases and the medical services provided.
Our Competitive Strengths, page 56
3.We note your response to prior comment 14 and reissue our comment. For all statements
throughout the registration statement regarding industry leadership, please substantiate
your claims or remove such statements. As an example only, we continue to note
references to your "best-in-class treatments and services" on page 56.

We have a highly scalable corporate infrastructure to support growth, page 56
4.We note your disclosure in response to prior comment 16, which we reissue in part. Please
expand your disclosure relating to your shareholders and clarify whether their global
network provides access to partnerships and collaborations in the medical and orthopedic
industries.
Our Growth Prospects, page 57
5.We note your response to prior comment 17, which we reissue. Please revise to disclose
the addressable market for orthopedic treatments in Singapore and Southeast Asia,
including any orthopedic devices.
Our Business Model, page 59
6.We note your response and revised disclosure on page 60 relating to your currently
dormant entities, SKS and SKC. Please revise to provide additional detail regarding the
purposes and types of patients that SKS and SKC were intended to serve and how your
business strategy and customer profiles have changed over time. Please also revise your
disclosure and the diagram on page 35 accordingly.
Our Patients and Clients, page 70
7.We note your revised disclosure in response to prior comment 19 that your ten largest
customers during the six months ended December 31, 2023 include 271 corporate clients
who refer their employees to you for treatment. You also disclose that your ten largest
customers for the fiscal years ended June 30, 2022 and June 30, 2023 included six
corporate clients. Please revise to clarify how your ten largest customers included 271
corporate clients during the six months ended December 31, 2023 and discuss the factors
that contributed to this increase in corporate clients.
8.We note your revised disclosure in response to prior comment 23 that 72% of your
patients receive outpatient treatments. You also disclose on page 60 that your outpatient
services include a wide range of non-surgical services. Please expand your disclosure to
discuss the types of services and treatments that constitute inpatient and outpatient
treatments, and clarify whether the majority of your outpatient treatments are non-

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surgical.
Intellectual Property, page 72
9.We note your response to prior comment 24 and reissue our comment in part. Please
expand your disclosure relating to your registered trademarks, including the number of
trademarks, when you obtained such trademarks, and the jurisdictions in which you
registered such trademarks.
Licenses, Permits and Approvals, page 73
10.We note your revised disclosure in response to prior comment 26 that you will submit a
renewal application a reasonable period of time prior to the expiration of a patent. For
each patent expiring in 2024, please clarify the status of each license, including the
updated expiration date.
Note 15. Amount Due From/(To) Related Parties, page F-34
11.We have reviewed your revised disclosure in response to prior comment 35. Please revise
your consolidated balance sheets to present the amounts due from a director and related
parties as a deduction from equity, consistent with the guidance in Staff Accounting
Bulletin Topic 4.E, or explain the reason why a change is not necessary. In addition,
please disclose the full financial terms of the June 2023 agreement between Dr. Kevin Yip
and Rainforest Capital VCC since payment is related to this agreement. Lastly, please
clarify your disclosure to state whether Rainforest Capital VCC will pay cash to Basel
Medical Group Ltd since the use of the word "offset" does not clearly indicate that the
payment of cash will be made to settle the outstanding receivables and to state whether
payment will be made if June 30, 2024 financial statements are not issued.
Note 16. Borrowings, page F-35
12.We note your response to comment 36. Please clearly disclose which specific term loans
and corresponding amounts have been classified as current liabilities.
13.We note your response to comment 37. You disclose that the risk of any cross-default or
cross-acceleration provisions is low.  Please specifically disclose whether there are cross-
default and cross-acceleration provisions in your term loan agreements and
correspondingly summarize the terms. Please also tell us how you determined the risk of
these provisions is low and do not need to be considered when determining the balance
sheet classification of your remaining term loans. In addition, please revise the relevant
risk factor on page 16 to reflect that loans are currently are in default.
General
14.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the

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Basel Medical Group Ltd
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Securities Act, whether or not they retain copies of the communications
            Please contact Nudrat Salik at 202-551-3692 or Michael Fay at 202-551-3812 if you have
questions regarding comments on the financial statements and related matters. Please contact
Robert Augustin at 202-551-8483 or Jane Park at 202-551-7439 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Benjamin Tan, Esq.