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Vistek
Limited

39
Woodlands Close #08-11

Mega@Woodlands

Singapore
737856

March
21, 2025

Via
Electronic Mail

Division
of Corporation Finance

Office
of Real Estate & Construction

U.S.
Securities Exchange Commission

Attn:
Mr. Howard Efron

    Re:
    Vistek
    Limited

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

    Filed
    March 4, 2025

    File
    No. 333-284559

Dear
Mr. Efron:

This
letter is in response to the letter dated March 14, 2025, from the staff (the “Staff”) of the U.S. Securities Exchange Commission
(“SEC”) addressed to Vistek Limited (the “Company,” “we,” and “our”). For ease of reference,
we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the
“Registration Statement Amendment”) is being submitted to accompany this letter.

Registration
Statement on Form F-1 filed March 4, 2025

Cover
Page

    1.
    We
    note that Diamond Stream and Vibrant Epoch each subscribed for 4.5% of the shares of the Company on August 26, 2024 and that such
    shares were acquired by Diamond Stream and Vibrant Epoch for cash at par. We further note that, on September 19, 2024, Mega Optimal
    and Mr. Tong each acquired 4.9% of the shares of the Company for $0.5 million each. Please tell us and revise your filing to include
    a discussion of any significant factors contributing to the expected difference between the value of the shares sold to Diamond Stream,
    Vibrant Epoch, Mega Optimal, and Mr. Tong and an equivalent number of shares at the anticipated mid-point of the IPO price.

RESPONSE:
We note the Staff’s comment and respectfully advise the Staff that we have revised the Registration Statement Amendment at
page 59. We respectfully advise the Staff that Diamond Stream and Vibrant Epoch acquired a 4.5% stake in the Company at a valuation of
approximately S$198,000, based on a net tangible asset value of S$2.2 million, and were issued shares at par due to their business relationships
with the Group. In contrast, Mega Optimal and the Estate of Mr. Tong invested at a higher assumed valuation of US$10.2 million
for a 4.9% stake, without prior business ties to the Group. Given the investment risk Mega Optimal assumed without a guaranteed exit
strategy, their shares were not subject to a lock-up if the Company pursued an IPO. The Estate of Mr. Tong has agreed to a 30-day lock-up
agreement given the present uncertainty regarding the distribution of his assets.

Management

Compensation
of Directors and Executive Officers, page 119

    2.
    Please
    revise to disclose compensation information for the financial year ended February 28, 2025. See Item 6.B of Form 20-F.

RESPONSE:
We note the Staff’s comment and respectfully advise the Staff that we have amended the Registration Statement Amendment at
page 119.

    3.
    We
    note the consent of your independent registered public accounting firm at exhibit 23.1. Such consent refers to the audit report dated
    September 5, 2024 except for Notes 1 and 11 and the effects of the resulting retrospective adjustments, as to which the dates are
    October 16, 2024 and January 28, 2025, respectively. We further note the audit report at page F-33 dated September 5, 2024, with
    the exception of Notes 1 and 11 and the effects of the resulting retrospective adjustments, as to which the dates are October 16,
    2024 and March 4, 2025, respectively. Please have your auditor revise the dates in their report and/or their consent for consistency.

RESPONSE:
We note the Staff’s comment and respectfully advise the Staff that we have revised and refiled Exhibit 23.1.

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 our securities counsel William S. Rosenstadt, Esq., or Jason Ye, Esq. of Ortoli
Rosenstadt LLP at wsr@orllp.legal, or jye@orllp.legal.

    Vistek
    Limited

    /s/ Teck Hong Ho

    Name:

    Teck
    Hong Ho

    Title:
    Chief
    Executive Officer