SecProbe.io

July 10, 2024
Chan Chun Sing
Chief Executive Officer
Click Holdings Ltd.
Unit 709, 7/F., Ocean Centre
5 Canton Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:Click Holdings Ltd.
Registration Statement on Form F-1
Filed June 27, 2024
File No. 333-280522
Dear Chan Chun Sing:
            We have reviewed your 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.
Registration Statement on Form F-1 filed June 27, 2024
Capitalization, page 46
1.Please tell us how you gave effect to the issuance and sale of 400,000 shares in private
placement subsequent to December 31, 2023 in the pro forma and pro forma as adjusted
columns.
Dilution, page 47
2.Please tell us how you reflected the issuance of 400,000 new ordinary shares for $512,821
on February 7, 2024 in your dilution disclosure.
            We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

July 10, 2024
Page 2
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Valeria Franks at 202-551-7705 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Scott Anderegg at 202-551-3342 or Dietrich King at 202-551-8071 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Hilda Chan