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Fitness
Champs Holdings Limited

7030
Ang Mo Kio

Avenue
5, #04-48

NorthStar@AMK

Singapore
569880

October 18, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Alyssa Wall

     
    Re:
    Fitness
    Champs Holdings Limited (the “Company”)

     

     

    Amendment
    No. 1 to Registration Statement on Form F-1 Submitted October 3, 2024 (as amended, the “Registration Statement”)

     

     

    File
    Number 333-282016

Ladies
and Gentlemen:

We
have set forth below responses to the comment of the staff (the “Staff”) of the Securities and Exchange Commission
contained in its letter of October 16, 2024 with respect to the Company’s Registration Statement.

For
your convenience, the text of the Staff’s comment is set forth below in italics, followed by the Company’s response. Please
note that all references to page numbers in the responses are references to the page numbers in the Amendment No. 2 to the Registration
Statement submitted concurrently with the submission of this letter in response to the Staff’s comment. 

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

Capitalization,
page 34

    1.
    On
    your table of indebtedness, please tell us what the column labeled “As adjusted” represents. The notes at the end of
    the table indicate that you intend to repay the shareholder loans in full using proceeds from this offering, so it is not clear what
    the as adjusted amounts represents. In addition, we note that your capitalization table also reflects the full amount of shareholder
    loans in the “as adjusted” column.

We
have revised the disclosure in the tables regarding Capitalization and Indebtedness to clarify that the shareholder loan will be paid
from the proceeds of the offering, and conformed the “As Adjusted” columns in these tables accordingly.

If
you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com
or Joilene Wood at 415-305-4651 or jwood@troygould.com.

     

    Sincerely,

     

       

     

    Fitness
    Champs Holdings Limited

     

     

     

     

    By:

    /s/
    Joyce Lee Jue Hui

     

     

    Joyce
    Lee Jue Hui

     

     

    Chief
    Executive Officer

  

    cc:

    David
    L. Ficksman

     

    R.
    Joilene Wood