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 May 22, 2025

Andrew Yeo
Chief Executive Officer
Phaos Technology Holdings (Cayman) Ltd
83 Science Park Dr,
#02-01 & #04-01A/B The Curie, Singapore Science Park 1
Singapore 118258

 Re: Phaos Technology Holdings (Cayman) Ltd
 Amendment No. 3 to Registration Statement on Form F-1
 Filed May 9, 2025
 File No. 333-284137
Dear Andrew Yeo:

 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 17,
2025 letter.

Amendment No. 3 to Registration Statement on Form F-1 filed May 9, 2025
Prospectus Summary
Overview, page 5

1. We note your revised disclosure in response to comment 1, including that
"[s]ervice
 revenue increased as a result of solutions and maintenance-based
contracts for our
 customers." Please revise to provide additional detail describing the
 solutions contracts, given your disclosure on page 6 that customers pay
a yearly
 maintenance fee, but software solutions services are bundled free of
charge with
 hardware.
 May 22, 2025
Page 2
Business Strategies, page 48

2. As previously requested, please fully explain how your loan to PT Neura
aligns with
 your stated business strategies and plans. In this regard, it is not
clear how the loan
 helps you "build strategic alliances" or how such alliances can
reasonably be expected
 to increase your revenue. Disclose specifically how PT Neura used the
loan proceeds,
 and fully describe the services that comprise the majority of PT Neura's
revenue,
 including the prices PT Neura charges for these services. Disclose the
competitive
 advantages and disadvantages of PT Neura that materially impact their
ability to
 succeed in the biomedical scanning and bespoke cloud storage solutions
markets. In
 your disclosure, please discuss objective and reliable evidence that
supports your
 conclusion that PT Neura has the financial resources needed to repay the
loan, and
 explain how this evidence supports your conclusion. Finally, please
disclose the total
 assets, total liabilities, total revenues, and net income or loss
reported by PT Neura in
 their most recent financial statements. We may have further comment.
Compensation of Executive Directors and Executive Officers, page 60

3. Please revise to include compensation disclosure for your last full
financial year, April
 30, 2025. See Item 6.B. of Form 20-F.
Financial Statements, page F-1

4. Pursuant to Item 8.A.4 of Form 20-F, please provide audited financial
statements that
 are no more than twelve months old. Alternatively, to the extent you
meet the 15-
 month criteria outlined in Instruction 2. to Item 8.A.4, file the
necessary
 representations as an exhibit to the registration statement.
Exhibit Index
Exhibit 23.1, page II-4

5. The consent references a prior amendment. Please revise.

 Please contact Al Pavot at 202-551-3738 or Terence O'Brien at
202-551-3355 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: William S. Rosenstadt
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