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 March 27, 2025

Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong

 Re: Bluemount Holdings Limited
 Registration Statement on Form F-1
 Filed March 17, 2025
 File No. 333-285843
Dear Chan Wan Shan Sandra:

 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
General

1. Please revise the presentation of your financial statements and other
financial data
 presented in tabular form so that it reads consistently from left to
right in the
 same chronological order throughout the filing. We note MD&A presents
the
 current period first while your financial statements present the prior
period first. Refer
 to SAB Topic 11:E for guidance.
Revenues
Advisory service fee income, page 89

2. Please expand your disclosure, similar to your disclosure for advisory
service income
 for fiscal year end 2024 and 2023 on page 83, regarding the material
increase in
 advisory service fee income and the upsurge in major projects undertaken
during the
 March 27, 2025
Page 2

 latter half of the six months ended September 30, 2024. Please include
relevant facts
 about the projects to inform investors about the quality of, and
potential variability of
 this revenue source so that investors can ascertain the likelihood that
past performance
 is indicative of future performance. Specifically, provide details about
the number of
 projects each period, the nature of projects (e.g., ad hoc vs.
recurring, etc.), the
 timeline of major projects including when they are expected to end, and
any estimate
 of revenue that may be recognized in future periods.
Impairment loss on trade and other receivables, page 89

3. Please revise your disclosures to discuss the key facts and
circumstances that resulted
 in the reversal of the impairment loss on trade and other receivables
for the current
 interim period.
Trading of timepieces, page 89

4. Please revise to provide details on the number of timepieces sold in
each period and
 any other factors that impacted the decrease in these revenues.
Major customers, page 99

5. We note the revenue concentration within your customer base, including
from
 Customer B, Customer C, Customer D, and Customer E. Please identify
these
 customers. In addition, revise the second risk factor on page 29
accordingly. Further,
 if applicable, disclose the terms of any material agreements with these
customers and
 file the agreements as exhibits. Refer to Item 601(b)(10) of Regulation
S-K.
Signatures, page II-5

6. Based on your disclosure on page 163 it appears that your board consists
of five
 members but only two directors have signed the registration statement.
Please revise
 to have the majority of the board of directors sign the registration
statement or advise.
 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.

 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.
 March 27, 2025
Page 3

 Please contact Michael Henderson at 202-551-3364 or Michael Volley at
202-551-
3437 if you have questions regarding comments on the financial statements and
related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at
202-551-
3601 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Finance
cc: Lawrence Venick, Esq.
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