SecProbe.io

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 April 25, 2025

Moore Xin Jin
Director and Chief Executive Officer
Antalpha Platform Holding Company
Suntec Tower 2, 9 Temasek Boulevard
#13-01/02/03, Singapore, 038989

 Re: Antalpha Platform Holding Company
 Registration Statement on Form F-1
 Filed April 18, 2025
 File No. 333-286629
Dear Moore Xin Jin:

 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. Unless
we note
otherwise, any references to prior comments are to comments in our April 14,
2025 letter.

Registration Statement on Form F-1
Summary Combined and Consolidated Financial Data, page 17

1. Please revise your per share data to reflect the following:
 Revise the income and loss per share information to reflect your
April 18, 2025
 reverse stock split.
 Revise your 2024 basic and diluted weighted average common shares
outstanding
 to properly reflect the post-split diluted shares of 19,425,638 as
presented on page
 F-4.
Enforceability of Civil Liabilities, page 88

2. We note your added disclosure on pages 76 and 88 in response to prior
comment 3,
 which states in part, "For example, Mr. Paul Guanning Liang, our
director and chief
 financial officer, and Mr. Yang Wang, our director, reside in Hong Kong"
(emphasis
 April 25, 2025
Page 2

 added). Please supplementally confirm whether you have identified all of
your
 directors and executive officers that are located in China or Hong Kong
and, if not,
 revise your disclosure to identify the relevant individuals and discuss,
both in the
 enforceability of civil liabilities section and the related risk factor,
the difficulty of
 bringing actions against them and enforcing judgments against them.
Notes to Combined and Consolidated Financial Statements
Note 6. Crypto assets held, page F-23

3. We note your response to prior comment 6 and your revised disclosures on
page F-
 24. Please also revise related disclosures on pages 107, 148 and F-36 to
conform.
 Further, please tell us and enhance the description of proceeds of
amounts due to
 related party and repayments of amount due to related party, to clarify
the nature of
 the underlying activity considering revised disclosures to separately
present crypto
 activities for revenue, costs and expenses, loan borrowings and
repayments, collateral
 receipts and remittances and BTC loan interest receipts and remittances.
 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.

 Please contact Michelle Miller at 202-551-3368 or Mark Brunhofer at
202-551-3638
if you have questions regarding comments on the financial statements and
related
matters. Please contact Irene Paik at 202-551-6553 or David Lin at 202-551-3552
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Crypto Assets
cc: Brian V. Breheny, Esq.
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