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 June 18, 2025

Wong Kok Seng
Chief Executive Officer
UltraTrex Inc.
220 Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

 Re: UltraTrex Inc.
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted June 3, 2025
 CIK No. 0002046954
Dear Wong Kok Seng:

 We have reviewed your amended draft registration statement and have the
following
comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our May 20, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1

1. We note your response to prior comment 5. Please explain why your
initial
 submission stated you had more than 70 customers and you now disclose
 your manufacturing and sales of amphibious heavy machinery business has
125
 customers. Additionally, please revise to provide an "as of" date for
this disclosure.
 We also note your statement on page 51 that you "have a wide customer
base in
 respect of our dredging solutions business, comprising more than 5
customers."
 Similarly revise to provide your number of customers for this line of
business as of
 June 18, 2025
Page 2

 the end of each period included in your filing and further explain why
you consider
 this to be a "wide customer base."
Risk Factors, page 10

2. On page F-53, you identify three "customers whom represent 10% or more
of the
 Group s total revenue;" however, it appears that only Customer A
accounted for 10%
 or more your revenue in 2024. Accordingly, please clarify the percentage
of revenue
 each of these customers accounted for in each period and revise your
disclosure as
 necessary. To the extent you rely on a limited number of customers,
please revise to
 include a risk factor discussing risks related to this dependence.
Additionally, to the
 extent these customers accounted for 10% or more of your revenues,
please revise to
 identify these customers.
Management's Discussion and Analysis of Our Financial Condition and Results of
Operations
Organization and reorganization, page 34

3. Please revise the organizational diagram to clearly indicate the voting
control of each
 of the beneficial owners that are a party to the Acting-in-Concert
Agreement and
 include the voting control of those parties prior to and after the
offering.
4. We note your response to prior comment 8 and reissue in part. Please
revise to clarify
 whether the concert party arrangement is still in effect and file the
Acting-in-Concert
 Agreement as an exhibit.
Liquidity and Capital Resources, page 44

5. We note your response to prior comment 13 and reissue in part. Please
revise to
 disclose an estimate of the amount of capital required to carry out your
business plan
 for the next 12 months.
Note 1. General Information
Organization and reorganization, page F-8

6. We note your response to prior comment 18. We also note that the report
of your
 independent registered public accounting firm included in the
registration statement
 has been issued for Ultratrex Inc., a Cayman Islands holding company,
and its
 consolidated subsidiaries, although the reorganization described in Note
1 is
 incomplete. Your disclosures indicate that Ultratrex Inc. has not
acquired Ultratrex
 Asia Pacific Pte. Ltd. as of the date of the audit report. Please tell
us why your public
 accounting firm included an unrestricted audit report rather than a
to be issued
 report due to the pending future event, namely the acquisition of
Ultratrex Asia
 Pacific Pte. Ltd.
7. We note your response to prior comment 20 and your disclosures of the
Acting-in-
 Concert Agreement signed on August 15, 2024. In order to better
understand the
 power held by Salim, Halim, Nursalim, and Taslim to collectively govern
the
 Company's financial and operating policies so as to obtain benefits from
its activities,
 please explain and expand your disclosures for the following:
 Clarify how the Concert Parties exercise their votes as shareholders
in
 concert. For example, explain in what manner contractually are they
required to
 June 18, 2025
Page 3

 make decisions together and coordinate their actions.
 Define all the matters that require the decisions of the
shareholders. For example,
 explain whether all the matters include electing directors,
approving acquisitions,
 and changing corporate bylaws.
 Tell us whether the Acting-in-Concert agreement remains in effect
after the
 completion of the reorganization and offering.
8. We note your response to prior comment 21. Please tell us why the board
of Ultratrex
 Machinery Sdn. Bhd. needed to legally mandate that Mr. Wong hold a 99%
equity
 interest in PT Ultratrex Machinery Indonesia ( PT UMI ) from October
22, 2022 until
 April 24, 2024, when PT UMI had been deemed capitalized by Ultratrex
Machinery
 Sdn. Bhd. Moreover, please clarify the "de facto" control held by the
Group
 collectively that provided the power to govern PT UMI's financial and
operating
 policies so as to obtain benefits from its activities. For instance,
explain any
 contractual arrangements giving power over PT UMI, exposure or rights to
variable
 returns from involvement with PT UMI, and the ability to use power to
affect those
 returns.
9. We note your response to prior comment 22. As part of the
reorganization, it appears
 Ultratrex Inc. will acquire Ultratrex Asia Pacific Pte. Ltd. under
common control due
 to the binding effect of the Acting-in-Concert Agreement. Please provide
the
 following about the parties before and after the transaction and the
offering:
 Clarify the ownership percentages of the Concert Parties in
Ultratrex Inc.
 and Ultratrex Asia Pacific. Ltd. upon the acquisition.
 Describe the transfer of ownership percentages from the Concert
Parties allowing
 Mr. Halim to exercise a controlling percentage of the total voting
power of your
 authorized and issued shares upon the completion of the offering.
 Explain the terms of any contractual arrangements of the transfer to
Mr. Halim
 upon completion of the offering and tell us why this transaction
does not result
 in a change of control from the Concert Parties collectively to Mr.
Halim.
10. We also note that the Ultratrex Asia Pacific Pte. Ltd. acquisition will
be accounted for
 as a business combination under common control in accordance with the
principles of
 IFRS 3. Please tell us your consideration of IFRS 3 paragraph 2(c) that
specifically
 scopes out transactions that are business combinations involving
entities or businesses
 under common control. Also tell us your consideration of IAS 8,
paragraphs 10 -12
 and revise your disclosures accordingly.
 June 18, 2025
Page 4

 Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Technology
cc: Yarona Yieh
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