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 August 4, 2025

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

 Re: UltraTrex Inc.
 Amendment No. 2 to Draft Registration Statement on Form F-1
 Submitted July 22, 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 June 18, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1

1. We note your response to prior comment 3. Please update your
organizational chart on
 page 7, and elsewhere as necessary, to include the voting control of
those parties prior
 to and after the offering to reflect the issuance of the Class B shares.
 August 4, 2025
Page 2
Management's Discussion and Analysis of Our Financial Condition and Results of
Operations
Organization and reorganization, page 35

2. We note in the disclosure regarding UMSB on page 36 you refer to the
"Concert
 Parties" however, in your response to prior comment 4 you did not refer
to an acting-
 in-concert agreement governing the control of UMSB. Please clarify your
disclosure
 and advise us. If an acting-in-concert agreement governing the control
of UMSB
 exists, disclose the details of this agreement including the date, the
parties involved,
 and the identity of the controlling person(s) on pages 36 and F-9. You
should also file
 this agreement as an exhibit.
3. We note after Mr. Halim transferred his 20% equity interest in UMSB on
December 6,
 2023, he held no equity in UMSB. Clarify in your disclosure your basis
for
 consolidating this entity with the other entities for which Mr. Halim
holds a
 controlling equity interest and advise us in detail.
4. Disclose on pages 37 and F-10 why the Group is considered to exercise
control over
 PT Ultratrex Indonesia and not Mr. Halim, and advise us. In light of his
98% equity
 interest it appears he controls.
5. Disclose on pages 37 and F-10 why the Group is considered to have
exercised control
 over Ultratrex Co. Ltd and not Mr. Halim, and advise us. In light of his
90% equity
 interest in Ultrator Co., Ltd, it appears he controlled it prior to the
November 29,
 2024 acquisition by Ultratrex Singapore.
Financial Statements
Note 1. General Information
Organization and reorganization, page F-8

6. Explain why in the table of page F-9 you indicate you held a 100% equity
interest
 in Ultratrex Asia Pacific Pte. Ltd. at June 30, 2024 and June 30, 2023,
prior to
 the July 3, 2024 date of incorporation. Similarly revise the disclosure
on page F-69
 and elsewhere, as applicable.

 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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