SecProbe.io

CORRESP
 1
 filename1.htm

 September
17, 2025

 Via
Edgar Correspondence

 Division
of Corporation Finance

 Office
of Technology

 U.S.
Securities and Exchange Commission

 Washington,
DC 20549

 Attn:
Ms. Marion Graham

 Re:
 Ultratrex
 Inc.
 Registration
 Statement on Form F-1 (File No. 333-290101)

 Request
 for Waiver and Representation under Item 8.A.4 of Form 20-F

 Dear
Ms. Graham:

 The
undersigned, Ultratrex Inc., a foreign private issuer organized under the laws of the Cayman Islands (the "Company"), is
submitting this letter via EDGAR to the U.S. Securities and Exchange Commission (the "Commission") in connection with the
Company's registration statement on Form F-1 filed with the Commission on September 8, 2025 (the "Registration Statement"),
relating to the proposed initial public offering and listing of the Company's class A ordinary shares in the United States.

 The
Company has included in the Registration Statement its audited consolidated financial statements, prepared in accordance with the provisions
of the International Financial Reporting Standards ("IFRS") as issued by the International Accounting Standards Board ("IASB"),
as of June 30, 2023 and 2024 and for each of the two fiscal years ended June 30, 2023 and 2024.

 The
Company respectfully requests that the Commission waive the requirement of Item 8.A.4 of Form 20-F, which states that in the case of
a company's initial public offering, the registration statement on Form F-1 must contain audited financial statements of a date
not older than 12 months from the date of the offering (the "12-Month Requirement"). See also Division of Corporation
Finance, Financial Reporting Manual , Section 6220.3.

 The
Company is submitting this waiver request pursuant to Instruction 2 to Item 8.A.4 of Form 20-F, which provides that the Commission will
waive the 12-Month Requirement "in cases where the company is able to represent adequately to us that it is not required to comply
with this requirement in any other jurisdiction outside the United States and that complying with this requirement is impracticable or
involves undue hardship." See also the 2004 release entitled International Reporting and Disclosure Issues in the Division
of Corporation Finance (available on the Commission's website at http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm)
by the staff of the Division of Corporation Finance of the Commission at Section III.B.c, in which the staff noted that:

 "the
instruction indicates that the staff will waive the 12-month requirement where it is not applicable in the registrant's other filing
jurisdictions and is impracticable or involves undue hardship. As a result, we expect that the vast majority of IPOs will be subject
only to the 15-month rule. The only times that we anticipate audited financial statements will be filed under the 12-month rule are when
the registrant must comply with the rule in another jurisdiction, or when those audited financial statements are otherwise readily available."

 In
connection with this waiver request, the Company represents to the Commission that:

 1.
 The
 Company is not required by any jurisdiction outside the United States to prepare consolidated financial statements audited under
 any generally accepted auditing standards for any interim period.

 2.
 Full
 compliance with Item 8.A.4 of Form 20-F at present is impracticable and involves undue hardship for the Company.

 3.
 The
 Company does not anticipate that its audited financial statements for the fiscal year ended June 30, 2025 will be available until
 October 31, 2025.

 4.
 In
 no event will the Company seek effectiveness of the Registration Statement if its audited financial statements are older than 15
 months at the time of the Company's initial public offering.

 The
Company will file this letter as an exhibit to the Registration Statement pursuant to Instruction 2 to Item 8.A.4 of Form 20-F.

 Sincerely,

 /s/
 Wong Kok Seng

 Wong
 Kok Seng

 Executive
 Director and Chief Executive Officer
 (principal executive officer)