SecProbe.io

March 20, 2025
Lim Heng Hai
Chief Executive Officer
TechCreate Group Limited
336 Smith Street, #06-303, New Bridge Centre
Singapore 050336
Re:TechCreate Group Limited
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 6, 2025
CIK No. 0002047190
Dear Lim Heng Hai:
            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 January 14, 2025 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Major Customers, page 85
1.We note your revised disclosure regarding your significant customers in response to
prior comment 4. Please clarify the material terms of your agreements with your top
three customers rather than a general discussion of your contracts with your major
customers. Disclose the term of each agreement, termination provisions including
notice requirements, and liquidation damage provisions. We also note your response
that you will disclose the identities of the customers in an amendment.

March 20, 2025
Page 2
Consolidated Balance Sheets, page F-3
2.Please revise the header to properly display the date or time period for each
consolidated financial statement presented in this filing.
3.Please confirm whether you have collected the "Amount Due from Shareholders." We
refer you to SAB Topic 4(E). Please note that amount recorded as a shareholder
receivable for capital stock should be presented in the balance sheet as a deduction
from stockholders’ equity unless the receivable is paid in cash prior to the
publication of the financial statements.
            Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at 202-
551-3488 if you have questions regarding comments on the financial statements and related
matters. Please contact Marion Graham at 202-551-6521 or Jan Woo at 202-551-3453 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Meng Ding