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  Sidley
                                            Austin

39F,
Two Int’l Finance Centre

Central,
Hong Kong

+852
2509 7888

+852
2509 3110 FAX

  +852
                                            2509 7858

                         MENG.DING@SIDLEY.COM

Confidential

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Technology

100
F. Street, N.E.

Washington,
D.C. 20549

  Attn:
  Morgan Youngwood

  Stephen Krikorian

  Re:
  TechCreate Group Limited

  Registration Statement on Form F-1

  Filed July 29, 2025

  File No. 333-289030

Dear
Sir/Madam,

On
behalf of our client, TechCreate Group Limited, a Cayman Islands exempted company (the “Company”), we are responding
to the comments from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
relating to the Company’s Registration Statement on Form F-1 (the “Registration Statement”) contained in the
Staff’s letter dated August 11, 2025 (the “Comment Letter”). In response to the comments set forth in the Comment
Letter, the Company is filing its Amendment No. 1 to the Registration Statement (the “Amended Registration Statement”)
together with this response letter. The Amended Registration Statement contains certain additional updates and revisions.

Set
forth below are the Company’s responses to the Staff’s comments. For convenience, the Staff’s comments are repeated
below in italics, followed by the Company’s response to the comments as well as a summary of the responsive actions taken. We have
included page numbers to refer to the location in the Amended Registration Statement where the revised language addressing a particular
comment appears.

Amendment
No. 1 to Registration Statement on Form F-1 filed July 29, 2025

Dilution,
page 51

 1. Please
                                            clarify how you determined that $3.96 represents the amount of dilution in net tangible book
                                            value to new investors in this offering. In this respect, explain why the amount of dilution
                                            in net tangible book value to new investors in this offering does not represent the $4.50
                                            assumed initial public offering price per Class A Ordinary Share less the $0.47 pro forma
                                            net tangible book value per Class A Ordinary Share after giving effect to the conversion
                                            of your preferred shares. As part of your response, explain your reference to the conversion
                                            of preferred shares. In addition, please disclose the amount of underwriter discounts and
                                            commissions being charged against the proceeds. Please also explain why the pro forma net
                                            tangible book value amount presented in this table does not agree to the amount presented
                                            in the Capitalization table.

Response:
In response to the Staff’s comment, the Company revised the disclosure on pages 50 and 51 of the Amended Registration Statement.
The dilution has been amended to $4.03 and the disclosures were amended to reflect Item 506(b) of Regulation S-K. We have also amended
the net tangible book value amount in the Capitalization table to ensure the accuracy and that it agrees to the amount used in computing
the dilution amount.

Partners
| Constance Choy H.M., Desmond Ang C.K., (Stephanie) Chan C. M., (Christopher) Cheng C.H., Meng Ding,
Dominic D. James, (Sherlyn) Lau S.Y.,

David
K. Lee, Olivia Ngan S.M., (Raymond) Oh C.H., Yuet Ming Tham, Claudia Yu K.W., Yan Zhang

Registered
Foreign Lawyers | Dhevine S. Chandrapala (England and Wales)*, (Carrie) Li J. (New York)*, Mevelyn Ong S.L. (New York),

David
J. Ryan (Victoria), Giancarlo B. Sambalido (New York), (Renee) Xiong Y. (New York)*, Liming Xu (New York)

Consultants
| (Coco) Liu T., Sophia Tong, Douglas Tsang C.L., (Eva) Tsui Y.W, Alan Wong C.K., Felicity Wong K.Y., (Dennis) Wu T.L., Iris Yuen L.S.

*
Partner of Sidley Austin Holding LLP (a Delaware Limited Liability Partnership)

Page
2

 2. Please
                                            revise your disclosures to separately present the increase in pro forma net tangible book
                                            value per share attributable to the cash payments made by purchasers of the shares being
                                            offered. We refer you to Item 506(b) of Regulation S-K.

Response:
In response to the Staff’s comment, the Company revised the disclosure on page 51 of the Amended Registration Statement.

 3. We
                                            note the table summarizing, on a pro forma as adjusted basis as of December 31, 2024, the
                                            differences between existing shareholders and the new investors with respect to the number
                                            of Ordinary Shares purchased from you, the total consideration paid and the average price
                                            per Ordinary Share paid before deducting the underwriting discounts and commissions and estimated
                                            offering expenses. Please explain how you determined the total consideration paid by existing
                                            shareholders. In this respect, $647,752 appears to represent your net tangible book value
                                            or shareholders’ equity as of December 31, 2024. In addition, explain why you present
                                            a total average price per ordinary share ($0.60) for existing and new investors.

Response:
In response to the Staff’s comment, the Company revised the disclosure on page 51 of the Amended Registration Statement. The
total consideration paid by existing shareholders has been revised to the Net Asset Value use in the computation of Stamp Duty paid to
the Inland Revenue Authority of Singapore during the restructuring process. The total average price per ordinary share has been revised
to $0.62.

Signatures,
page II-5

 4. Please
                                            revise to include the signature of your controller or principal accounting officer.

Response:
In response to the Staff’s comment, the Company revised page II-5 to the Amended Registration Statement.

If
you have any questions regarding the Amendment No. 1 to Registration Statement on Form F-1, please do not hesitate to contact me by phone
at +852 2509 7858 or via e-mail at meng.ding@sidley.com.

    Very
    truly yours,

    /s/
    Meng Ding

    Meng
    Ding

    cc:
    Via
                                            E-mail

    Lim
    Heng Hai, Chief Executive Officer

    TechCreate Group Limited