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 March 28, 2025

Huiyi Zheng
Chief Executive Officer
Platinum Analytics Cayman Limited
60 Anson Road, 17-01, Mapletree
Singapore 079914

 Re: Platinum Analytics Cayman Limited
 Draft Registration Statement on Form F-1
 Submitted January 24, 2025
 CIK No. 0002053033
Dear Huiyi Zheng:

 We have reviewed your 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.

Draft Registration Statement on Form F-1
Cover Page

1. Revise the registration cover page to include the name, address, and
telephone number
 of the agent for service.
2. You disclose you will be a "controlled company" under Nasdaq rules upon
the
 completion of this offering because Huiyi Zheng and Qihong Bao will hold
more than
 50% of the voting power. Your Principal Shareholders table on page 67
appears to
 disclose Huiyi Zheng beneficially owns 33.54% your ordinary shares and
Qihong Bao
 beneficially owns 9.95% of your ordinary shares, or 43.44% together.
Please revise to
 reconcile this apparent discrepancy or advise.
 March 28, 2025
Page 2
About this Prospectus, page ii

3. In the second paragraph under the table of contents, we note your
disclosure that "You
 should not assume that the information contained in this prospectus is
accurate on any
 date subsequent to the date set forth on the front cover of this
prospectus or that any
 information we have incorporated by reference is correct on any date
subsequent to
 the date of the document incorporated by reference, even though this
prospectus is
 delivered or shares of Ordinary Shares are sold or otherwise disposed of
on a later
 date." This statement does not appear to be consistent with your
disclosure
 obligations. Please revise to clarify that the prospectus will be
updated to the extent
 required by law and acknowledge that you are responsible for updating
the prospectus
 to contain all material information.
4. In the fourth paragraph under the table of contents, we note your
disclosure that
 representations, warranties and covenants that you have made in any
agreement filed
 as an exhibit to the registration statement were made solely for the
benefit of the
 parties and should not be relied upon as accurately representing your
current state of
 affairs. Disclosure regarding an agreement's representations, warranties
and
 covenants in a registration statement (whether through incorporation by
reference or
 direct inclusion) constitutes a disclosure to investors, and you are
required to consider
 whether additional disclosure is necessary in order to put the
information contained in,
 or otherwise incorporated into that publication, into context so that
such information
 is not misleading. If you continue to use these cautionary statements in
your
 registration statement, please revise them to remove any implication
that the
 agreements do not constitute disclosure under the federal securities
laws and to clarify
 that you will provide additional disclosure to the extent that you are
or become aware
 of the existence of any material facts that are required to be disclosed
under the
 federal securities laws and that might otherwise contradict the
representations,
 warranties and covenants contained in the agreements and will update
such disclosure
 as required by federal securities laws.
Other Pertinent Information, page iii

5. Clearly disclose how you will refer to the holding company and
subsidiaries when
 providing the disclosure throughout the document so that it is clear to
investors which
 entity the disclosure is referencing and which subsidiaries or entities
are conducting
 the business operations. Disclose clearly the entity (including the
domicile) in which
 investors are purchasing an interest.
Corporate Structure, page 1

6. You refer to the section "Our History and Structure" for more details on
your
 corporate history. We were unable to locate a section entitled "Our
History and
 Structure." Please revise your disclosure accordingly. Additionally,
please include all
 significant subsidiaries in your organizational chart and identify the
person or entity
 that owns the equity in each depicted entity. Identify clearly the
entity in which
 investors are purchasing their interest and the entities in which the
company s
 operations are conducted.
 March 28, 2025
Page 3
Prospectus Summary, page 1

7. We note your statements that you have not independently verified
industry and market
 data obtained from various third-party sources and that the accuracy and
completeness
 of the information are not guaranteed. Please remove such disclosure or
include a
 sentence expressly confirming that you are responsible for all
disclosures in the
 registration statement.
8. Please provide more specific disclosure with regard to why you believe
that your
 products provide you with an advantage versus your competitors. For
example,
 explain how your "fully integrated suite" is "agile in integrating
cutting-edge AI
 technologies or customizing solutions to meet the specific demands of
high-growth
 markets in Asia." In addition, please provide support for you claim
regarding your
 status as "a trailblazer in leveraging advanced AI technologies for
foreign exchange
 (FX) trading and analytics."
Risk Factors
Our lack of effective internal controls over financial reporting..., page 11

9. On page 46, you disclose the audits of your financial statements for the
years ended
 September 30, 2023 and 2024 identified three "material weaknesses" in
your internal
 control over financial reporting. Please revise this risk factor to
include a discussion of
 these identified "material weaknesses."
Contractual Obligations, page 44

10. We refer to your disclosure relating to your "lease agreements for
several offices."
 Please revise to file each material lease agreement as exhibits or tell
us why
 you believe each of the leases is not material. Refer to Item 601(b)(10)
of Regulation
 S-K.
Business, page 53

11. On page F-16, you disclose that you depend on a small number of
suppliers. Please
 revise here or in your MD&A section to identify suppliers who accounted
for 10% or
 more of your purchases for the fiscal year ended September 30, 2024 and
disclose the
 material terms of any material agreements with these suppliers.
Additionally, please
 file these agreements as exhibits. Lastly, please revise to discuss your
dependence on
 a limited number of suppliers in your MD&A and add a risk factor
discussing material
 risks related to your dependence on a limited number of suppliers. See
Items 3.D, 4.B
 and 5 of Form 20-F and Item 601(b)(10) of Regulation S-K.
12. We note that you are able to offer "highly customized, AI-driven
solutions" and that
 you are "pioneering AI-driven trading and analytics solutions." Please
disclose
 whether the algorithms used in your products and services are
proprietary or open-
 source and clarify the operational status of these products.
Additionally, please add
 risk factors discussing any material risks resulting from your use of AI
technologies.
Our Customers, page 57

13. You disclose that your top two customers for the fiscal year ended
September 30,
 2024 accounted for 75.9% and 23.2% of your revenue, respectively. Please
revise to
 March 28, 2025
Page 4

 identify these customers and disclose the material terms of any material
agreements
 with these customers. Additionally, please file these agreements as
exhibits. Lastly,
 please revise to discuss your dependence on a limited number of
customers in your
 MD&A and add a risk factor discussing material risks related to your
dependence on a
 limited number of customers. See Items 3.D, 4.B and 5 of Form 20-F and
Item
 601(b)(10) of Regulation S-K.
Management, page 65

14. Please revise to identify your chief financial officer.
Employment Agreements, page 66

15. Please file the employment agreements and indemnification agreements
with each of
 your directors and executive officers.
Related Party Transactions, page 68

16. We note that you have amounts due from related parties, including an
entity
 controlled by your Chief Executive Officer, as of September 30, 2024.
Exchange Act
 Section 13(k)(1) of the Exchange Act prohibits public companies from
extending or
 maintaining credit in the form of personal loans to or for any director
or executive
 officer. Please disclose the business purpose of the loan and tell us
whether you
 believe the amounts due from this entity implicate the prohibition in
Section 13(k).
NOTE 12 - SUBSEQUENT EVENTS, page F-25

17. Please revise to disclose the date through which you evaluated
subsequent events.
 Refer to ASC 855-10-50-1(a).
General

18. We note that you disposed of your Hong Kong and Mainland China
subsidiaries on
 January 10, 2025 and are currently headquartered in Singapore. Please
revise to
 clarify the nature of your current business operations in China. In this
regard, please
 revise to clarify:

 whether you currently generate any revenue from customers in Hong
Kong or
 China, and if so, quantify the amount of revenue;
 whether any of your officers or directors reside in, or are
citizens of, Hong Kong
 or China; and
 whether you have any other business operations in Hong Kong or
China, such as
 assets located in Hong Kong or China or agreements with Hong Kong or
China-
 based suppliers.
19. We note that you did not identify an underwriter in this initial draft
registration
 statement submission. Please identify an underwriter in your next
submission or
 filing.
20. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, have presented or expect to present to potential
investors in reliance
 March 28, 2025
Page 5

 on Section 5(d) of the Securities Act, whether or not they retain copies
of the
 communications.
 Please contact Amanda Kim at 202-551-3241 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 Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Andrei Sirabionian
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