SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 22, 2025

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

 Re: Platinum Analytics Cayman Limited
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted April 8, 2025
 CIK No. 0002053033
Dear Huiyi Zheng:

 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 March 28, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1
Cover Page

1. We note that you have a dual class share structure and that you will be
offering Class
 A ordinary shares in this offering. While you disclose the voting rights
of your Class
 B ordinary shares on your cover page, please revise your cover page to
highlight this
 dual class structure, clearly disclose the voting rights of your Class A
ordinary shares
 and provide a cross-reference to a longer discussion of the material
risks and effects of
 this structure.
 April 22, 2025
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Major customers and suppliers, page 43

2. We note the revisions made here in response to prior comment 11. As
previously
 requested, please further revise to summarize the material terms of your
material
 agreements with these major suppliers. Additionally, please revise here
and on page
 58 to highlight that your main supplier, Shanghai Borui Finance
Information Limited,
 is a related party and is an entity controlled by your CEO. Please also
add a risk factor
 discussing any material risks to your company or its shareholders
resulting from your
 main supplier being a related party and an entity controlled by your
CEO.
3. We note the revisions made here in response to prior comment 13. As
previously
 requested, please further revise to summarize the material terms of your
material
 agreements with these significant customers. Additionally, please make
similar
 revisions on page 58.
Principal Shareholders, page 68

4. We note that you have two classes of voting securities, Class A ordinary
shares with 1
 vote per share and Class B ordinary shares with 20 votes per share.
While your
 Principal Shareholders table currently presents the beneficial ownership
disclosures
 for holders of your Class A ordinary shares, please revise your table to
also separately
 present the required beneficial ownership disclosures for holders of
your Class B
 ordinary shares. Additionally, include a column to reflect each
beneficial owner's total
 voting power. See Item 7.A of Form 20-F.

 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
</TEXT>
</DOCUMENT>