SecProbe.io

September 19, 2025
Wai Ting, CHEUNG
Chief Executive Officer
HAMA Intelligence Ltd
380 Jalan Besar, #07-10 ARC 380
Singapore 209000
Re:HAMA Intelligence Ltd
Registration Statement on Form F-1
Filed September 9, 2025
File No. 333-290122
Dear Wai Ting, CHEUNG:
            We have reviewed your registration statement and have the following comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1
Cover Page
1.Here and on pages 13, 29 and 35, please revise your disclosure to state plainly that
your controlling shareholder and CFO, Mr. Wing Sum Ho, will have the ability to
control the outcome of matters requiring approval by shareholders. In this regard, we
note your current statement that the controlling shareholder of the holders of the Class
B shares will have the ability to control "or significantly influence" these matters.
However, we note that Mr. Ho will control an aggregate of 96.1% of the total voting
power.

September 19, 2025
Page 2
Report of Independent Registered Public Accounting Firm, page F-2
2.We note your response to prior comment 5. We continue to believe that the audit
report should be dual dated as the conversion of the shares and adjustment to the
financial statements occurred after the date of the auditor's report. See paragraphs .03
and .05 of AS 3110. Please revise accordingly.
Consolidated Statements of Changes in Stockholders' Equity, page F-5
3.Please explain how you derived the 3,000,0000 Class A and 9,407,000 Class B shares
balance as of February 28, 2025.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Scott Stringer at 202-551-3272 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Lilyanna Peyser at 202-551-
3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Lawrence Venick