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 July 23, 2025

Goh Kok Foong
Chief Executive Officer
CCH Holdings Ltd
No. 1, Jalan Perda Jaya
Kawasan Perniagaan Perda Jaya, 14000
Bukit Mertajam, Pulau Pinang, Malaysia

 Re: CCH Holdings Ltd
 Draft Registration Statement on Form F-1
 Submitted June 26, 2025
 CIK No. 0002074123
Dear Goh Kok Foong:

 We have reviewed your draft registration statement and have the following
comment(s).

 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. Please revise your cover page and Risk Factors sections and elsewhere as
appropriate
 to disclose the percentage ownership and voting power pre- and post-IPO
of Mr. Goh
 Kok Foong, your founder, chairman and CEO. Additionally, please revise
your
 discussion here and in your risk factor on page 26 as well as elsewhere
as appropriate
 to provide examples of corporate matters that your CEO, Mr. Goh Kook
Foong, will
 have the ability to control or significantly influence the outcome of as
matters
 July 23, 2025
Page 2

 requiring approval by shareholders (e.g., the election of directors,
amendment of
 organizational documents, and approval of major corporate transactions,
such as a
 change in control, merger, consolidation, or sale of assets).
Risk Factors, page 10

2. Please add a risk factor to address any risks or other impacts on
shareholders as a
 result of your exclusive forum provision discussed on page 88, including
the increased
 costs to bring a claim and that these provisions can discourage claims
or limit
 shareholders ability to bring a claim in a judicial forum that they
find favorable. Here
 and on page 88, explicitly state whether or not such provision applies
to claims arising
 under the Exchange Act and under the Securities Act. In addition, please
state in your
 risk factor disclosure that investors cannot waive compliance with the
federal
 securities laws and the rules and regulations thereunder and that there
is uncertainty as
 to whether a court may enforce your exclusive forum provision as it
applies to the
 Securities Act. In this regard, we note that Section 22 of the
Securities Act
 provides concurrent jurisdiction for claims arising thereunder, and it
appears your
 exclusive forum provision requires that Securities Act claims be
litigated in federal
 court.
Use of Proceeds, page 33

3. We note your disclosure that you intend to use the offering proceeds for
strategic
 investments or acquisitions and that you have been actively expanding
the network of
 your restaurant outlets in Malaysia and are "poised for strategic
expansion into other
 locations in Southeast Asia." Please give a brief description of such
businesses and
 information on the status of the acquisitions. Refer to Item 3.C.3 of
Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Strategic Expansion of Our Network of Restaurant Outlets, page 43

4. Please revise your disclosure here and elsewhere as appropriate to
briefly expand your
 discussion to state what specific steps or actions you have taken to
date to implement
 your strategic restaurant expansion plan. If none, clarify your
anticipated timeline for
 expansion. As currently disclosed, it is not clear whether this is a
future-looking plan
 or whether certain steps have already been taken.
Business
Our Competitive Strengths, page 62

5. Please revise your disclosure here to balance your discussion of "Our
Competitive
 Strengths" and "Our Growth Strategies" with discussion of the challenges
your
 business faces.
Franchise Licensing, page 68

6. We note the use of licensing agreements with licensees in Malaysia and
that each
 licensee is required to pay you royalties. Please file the form of
licensing agreement,
 or tell us why you are not required to do so. Refer to Item 601(b)(10)
of Regulation S-
 K.
 July 23, 2025
Page 3

Related Party Transactions, page 83

7. We note that many of the transactions disclosed here involve entities
controlled by
 your Chief Operation Officer, Mr. Goh Kok E., and his brother your
founder,
 chairman and Chief Executive Officer, Mr. Goh Kok Foong. Please revise
your Risk
 Factors section accordingly to discuss the risks associated with a
significant portion of
 your business being dependent on these relationships and relationship to
entities
 controlled by your CEO and COO. Quantify the dollar amounts and
percentage of
 revenue associated with these relationships.
8. Please revise your disclosure here to clarify the meaning of certain
entities (e.g., CCH
 Tasty) being "significantly influenced" by you. We note elsewhere that
you disclose
 holding certain equity ownership interests in certain entities. Consider
the use of
 footnotes and/or cross-references to make clear the nature of these
relationships.
Loans to Related Parties, page 84

9. Please revise to briefly state the purpose the various loans to related
parties,
 including Messrs. Goh Kok Foong and Mr. Goh Kok E. Additionally, please
disclose
 the amount due from related parties. We note your subsection describing
the amounts
 due to related parties.
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
(y) Segment Reporting, page F-19

10. We note that the primary measure of segment revenue and profitability is
consolidated
 revenue and net income. Please tell us how you considered the guidance
in ASC 280-
 10-50-29(f) and the example at 280-10-55-54(c) to discuss how the CODM
uses this
 measure in assessing performance and deciding how to allocate resources.
General

11. Please provide us with supplemental 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, present to potential investors in reliance on Section 5(d) of
the Securities Act,
 whether or not they retain copies of the communications.
 Please contact Ta Tanisha Meadows at 202-551-3322 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 Taylor Beech at
202-551-4515
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Stephanie Tang
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