CORRESP Filing
CCH Holdings Ltd
Date: Aug. 27, 2025 · CIK: 0002074123 · Accession: 0001213900-25-081018
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CORRESP 1 filename1.htm Hogan Lovells 11th Floor, One Pacific Place 88 Queensway Hong Kong 霍金路偉律師行 香港金鐘道88號 太古廣場一座11樓 T 電話 +852 2219 0888 F 傳真 +852 2219 0222 DX No 009021 Central www.hoganlovells.com 霍金路偉律師行 August 27, 2025 VIA EDGAR Ms. Kate Beukenkamp Ms. Taylor Beech Ms. Ta Tanisha Meadows Ms. Theresa Brillant Division of Corporation Finance Office of Trade & Services U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: CCH Holdings Ltd (CIK No. 0002074123) Registration Statement on Form F-1 Dear Ms. Beukenkamp, Ms. Beech, Ms. Meadows and Ms. Brillant, On behalf of our client, CCH Holdings Ltd, a company organized under the laws of the Cayman Islands (the " Company "), we are filing herewith the Company's registration statement on Form F-1 (the " Registration Statement ") and certain exhibits via EDGAR with the Securities and Exchange Commission (the " Commission "). In accordance with the Jumpstart Our Business Startups Act, as amended, the Company is, concurrently with the Registration Statement, filing the draft registration statement and its amendment thereto that were previously submitted for the non-public review of the staff of the Commission ( the " Staff "). The Company plans to file an amendment to the Registration Statement containing the estimated price range and offering size, and to launch the road show no earlier than 15 days after the date hereof. The Company would appreciate the Staff's timely assistance and support to the Company in meeting the proposed timetable for the offering. Should you have any questions regarding the Registration Statement, please contact me by telephone at (852) 2840 5026 (office) or via email at stephanie.tang@hoganlovells.com. Questions relating to accounting and auditing matters of the Company may also be directed to Wong Kok Siang, partner at ST & Partners PLT, by telephone at (60) 012 276 8178 or via email at kswong@stpartners.com.my. ST & Partners PLT is the independent registered public accounting firm of the Company. Sincerely yours, /s/ Stephanie Tang Stephanie Tang Partners M Lin O Chan D Y C So C J Dobby N W O Tang E I Low* J P Kwan S K S Li L H S Leung A J McGinty J E M Leitch B A Phillips T Liu J Cheng M Wong M Sit Z Dong Counsel A D E Cobden J S F Yim J Leung D Lau S Suen P J Kaur Foreign Legal Consultants S Tang (New York, USA) B Kostrzewa (District of Columbia, USA) S Jiang (New York, USA) *Notary Public Enclosures CC: Goh Kok Foong, Chief Executive Officer, CCH Holdings Ltd Wong Kok Siang, Partner, ST & Partners PLT Joseph M. Lucosky, Managing Partner, Lucosky Brookman LLP Hogan Lovells is an affiliated business of Hogan Lovells International LLP, a limited liability partnership registered in England and Wales. Hogan Lovells is part of an international legal practice that includes Hogan Lovells International LLP, Hogan Lovells US LLP and their affiliated businesses, with offices in: Alicante Amsterdam Baltimore Beijing Berlin Birmingham Boston Brussels Colorado Springs Denver Dubai Dublin Dusseldorf Frankfurt Hamburg Hanoi Ho Chi Minh City Hong Kong Houston London Los Angeles Luxembourg Madrid Mexico City Miami Milan Minneapolis Monterrey Munich New York Northern Virginia Paris Philadelphia Riyadh Rome San Francisco Sao Paulo Shanghai Silicon Valley Singapore Tokyo Washington, D.C. Associated Offices: Budapest Jakarta Shanghai FTZ. Business Services Centers: Johannesburg Louisville. The word "partner" is used to describe a partner or member of Hogan Lovells International LLP, Hogan Lovells US LLP or any of their affiliated entities or any employee or consultant with equivalent standing. Certain individuals, who are designated as partners, but who are not members of Hogan Lovells International LLP, do not hold qualifications equivalent to members. For more information about Hogan Lovells, the partners and their qualifications, see www.hoganlovells.com. Hogan Lovells is a member of the Pacific Rim Advisory Council with member offices in: Argentina Australia Brazil Canada Chile China (Mainland) Colombia France Hong Kong India Indonesia Japan Korea Malaysia Mexico Netherlands New Zealand Peru Philippines Singapore Taiwan Thailand USA Venezuela.