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CORRESP Filing

CCH Holdings Ltd
Date: Aug. 27, 2025 · CIK: 0002074123 · Accession: 0001213900-25-081018

Offering / Registration Process Regulatory Compliance Financial Reporting

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 27, 2025
Author
/s/ Stephanie Tang
Form
CORRESP
Company
CCH Holdings Ltd

Letter

VIA EDGAR Division of Corporation Finance Office of Trade & Services 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

Show Raw Text
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.