SecProbe.io

CORRESP
 1
 filename1.htm

 September 26, 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, NE

 Washington, D.C. 20549

 Re:
 CCH Holdings Ltd (CIK No. 0002074123)

 Registration Statement on Form F-1 (File No. 333-289878)

 Registration Statement on Form 8-A (File No. 001-42864)

 Dear Ms. Beukenkamp, Ms. Beech, Ms. Meadows and
Ms. Brillant,

 Pursuant to Rule 461 of Regulation C ("Rule
461") promulgated under the Securities Act of 1933, as amended, CCH Holdings Ltd (the "Company") hereby requests that
the effectiveness of the above-referenced Registration Statement on Form F-1 (the "F-1 Registration Statement") be accelerated
to, and that the F-1 Registration Statement become effective at, 5:00 p.m., Eastern Time on September 29, 2025, or as soon thereafter
as practicable.

 The Company also requests that the Registration
Statement on Form 8-A under the Securities Exchange Act of 1934, covering the ordinary shares of the Company, be declared effective concurrently
with the F-1 Registration Statement (the F-1 Registration Statement, together with the Registration Statement on Form 8-A, the "Registration
Statements").

 If there is any change in the acceleration request
set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration
of the effectiveness of the Registration Statements in accordance with Rule 461 of Regulation C. Such request may be made by an executive
officer of the Company or by any attorney from the Company's U.S. counsel, Hogan Lovells.

 The Company understands that the representative
of the underwriters, on behalf of the prospective underwriters of the offering, has joined in this request in a separate letter filed
with the Securities and Exchange Commission today.

 [ Signature page follows ]

 Very truly yours,

 CCH Holdings Ltd

 By:
 /s/ Goh Kok Foong

 Name:
 Goh Kok Foong

 Title:
 Chairman and Chief Executive Officer

 [Signature Page to Issuer Acceleration Request]

CORRESP
 1
 filename1.htm

 Cathay
Securities, Inc.

 40
Wall Street, Suite 3600

 New
York, NY 10005

 September
26, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade & Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention: Ms.
Kate Beukenkamp, Ms. Taylor Beech, Ms. Ta Tanisha Meadows, and Ms. Theresa Brillant

 Re :
 CCH Holdings
 Ltd

 Registration
 Statement on Form F-1, as amended

 File No.
 333-289878

 REQUEST FOR
 ACCELERATION OF EFFECTIVENESS

 Requested Date:
 Monday, September 29, 2025

 Requested Time:
 5:00 p.m., Eastern Time

 Ladies
and Gentlemen:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended (the " Securities Act "), we, the undersigned,
as representative of the several underwriters of the proposed initial public offering of securities of CCH Holdings Ltd (the " Company "),
hereby join the Company's request that the effective date of the above-referenced registration statement on Form F-1, as amended,
be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time, on September 29, 2025 or as soon thereafter as possible.

 Pursuant
to Rule 460 under the Securities Act, please be advised that we will distribute as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

 Very truly yours,

 CATHAY SECURITIES, INC.

 By:
 /s/ Shell Li

 Name:
 Shell Li

 Title:
 Chief Executive Officer

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.

<DOCUMENT>
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<TEXT>
 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
</TEXT>
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