SecProbe.io

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 April 8, 2026

Angel Siu
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
People s Republic of China

 Re: Creative Global Technology Holdings Ltd
 Form 20-F for Fiscal Year Ended September 30, 2025
 File No. 1-42412
Dear Angel Siu:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Lan Lou
</TEXT>
</DOCUMENT>

CORRESP
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 Suite 1919, 45 Rockefeller Plaza

 630 Fifth Avenue

 New York, NY 10111, USA

 T: (1-737) 215-8491

 F: (1-917) 672-3642

 VIA EDGAR

 April 7, 2026

 Division of Corporation Finance

 Office of Trade & Services

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Nicholas Nalbantian, Jason Drory, Ta Tanisha Meadows, Joel Parker

 Re:
 Creative Global Technology Holdings Ltd (the "Company")

 Form 20-F for Fiscal Year Ended September 30,
 2025
 Filed on January 30, 2026
 File No. 1-42412

 Ladies and Gentlemen:

 On behalf of our client, Creative Global Technology
Holdings Ltd (the "Company"), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the "Staff") this letter setting forth the Company's
responses to the comments contained in the Staff's letter dated March 30, 2026 (the "Comment Letter") on the Company's
Form 20-F for Fiscal Year Ended September 30, 2025 filed on January 30, 2026 (the "Form 20-F").

 Form 20-F for Fiscal Year Ended September
30, 2025

 General

 1.

 Please revise future filings, as applicable,
 to provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. For additional
 guidance, please see the Division of Corporation Finance's Sample Letter to China-Based Companies issued by the Staff in December
 2021 (the "CBI Sample Letter"). To the extent the CBI Sample Letter requests disclosure on the prospectus cover page or in the
 prospectus summary, please provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F; in addition, please
 include a discussion of the transfer of cash within the company in Item 5 of Form 20-F.

 In response to the Staff's comment, the
 Company will revise future filings, as applicable, to provide more specific and prominent disclosures about the legal and operational
 risks associated with China-based companies. To the extent the CBI Sample Letter requests disclosure on the prospectus cover page or in
 the prospectus summary, the Company will provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F; in addition,
 the Company will include a discussion of the transfer of cash within the Company in Item 5 of Form 20-F.

 1

 If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

 Thank you again
for your time and attention.

 Yours sincerely,

 /s/ Lan Lou

 Lan Lou

 Partner

 Jun He Law Offices LLC

 cc:

 Hei Tung (Angel) Siu, Director and Chief Executive Officer, Creative
Global Technology Holdings Limited

 2

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<TEXT>
 March 30, 2026

Angel Siu
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
People s Republic of China

 Re: Creative Global Technology Holdings Ltd
 Form 20-F for Fiscal Year Ended September 30, 2025
 File No. 1-42412
Dear Angel Siu:

 We have reviewed your filing and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for Fiscal Year Ended September 30, 2025
General

1. Please revise future filings, as applicable, to provide more specific
and prominent
 disclosures about the legal and operational risks associated with
China-based
 companies. For additional guidance, please see the Division of
Corporation Finance s
 Sample Letter to China-Based Companies issued by the Staff in December
2021 (the
 "CBI Sample Letter"). To the extent the CBI Sample Letter requests
disclosure on the
 prospectus cover page or in the prospectus summary, please provide such
disclosure in a
 separate section at the beginning of Item 3 of Form 20-F; in addition,
please include a
 discussion of the transfer of cash within the company in Item 5 of Form
20-F.
 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.

 Please contact Ta Tanisha Meadows at 202-551-3322 or Joel Parker at
202-551-3651 if
 March 30, 2026
Page 2

you have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Jason Drory at 202-551-8342 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Lan Lou
</TEXT>
</DOCUMENT>

CORRESP
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Benjamin Securities, Inc.

3 West Garden Street

Suite 407

Pensacola, FL 32502

November 14, 2024

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

RE: Creative Global Technology Holdings Limited

Registration Statement on Form F-1, as amended

File No. 333- 273329

Ladies and Gentlemen:

Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and
the other underwriters, hereby join in the request of Creative Global Technology Holdings Limited that the effective date of the above-referenced
registration statement be accelerated so as to permit it to become effective at 4:00 p.m., Eastern Time, on November 18, 2024 or as soon
thereafter as practicable.

Pursuant to 460 under the
Act, we wish to advise you that the underwriters will distribute as many copies of the preliminary prospectus dated September 24, 2024
to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such 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,

    Benjamin Securities, Inc.

    By:
    /s/ Michael Coyne

    Name:
    Michael Coyne

    Title:
    Principal

CORRESP
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Creative Global Technology Holdings Limited

Unit 03, 22/F, Westin Centre

26 Hung To Road, Kwun Tong

Kowloon, Hong Kong

November 14, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, NE

Washington, D.C., 20549

Attn: Mr. Nicholas Nalbantian

    Re:
    Creative Global Technology Holdings Limited

    Registration Statement on Form F-1, as amended (File No. 333-273329)

    Request for Acceleration of Effectiveness

Dear Mr. Nalbantian:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Creative Global Technology Holdings Limited hereby
requests that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended be accelerated to and that
the Registration Statement become effective at 4:00 p.m., Eastern Time, on November 18, 2024, or as soon thereafter as practicable.

    Very truly yours,

    Creative Global Technology Holdings Limited

    By:
    /s/ Shangzhao (Cizar) Hong

    Name:
    Shangzhao (Cizar) Hong

    Title:
    Chief Executive Officer

CORRESP
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Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-737) 215-8491

junheny@junhe.com

VIA EDGAR

September 24, 2024

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian

    Re:
    Creative Global Technology Holdings Ltd (the “Company”)

Amendment No. 13 to Registration Statement on
Form F-1

Filed on September 11, 2024

CIK No. 0001967822

Dear Mr. Nalbantian:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated September 20, 2024 (the “Comment Letter”) on the Company’s
Amendment No. 13 to Registration Statement on Form F-1 filed on September 11, 2024 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No. 14 to Registration Statement (the “Revised Registration Statement”). The
Company has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing
an explanation if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment
Letter is printed below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth
below refer to the page numbers in the Revised Registration Statement.

General

    1.
    Please
    refer to the Selling Shareholders Plan of Distribution section on page Alt-4. We note your disclosure that a selling shareholder may
    use any one or more methods which include “purchases by a broker-dealer as principal and resale by the brokerdealer for its
    account” and that “[t]o the extent required,... the name of the Selling Shareholder, the respective purchase prices and
    public offering prices, the names of any agents, dealer or underwriter, any applicable commissions or discounts with respect to a
    particular offer will be set forth in an accompanying prospectus supplement or, if appropriate, a post-effective amendment to the
    registration statement that includes this prospectus.” Please confirm your understanding that the retention by a selling
    shareholder of an underwriter would constitute a material change to your plan of distribution requiring a post-effective
    amendment. Refer to your undertaking provided pursuant to Item 512(a)(1)(iii) of Regulation S-K. Lastly, please revise the Selling
    Shareholder Plan of Distribution section accordingly.

In response to the Staff’s
comment, the Company respectfully confirms the Company’s understanding that the retention by a selling shareholder of an
underwriter would constitute a material change to the plan of distribution requiring a post-effective amendment and has revised the
disclosure on page Alt-4 of Revised Registration Statement accordingly.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank you again
for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Michael J. Blankenship, Winston & Strawn LLP

September 20, 2024
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 13 to Registration Statement on Form F-1
Filed September 11, 2024
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our April 15, 2024 letter.
Amendment No. 13 to Registration Statement on Form F-1, Filed September 11, 2024
General
Please refer to the Selling Shareholders Plan of Distribution section on page Alt-4.  We
note your disclosure that a selling shareholder may use any one or more methods
which include "purchases by a broker-dealer as principal and resale by the broker-
dealer for its account" and that "[t]o the extent required,... the name of the Selling
Shareholder, the respective purchase prices and public offering prices, the names of any
agents, dealer or underwriter, any applicable commissions or discounts with respect to a
particular offer will be set forth in an accompanying prospectus supplement or, if
appropriate, a post-effective amendment to the registration statement that includes this
prospectus."  Please confirm your understanding that the retention by a selling shareholder
of an underwriter would constitute a material change to your plan of distribution requiring 1.

September 20, 2024
Page 2
a post-effective amendment.  Refer to your undertaking provided pursuant to Item
512(a)(1)(iii) of Regulation S-K.  Lastly, please revise the Selling Shareholder Plan of
Distribution section accordingly.
            Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Lan Lou

CORRESP
1
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Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-917) 672-3642

VIA EDGAR

April 26, 2024

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian,

    Re:
    Creative Global Technology Holdings Ltd (the “Company”)

Amendment No.9 to Registration Statement on
Form F-1

Filed on April 8, 2024

CIK No. 0001967822

Ladies and Gentlemen:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comments contained in the Staff’s letter dated April 15, 2024 (the “Comment Letter”) on the Company’s
Amendment No.9 to Registration Statement on Form F-1 filed on April 8, 2024 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No.10 to Registration Statement (the “Revised Registration Statement”). The
Company has responded to all of the Staff’s comment by revising the Registration Statement to address the comments, or by providing
an explanation if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment
Letter is printed below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth
below refer to the page numbers in the Revised Registration Statement.

Resale Prospectus, page Alt-1

    1.

    We note your response to prior comment 1 and
    reissue in part. With respect to the resale offering:

    ● We note your explanation as to why
    you have kept the language “concurrent” in footnote 1 on page Alt-1 and footnote 1 on page Alt-3; however, since the sale
    of secondary shares cannot proceed until after a market is created by the primary offering, please amend the disclosure so the distinction
    is clearer.

    In response to the Staff’s comment, the
    Company has revised the disclosures on pages Alt-1 and Alt-3 to delete reference to the primary and secondary offerings of the ordinary
    shares of the Company (the “Ordinary Shares”) being conducted “concurrently”.

    ● Please amend footnote 3 on page
    Alt-3 to clarify that Mr. Hong is the beneficial owner of the shares held by CHSZ Holdings Limited and that, after the offerings,
    Mr. Hong will continue to control a substantial number of ordinary shares due to his beneficial ownership of shares held by HSZ
    Holdings Limited and CHSZ Holdings Limited.

    In response to the Staff’s comment,
    the Company has revised the disclosure on page Alt-3 to disclose that Mr. Hong is the beneficial owner of the Ordinary Shares held
    by CHSZ Holdings Limited (the “Selling Shareholder”) and that, after the primary offering and the secondary offering of
    the Ordinary Shares, Mr. Hong will continue to control a substantial number of Ordinary Shares due to his beneficial ownership of
    the Ordinary Shares held by HSZ Holdings Limited and CHSZ Holdings Limited.

    ● Please advise why HSZ Holdings Limited
    transferred 2,000,000 ordinary shares and 1,000,000 ordinary shares to CHSZ Holdings Limited in December 2023 and February 2024, respectively.
    Additionally, please advise if these transfers were in anticipation of this offering.

    In response to the Staff’s comment, the
Company respectfully advises the Staff that HSZ Holdings Limited transferred 2,000,000 ordinary shares and 1,000,000 ordinary shares to
CHSZ Holdings Limited (the “Share Transfers”) for Mr. Hong’s private wealth planning purposes. By keeping the registered
resale shares in a separate entity, Mr. Hong will have more flexibility in his personal wealth management, such as setting up a family
trust regarding the Ordinary Shares held by CHSZ Holdings Limited, the Selling Shareholder. Mr. Hong will also be able to accomplish his
personal wealth management goals and receive compensation for his past years’ contributions to the Company through the resale of Ordinary
Shares registered in the resale offering. After the Share Transfers, Mr. Hong will retain his controlling shareholding in the Company
through HSZ Holdings Limited and such controls of shareholding will not be part of the personal wealth management plan.

    The Company further respectfully advises the Staff
    that the Share Transfers were in anticipation of the resale offering of the Ordinary Shares.

    ● Please advise whether the resale
    of offering is required to satisfy the listing requirements of the Cboe BZX Exchange. Additionally, we note that the structure of
    this offering (primary and resale) has changed over time. In this regard, we note that a resale component was added, your
    underwriters changed, the listing exchange changed, the amount of ordinary shares with respect to the resale offering increased.
    Please advise what considerations factored into the structure changes and whether satisfying any listing requirements of either
    Nasdaq or Cboe BZX Exchange played a role in how this offering was structured, i.e. the size and amounts of the respective
    offering.

    In response to the Staff’s comment,
    the Company respectfully advises the Staff that the resale offering is not required for the Company to satisfy the listing
    requirements of the Cboe BZX Exchange (“Cboe”). The Company’s primary offering is expected to meet the Net Income
    Standard (Tier II) under Cboe Rule 14.9(b)(2)(C). The offering of 1,250,000 Ordinary Shares in the primary offering will meet
    Cboe’s minimum requirement of the number of publicly held shares of 1 million shares. The expected offering size of $5
    million will meet Cboe’s minimum requirement of the market value of publicly held shares. The Company’s net income of
    approximately $3.2 million for the year ended September 30, 2023 meets Cboe’s minimum net income requirement of $750,000 in
    the most recently completed fiscal year. The Company’s total shareholder’s equity of approximately $9.2 million for the
    year ended September 30, 2023 meets Cboe’s minimum shareholder’s equity requirement of $4 million.

    2

      On
    October 20, 2023, the primary offering size was decreased from 4,000,000 Ordinary Shares to 2,000,000 Ordinary Shares because of the change
    of market sentiment. On January 16, 2024, a resale secondary offering of 2,000,000 was added. Mr.
    Hong deems it in the interest of the Company and the investors to retain the cash with the Company and intends to receive compensation
    for his past years’ contributions through the sale of the resale shares. In addition, the Company believes that including the resale
    offering in the registration statement provides important information about the Company in a single document, which allows potential investors
    who may be interested in both the primary offering and the resale offering to make informed investment decisions. Moreover, the Company
    believes that the registration of the resale offering provides flexibility to the Selling Shareholder to sell its shares immediately after
    the Company’s initial public offering or wait until a favorable market condition develops, while saving the extra cost of filing
    a separate resale registration statement. On March 4, 2024, the size of secondary offering increased
    from 2,000,000 to 3,000,000 Ordinary Shares based on Mr. Hong’s further assessment about his personal wealth management plan. On
    March 22, 2024, the primary offering size was decreased from 2,000,000 to 1,250,000 because of Company’s
    further concern over the market conditions.

The Company submitted its application materials
with Nasdaq Capital Market (“Nasdaq”) on April 27, 2023. At that time, the underwriter of the Company was Revere Securities
LLC (“Revere”). The Company changed its underwriter from Revere to Prime Number Capital, LLC (“Prime Number”)
on September 28, 2023 due to the expiration of the engagement between the Company and Revere. After the change of the underwriter, Prime
Number introduced the Company to Cboe. During the first meeting among Cboe, Prime Number and the Company, Cboe provided a comprehensive
introduction of itself and the Company found Cboe to be a very attractive listing venue with cheaper maintaining cost after listing, high
liquidity, and global access to capital. After the meeting, the Company decided to withdraw its application from Nasdaq and submitted
the listing application to Cboe. Subsequently, on April 22, 2024, the Company selected Alexander Capital, L.P. to serve as the lead underwriter
due to its unique position, stemming from its recent success in closing initial public offerings of companies listed on Cboe.

The Company further respectfully advises the
Staff that the market condition and sentiment, Mr. Hong’s personal wealth management plans, and the business growth strategies
of the Company in general are the considerations factored into the structure changes. Satisfying listing requirements of either
Nasdaq or Cboe did not play a role in how this offering was structured, i.e. the size and amounts of the respective offering. Either
the Company’s current offering structure or its historical offering structure meets the Net Income Standard under Nasdaq Rules
5505(a) and 5505(b)(3). The offering of 1,250,000 shares of Ordinary Shares in the primary offering will meet Nasdaq’s minimum
requirement of the number of publicly held shares of 1 million shares. The expected primary offering size of $5 million will meet
Nasdaq’s minimum requirement of the market value of unrestricted publicly held shares. The Company’s net income of
approximately $3.2 million for the year ended September 30, 2023 meets Nasdaq’s minimum net income requirement of $750,000 in
the latest fiscal year. The Company’s total shareholder’s equity of approximately $9.2 million for the year ended
September 30, 2023 meets Nasdaq’s minimum shareholder’s equity requirement of $4 million. In addition, as described
above, Company’s primary offering will also satisfy the listing requirements of Cboe.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank you again
for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Michael J. Blankenship, Winston & Strawn LLP

3

United States securities and exchange commission logo
April 15, 2024
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 9 to Registration Statement on Form F-1
Filed April 8, 2024
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our April 3, 2024 letter.
Amendment No. 9 to Registration Statement on Form F-1
Resale Prospectus, page Alt-1
1.We note your response to prior comment 1 and reissue in part. With respect to the resale
offering:
•We note your explanation as to why you have kept the language "concurrent" in
footnote 1 on page Alt-1 and footnote 1 on page Alt-3; however, since the sale of
secondary shares cannot proceed until after a market is created by the primary
offering, please amend the disclosure so the distinction is clearer.
•Please amend footnote 3 on page Alt-3 to clarify that Mr. Hong is the beneficial
owner of the shares held by CHSZ Holdings Limited and that, after the offerings, Mr.
Hong will continue to control a substantial number of ordinary shares due to his
beneficial ownership of shares held by HSZ Holdings Limited and CHSZ Holdings

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 April 15, 2024 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
April 15, 2024
Page 2
Limited.
•Please advise why HSZ Holdings Limited transferred 2,000,000 ordinary shares and
1,000,000 ordinary shares to CHSZ Holdings Limited in December 2023 and
February 2024, respectively. Additionally, please advise if these transfers were in
anticipation of this offering.
•Please advise whether the resale offering is required to satisfy the listing
requirements of the Cboe BZX Exchange. Additionally, we note that the structure of
this offering (primary and resale) has changed over time. In this regard, we note that a
resale component was added, your underwriters changed, the listing exchange
changed, the amount of ordinary shares with respect to the primary offering
decreased and the amount of ordinary shares with respect to the resale offering
increased. Please advise what considerations factored into the structure changes and
whether satisfying any listing requirements of either Nasdaq or Cboe BZX Exchange
played a role in how this offering was structured, i.e. the size and amounts of the
respective offerings.

            Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou

CORRESP
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Suite
1919, 45 Rockefeller Plaza

630
Fifth Avenue

New
York, NY 10111, USA

T:
(1-737) 215-8491

F:
(1-917) 672-3642

junheny@junhe.com

VIA
EDGAR

April
8, 2024

Division
of Corporation Finance

Office
of Trade & Services

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Nicholas Nalbantian,

    Re:
    Creative
    Global Technology Holdings Ltd (the “Company”)

Amendment
No.8 to Registration Statement on Form F-1

Filed
on March 22, 2024

CIK
No. 0001967822

Ladies
and Gentlemen:

On
behalf of our client, Creative Global Technology Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands,
we are submitting to the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”)
this letter setting forth the Company’s responses to the comment contained in the Staff’s letter dated April 3, 2024 (the
“Comment Letter”) on the Company’s Amendment No.8 to Registration Statement on Form F-1 filed on March 22, 2024 (the
“Registration Statement”).

Concurrently
with the submission of this letter, the Company is submitting via EDGAR Amendment No.9 to Registration Statement (the “Revised
Registration Statement”). The Company has responded to all of the Staff’s comment by revising the Registration Statement
to address the comment, or by providing an explanation if the Company has not so revised the Registration Statement. For ease of reference,
each comment contained in the Comment Letter is printed below in bold, followed by the Company’s responses to such comment. All
page references in the responses set forth below refer to the page numbers in the Revised Registration Statement.

Quantitative
and Qualitative Disclosures about Market Risks

Resale
Prospectus, page Alt-1

    1.

    We note the reduction of the primary offering
    from 2,000,000 Ordinary Shares to 1,250,000 Ordinary Shares. We also note that the Resale Prospectus accounts for 3,000,000 Ordinary Shares.
    As a result, with respect to the resale offering:

    ● Revise to delete references to the primary
    and secondary offerings being conducted “concurrently,” as it appears that the resale offering will begin only once your Ordinary
    Shares are listed and the initial public offering is complete.

    In response to the Staff’s comment, the
    Company respectfully advises the Staff that the resale shares will begin trading upon the listing of the Company’s Ordinary Shares,
    which is simultaneous with the primary offering. Therefore, the Company believes that “concurrently” is an accurate description
    of the relationship between primary offering and resale offering.

    ● Disclose any natural persons that control
    the selling shareholder and any position, office, or other material relationship which the selling shareholder has had with the registrant
    or any of its predecessors or affiliates within three years prior to the filing of the registration statement. Refer to Item 507 of Regulation
    S-K.

    In response to the Staff’s comment, the
    Company has revised the disclosure on page Alt-3 to disclose the natural person that controls CHSZ Holdings Limited (“CHSZ Holdings”
    or the “Selling Shareholder”) and such natural person’s position, office, and other material relationship with the registrant
    or any of its predecessors or affiliates within three years prior to the filing of the registration statement.

    ● Disclose
    in greater detail the circumstances under which the selling shareholder received the shares covered by the resale offering, as well as
    how long the selling shareholder has held such shares. Specifically, how long HSZ Holdings Limited held the shares covered by the resale
    offering prior to transferring the shares to CHSZ Holdings Limited.

    In response to the Staff’s comment, the
    Company has revised the disclosure on page Alt-3 to disclose in greater detail the circumstances under which the Selling Shareholder received
    the shares covered by the resale offering, as well as how long the Selling Shareholder has held such shares, specifically, how long HSZ
    Holdings Limited held the shares covered by the resale offering prior to transferring the shares to CHSZ Holdings Limited.

    ● Advise
    why the resale offering is required to be registered at this time.

    In response to the Staff’s comment, the Company respectfully advises the Staff that the resale shares are registered at this time
for the following reasons. Since Mr. Shangzhao (“Cizar”) Hong, the sole shareholder of the Selling Shareholder, started Creative
Global Technology Limited (“CGTHK”), the Hong Kong operating subsidiary of the Company formed in 2016, CGTHK did not declare
any dividends despite it has been profitable. Mr. Hong deems it in the interest of the Company and the investors to retain the cash with
the Company and intends to receive compensation for his past years’ contributions through the sale of the resale shares. In addition,
the Company believes that including the resale offering in the registration statement provides important information about the Company
in a single document, which allows potential investors who may be interested in both the primary offering and the resale offering to make
informed investment decisions. Moreover, the Company believes that the registration of the resale offering provides flexibility to the
Selling Shareholder to sell its shares concurrently with the Company’s initial public offering or wait until a favorable market
condition develops, while saving the extra cost of filing a separate resale registration statement. The resale offering by the Selling
Shareholder will also result in higher public float of the Company.

    2

    ● Advise
    how you determined the number of Ordinary Shares being registered in connection with the resale offering.

    In response to the Staff’s comment, the
    Company respectfully advises the Staff that the Company and the Selling Shareholder determined the number of Ordinary Shares registered
    in the resale offering after taking into consideration factors including the market condition, the expected gain of the Selling Shareholder,
    and the future profitability of the Company.

    ● Advise
    how the selling shareholder was selected to participate in this resale offering and why the selling shareholder who is a greater than
    5% shareholder has been excluded from the lock-up.

    In response to the Staff’s comment, the
    Company respectfully advises the Staff that the Company and the Selling Shareholder negotiated a customized lock-up agreement with Prime
    Number Capital LLC to allow only those Ordinary Shares sold in the resale offering by the Selling Shareholder excluded from the lock-up
    arrangement. This customized lock-up arrangement is designed to allow Mr. Shangzhao (“Cizar”) Hong, through the Selling Shareholder,
    to receive compensation for all his past years contributions to the Company.

    ● Lastly,
    advise why the resale offering should not be deemed an indirect primary being conducted by or on behalf of the issuer. Refer to Question
    612.09 of the Securities Act Rules Compliance and Disclosure Interpretations.

    In response to the Staff’s comment, the Company respectfully advises the Staff that it believes that the resale offering should
not be deemed as an indirect primary offering being conducted by or on behalf of the issuer. The Selling Shareholder does not intend to
nor will act as a conduit for the issuer. In 2016, the sole shareholder of the Selling Shareholder, Mr. Shangzhao (“Cizar”)
Hong, started CGTHK, the operating entity conducting substantially all of the Company’s business operations. Mr. Hong had been CGTHK’s
sole shareholder since 2020, until a reorganization in March 2023 (the “Reorganization”), where CGT Holdings became the 100%
owner of CGTHK through a holding intermediary and the ultimate sole shareholder of the Company. Mr. Hong served as the sole director of
CGTHK since 2020, and the CEO of the Company after the Reorganization. Mr. Hong has decided to sell some of his Ordinary Shares in the
resale offering as compensation for his contributions to the Company and its subsidiaries. Mr. Hong has the ultimate ownership of the
Resale Shares and no new Ordinary Shares will be issued or offered in the resale offering. Consequently, the Selling Shareholder, instead
of the Company, will receive all the proceeds in the resale offering. Lastly, Mr. Hong has never been in the business of underwriting
securities, and no underwriter has been engaged, nor will any party including the Selling Shareholder receive commission in the resale
offering. For the reasons above, the Company believes that the resale offering should not be deemed an indirect primary offering under
Question 612.09 of the Securities Act Rules Compliance and Disclosure Interpretations.

If
you have any questions regarding this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank
you again for your time and attention.

    Yours
    sincerely,

    /s/
    Lan Lou

    Lan
    Lou

    Partner

    Jun
    He Law Offices LLC

cc:

Shangzhao
(“Cizar”) Hong, Director and Chief Executive Officer, Creative Global

Technology
Holdings Limited

Edward
Chen, Partner, Wei, Wei & Co.

Michael
J. Blankenship, Winston & Strawn LLP

3

United States securities and exchange commission logo
April 3, 2024
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 8 to Registration Statement on Form F-1
Filed March 22, 2024
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our January 26, 2024 letter.
Amendment No. 8 to Registration Statement on Form F-1 Filed March 22, 2024
Resale Prospectus, page Alt-1
1.We note the reduction of the primary offering from 2,000,000 Ordinary Shares to
1,250,000 Ordinary Shares. We also note that the Resale Prospectus accounts for
3,000,000 Ordinary Shares. As a result, with respect to the resale offering:
•Revise to delete references to the primary and secondary offerings being conducted
"concurrently," as it appears that the resale offering will begin only once your
Ordinary Shares are listed and the initial public offering is complete.
•Disclose any natural persons that control the selling shareholder and any position,
office, or other material relationship which the selling shareholder has had with the
registrant or any of its predecessors or affiliates within three years prior to the filing
of the registration statement. Refer to Item 507 of Regulation S-K.

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 April 3, 2024 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
April 3, 2024
Page 2
•Disclose in greater detail the circumstances under which the selling shareholder
received the shares covered by the resale offering, as well as how long the selling
shareholder has held such shares. Specifically, how long HSZ Holdings Limited held
the shares covered by the resale offering prior to transferring the shares to CHSZ
Holdings Limited.
•Advise why the resale offering is required to be registered at this time.
•Advise how you determined the number of Ordinary Shares being registered in
connection with the resale offering.
•Advise how the selling shareholder was selected to participate in this resale offering
and why the selling shareholder who is a greater than 5% shareholder has been
excluded from the lock-up.
•Lastly, advise why the resale offering should not be deemed an indirect primary
being conducted by or on behalf of the issuer. Refer to Question 612.09 of the
Securities Act Rules Compliance and Disclosure Interpretations.
            Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou

CORRESP
1
filename1.htm

Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-917) 672-3642

junheny@junhe.com

VIA EDGAR

January 30, 2024

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian,

    Re:
    Creative Global Technology Holdings Ltd (the “Company”)

Amendment No.4 to Registration Statement on
Form F-1

Filed on January 16, 2024

CIK No. 0001967822

Ladies and Gentlemen:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated January 26, 2024 (the “Comment Letter”) on the Company’s
Amendment No.4 to Registration Statement on Form F-1 filed on January 16, 2023 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No.5 to Registration Statement (the “Revised Registration Statement”). The Company
has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation
if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed
below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to
the page numbers in the Revised Registration Statement.

Quantitative and Qualitative Disclosures
about Market Risks

Foreign Currency Exchange Risk, page 72

    1.
    We note your references to American Depositary Shares. However, the rest of your registration statement discloses the registration of ordinary shares. Please amend your

registration statement to clarify this discrepancy.

In response to the Staff’s comment,
the Company has revised the disclosures on page 72 of the Revised Registration Statement.

    2.
    We
    note that the Resale Prospectus Summary contemplates the same offering price range as the Prospectus Cover Page. Please confirm the
    price range within which the selling shareholder will offer its ordinary shares and revise the Resale Prospectus Cover Page as
    applicable. Refer to Item 501(b)(3) of Regulation S-K. In the alternative, please revise and confirm that the selling
    shareholder will not make any offers or sales until the ordinary shares are listed on Nasdaq, and revise your Resale Prospectus
    Cover Page to clarify that such selling shareholder will then sell its ordinary shares at market prices once trading of your
    ordinary shares begins. Lastly, please revise the Resale Prospectus Summary and Selling Shareholder Plan of Distribution
    sections to align with the Resale Prospectus Cover Page which details that the offering is contingent on the company’s Nasdaq
    listing.

In response to the Staff’s comment, the Company confirms that the selling shareholder will not make any offers or sales until the
ordinary shares are listed on Nasdaq and has revised the disclosures on the Resale Prospectus Cover Page, Alt-1, and Alt-4 accordingly.
The Company has also revised the disclosures on the Resale Prospectus Cover Page to clarify that the selling shareholder will then sell
its ordinary shares at market prices once trading of the Company’s ordinary shares begins. The Company has also revised the disclosures
on pages Alt-1 and Alt-4 of the Revised Registration Statement to reflect that the offering is contingent on the Company’s Nasdaq
listing.

    3.
    We
    note that the disclosure describing the exemptions to the Nasdaq corporate governance rules deviate between the Prospectus Cover
    Page and the Resale Prospectus Cover Page. Please reconcile.

In response to the Staff’s comment,
the Company has revised the disclosures on the Resale Prospectus Cover Page of the Revised Registration Statement.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank you again
for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Michael J. Blankenship, Winston & Strawn LLP

United States securities and exchange commission logo
January 26, 2024
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 4 to Registration Statement on Form F-1
Filed January 16, 2024
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our October 31, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1, Filed January 16, 2024
Quantitative and Qualitative Disclosures about Market Risks
Foreign Currency Exchange Risk, page 72
1.We note your references to American Depositary Shares. However, the rest of your
registration statement discloses the registration of ordinary shares. Please amend your
registration statement to clarify this discrepancy.
Resale Prospectus Alternate Page
Cover Page, page A-1
2.We note that the Resale Prospectus Summary contemplates the same offering price range
as the Prospectus Cover Page. Please confirm the price range within which the selling

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 January 26, 2024 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
January 26, 2024
Page 2
shareholder will offer its ordinary shares and revise the Resale Prospectus Cover Page as
applicable. Refer to Item 501(b)(3) of Regulation S-K. In the alternative, please revise and
confirm that the selling shareholder will not make any offers or sales until the ordinary
shares are listed on Nasdaq, and revise your Resale Prospectus Cover Page to clarify that
such selling shareholder will then sell its ordinary shares at market prices once trading of
your ordinary shares begins. Lastly, please revise the Resale Prospectus Summary and
Selling Shareholder Plan of Distribution sections to align with the Resale Prospectus
Cover Page which details that the offering is contingent on the company's Nasdaq listing.
3.We note that the disclosure describing the exemptions to the Nasdaq corporate governance
rules deviate between the Prospectus Cover Page and the Resale Prospectus Cover Page.
Please reconcile.
            Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou

CORRESP
1
filename1.htm

Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-917) 672-3642

junheny@junhe.com

VIA EDGAR

November 3, 2023

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian

 Re: Creative
Global Technology Holdings Ltd (the “Company”)

Amendment No.2 to Registration Statement on
Form F-1

Filed on October 20, 2023

CIK No. 0001967822

Dear Mr. Nalbantian:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated October 31, 2023 (the “Comment Letter”) on the Company’s
Amendment No.2 to Registration Statement on Form F-1 filed on October 20, 2023 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No.3 to Registration Statement (the “Revised Registration Statement”). The Company
has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation
if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed
below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to
the page numbers in the Revised Registration Statement.

Item 8. Exhibits and Financial Statement
Schedules, page II-2

 1. Please update your financial statements in accordance with
Item 8.A.4. of Form 20-F or include the representation noted in the Instruction to Item 8.A.4:2. as an exhibit to your registration statement.

In response to the Staff’s comment,
the Company has filed a Request for Waiver and Representation under Item 8.A.4 of Form 20-F as Exhibit 99.8 to the Registration Statement.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank you again
for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Michael J. Blankenship, Winston & Strawn LLP

United States securities and exchange commission logo
October 31, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed October 20, 2023
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended registration statement and have the following comment.
            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. Unless we note otherwise,
any references to prior comments are to comments in our August 29, 2023 letter.
Amendment No. 2 to Form F-1 filed October 20, 2023
Item 8. Exhibits and Financial Statement Schedules, page II-2
1.Please update your financial statements in accordance with Item 8.A.4. of Form 20-F or
include the representation noted in the Instruction to Item 8.A.4:2. as an exhibit to your
registration statement.

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 October 31, 2023 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
October 31, 2023
Page 2
            Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou

CORRESP
1
filename1.htm

Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-917) 672-3642

junheny@junhe.com

VIA EDGAR

October 20, 2023

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian

    Re:
    Creative Global Technology Holdings Ltd (the “Company”)

Amendment No.1 to Registration Statement on
Form F-1

Filed on August 14, 2023

CIK No. 0001967822

Dear Mr. Nalbantian:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated August 29, 2023 (the “Comment Letter”) on the Company’s
Amendment No.1 to Registration Statement on Form F-1 filed on August 14, 2023 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No.2 to Registration Statement (the “Revised Registration Statement”). The Company
has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation
if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed
below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to
the page numbers in the Revised Registration Statement.

General

    1.

    We note the changes you made to your disclosure appearing on
the prospectus cover page, Prospectus Summary and Risk Factor sections relating to legal and operational risks associated with PRC laws
and regulations and how they apply in Hong Kong. It is unclear to us that there have been changes in the regulatory environment in Hong
Kong and the PRC since the amendment that was filed on July 19, 2023, warranting revised disclosure to mitigate the challenges you face
and related disclosures. The Sample Letters to China Based Companies sought specific disclosure relating to the risk that the PRC government
may intervene in or influence your operations at any time, or may exert control over operations of your business, which could result
in a material change in your operations and/or the value of the securities you are registering for sale. We remind you that, pursuant
to federal securities rules, the term “control” (including the terms “controlling,” “controlled by,”
and “under common control with”) as defined in Securities Act Rule 405 means “the possession, direct or indirect, of
the power to direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities,
by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to uncertainties regarding the enforcement
of laws and that the rules and regulations in China can change quickly with little advance notice. We do not believe that your revised
disclosure removing references to the PRC government conveys the same risks. Please restore your disclosures in these areas to the disclosures
as they existed in the registration statement as of July 19, 2023.

In response to the Staff’s
comment, the Company has restored the disclosures appearing on the prospectus cover page, Prospectus Summary, and Risk Factor
sections relating to legal and operational risks associated with PRC laws and regulations and how they apply in Hong Kong to the
disclosures as they existed in the registration statement as of July 19, 2023.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank you again
for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Michael J. Blankenship, Winston & Strawn LLP

United States securities and exchange commission logo
August 29, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed August 14, 2023
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 28, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1
General
1.We note the changes you made to your disclosure appearing on the prospectus cover page,
Prospectus Summary and Risk Factor sections relating to legal and operational risks
associated with PRC laws and regulations and how they apply in Hong Kong.  It is unclear
to us that there have been changes in the regulatory environment in Hong Kong and the
PRC since the amendment that was filed on July 19, 2023, warranting revised disclosure
to mitigate the challenges you face and related disclosures. The Sample Letters to China-
Based Companies sought specific disclosure relating to the risk that the PRC government
may intervene in or influence your operations at any time, or may exert control over

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 August 29, 2023 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
August 29, 2023
Page 2
operations of your business, which could result in a material change in your operations
and/or the value of the securities you are registering for sale. We remind you that,
pursuant to federal securities rules, the term “control” (including the terms “controlling,”
“controlled by,” and “under common control with”) as defined in Securities Act Rule 405
means “the possession, direct or indirect, of the power to direct or cause the direction of
the management and policies of a person, whether through the ownership of voting
securities, by contract, or otherwise.”  The Sample Letters also sought specific disclosures
relating to uncertainties regarding the enforcement of laws and that the rules and
regulations in China can change quickly with little advance notice.  We do not believe that
your revised disclosure removing references to the PRC government conveys the same
risks.  Please restore your disclosures in these areas to the disclosures as they existed in
the registration statement as of July 19, 2023.
            You may contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336
if you have questions regarding comments on the financial statements and related
matters.  Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-
3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou

CORRESP
1
filename1.htm

Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-917) 672-3642

junheny@junhe.com

VIA EDGAR

August 14, 2023

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian

    Re:
    Creative Global Technology Holdings Ltd (the “Company”)

Registration Statement on Form F-1

Filed on July 19, 2023

CIK No. 0001967822

Dear Mr. Nalbantian:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated July 28, 2023 (the “Comment Letter”) on the Company’s
Registration Statement on Form F-1 filed on July 19, 2023 (the “Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting via EDGAR Amendment No.1 to Registration Statement (the “Revised Registration Statement”). The Company
has responded to all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation
if the Company has not so revised the Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed
below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to
the page numbers in the Revised Registration Statement.

Capitalization, page 58

    1.

    Please tell us how you considered the
    underwriting discounts and commissions and estimated offering expense payable by you when determining as adjusted additional paid in
    capital.

In response to the Staff’s comment,
the Company has revised the disclosure on page 58 of the Revised Registration Statement. The underwriting discounts and commission and
estimated expenses will be deducted from additional paid-in capital.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank you again
for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Fang Liu, Partner, VCL Law LLP

United States securities and exchange commission logo
July 28, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Registration Statement on Form F-1
Filed July 19, 2023
File No. 333-273329
Dear Shangzhao Hong:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1
Capitalization, page 58
1.Please tell us how you considered the underwriting discounts and commissions and
estimated offering expense payable by you when determining as adjusted additional paid
in capital.
            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

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 July 28, 2023 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
July 28, 2023
Page 2
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters.  Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-
3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
filename1.htm

Suite 1919, 45 Rockefeller Plaza

630 Fifth Avenue

New York, NY 10111, USA

T: (1-737) 215-8491

F: (1-917) 672-3642

junheny@junhe.com

VIA EDGAR

July 19, 2023

Division of Corporation Finance

Office of Trade & Services

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nicholas Nalbantian

Re: Creative
Global Technology Holdings Ltd (the “Company”)

Amendment No.1 to Draft Registration Statement
on Form F-1

Submitted June 5, 2023

CIK No. 0001967822

Dear Mr. Nalbantian:

On behalf of our client, Creative Global Technology
Holdings Ltd (the “Company”), a company incorporated in the Cayman Islands, we are submitting to the Staff of the Division
of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting forth the Company’s
responses to the comment contained in the Staff’s letter dated June 15, 2023 (the “Comment Letter”) on the Company’s
Amendment No.1 to Draft Registration Statement on Form F-1 confidentially submitted on June 5, 2023 (the “Draft Registration Statement”).
The Company confirms that it will publicly file its registration statement and nonpublic draft submissions at least 15 days prior to any
road show or the requested effective date of the registration statement.

Concurrently with the submission of this letter,
the Company is submitting via EDGAR the Registration Statement (the “Registration Statement”). The Company has responded to
all of the Staff’s comment by revising the Registration Statement to address the comment, or by providing an explanation if the
Company has not so revised the Draft Registration Statement. For ease of reference, each comment contained in the Comment Letter is printed
below in bold, followed by the Company’s responses to such comment. All page references in the responses set forth below refer to
the page numbers in the Revised Draft Registration Statement.

PRC Related Regulations Related to this
Offering, page 11

    1.
    We
    note your response to comments 8 and 14 and reissue in part. We acknowledge your new disclosure stating that according to
    “the legal advice” of JunHe LLP. Please clarify, if true, whether you have received an opinion of counsel from JunHe
    LLP. If you have not relied upon an opinion of counsel with respect to your conclusions, state as much and explain why such an
    opinion was not obtained.

In response to the Staff’s comment,
the Company has revised the disclosure on page 11 of the Registration Statement that the Company relied on the legal opinion of JunHe
LLP.

If you have any questions regarding
this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank
you again for your time and attention.

    Yours sincerely,

    /s/ Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Shangzhao (“Cizar”) Hong, Director and Chief Executive
Officer, Creative Global

Technology Holdings Limited

Edward Chen, Partner, Wei, Wei & Co.

Fang Liu, Partner, VCL Law LLP

United States securities and exchange commission logo
June 15, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted June 5, 2023
CIK No. 0001967822
Dear Shangzhao Hong:
            We have reviewed your amended draft registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our 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 comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted June 5, 2023
PRC Related Regulations Related to this Offering, page 11
1.We note your response to comments 8 and 14 and reissue in part. We acknowledge your
new disclosure stating that according to "the legal advice" of JunHe LLP. Please clarify, if
true, whether you have received an opinion of counsel from JunHe LLP. If you have not
relied upon an opinion of counsel with respect to your conclusions, state as much and
explain why such an opinion was not obtained.

 FirstName LastNameShangzhao Hong
 Comapany NameCreative Global Technology Holdings Ltd
 June 15, 2023 Page 2
 FirstName LastName
Shangzhao Hong
Creative Global Technology Holdings Ltd
June 15, 2023
Page 2
            You may contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336
if you have questions regarding comments on the financial statements and related
matters.  Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou

United States securities and exchange commission logo
May 17, 2023
Shangzhao Hong
Chief Executive Officer
Creative Global Technology Holdings Ltd
Unit 03, 22/F, Westin Centre
26 Hung To Road, Kwun Tong
Kowloon, Hong Kong
Re:Creative Global Technology Holdings Ltd
Draft Registration Statement on Form F-1
Submitted April 21, 2023
CIK No. 0001967822
Dear Shangzhao Hong:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 Submitted April 21, 2023
Cover Page
1.We note your disclosure that following the offering, Mr. Hong will carry a majority of the
voting power of the company and that the company will be a "controlled company."
Please revise the cover page to disclose the percentage of voting power to be held by
Mr. Hong following the offering and, if true, that Mr. Hong will have the ability to
determine all matters requiring approval by stockholders.
2.Your disclosure should acknowledge that Chinese regulatory authorities could disallow
your holding company structure, which would likely result in a material change in your

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Page 2
operations and/or a material change in the value of the securities you are registering for
sale, including that it could cause the value of such securities to significantly decline or
become worthless.
3.Please discuss on the cover page and risk factor section the applicable laws and
regulations in Hong Kong as well as the related risks and consequences. Examples of
applicable laws and regulations include, but are not limited to, are:
•Enforceability of civil liabilities in Hong Kong;
•Disclose on the cover page how regulatory actions related to data security or
antimonopoly concerns in Hong Kong have or may impact the company’s ability to
conduct its business, accept foreign investment or list on a U.S./foreign exchange;
and
•Include risk factor disclosure explaining whether there are laws/regulations in Hong
Kong that result in oversight over data security, how this oversight impacts the
company’s business and the offering, and to what extent the company believes that it
is compliant with the regulations or policies that have been issued.
4.Please amend your disclosure here and in the summary risk factors and risk factors
sections to state that, to the extent cash or assets in the business is in Hong Kong or a
Hong Kong entity, the funds or assets may not be available to fund operations or for other
use outside of Hong Kong due to interventions in or the imposition of restrictions and
limitations on the ability of you or your subsidiaries by the PRC government to transfer
cash or assets. On the cover page, provide cross-references to these other discussions.
Prospectus Summary
Corporate History and Structure, page 1
5.Identify clearly the entity in which investors are purchasing their interest and the entity in
which the company’s operations are conducted, similar to your disclosure on the cover
page.
Wholesale of Pre-Owned Consumer Electronic Devices Business, page 2
6.Please revise to balance any revenue discussion with a discussion of your total revenues
and net income or loss (for similar periods) as reflected in the included financial
statements.
Summary of Risks Associated with our Business
Risks Related to Doing Business in Hong Kong, page 6
7.In addition to the existing summary bullets in this sub-section, please also include specific
cross-references (title and page number) to the risk factors summarized in each bullet,
rather than a generalized cross-reference to page 35 of your registration statement.

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PRC Related Regulations Related to this Offering, page 9
8.We note that you do not appear to have relied upon an opinion of counsel with respect to
your conclusions that you do not need any permissions and approvals to offer securities to
investors.  If true, state as much and explain why such an opinion was not obtained.
9.We note your disclosure concluding that you are not subject to the disclosed PRC
authorities' capital markets regulations. In addition to this disclosure, please also include
disclosure discussing the possible ramifications if you did become subject to such PRC
laws/authorities, similar to your disclosure on the cover page.
Risk Factors, page 14
10.We note your disclosure on page 2, and elsewhere, in the registration statement that you
rely on maintaining a lean inventory. We also note your risk factor on page 20 that failing
to manage your inventory effectively is a material risk. However, please also disclose the
risks of how an incident or disruption in your supply chain could impact your business and
operations due to this reliance on maintaining a lean inventory and any disruptions you
have experienced due to such reliance.
Risks Related to our Business, page 14
11.We note your risk factor on page 31 addressing, amongst other things, your lack of
sufficiently U.S. GAAP skilled staff and on page 33 management's lack of public
company experience. Please include a risk factor addressing your lack of experience
complying with public company ongoing reporting requirements and the negative impact
this could have on your business.
If we are unable to maintain our existing customer base and attract new customers, our business,
financial condition and results of..., page 15
12.You state in this risk factor that the public perception that pre-owned electronic consumer
goods may be counterfeit or defective is "factually incorrect or based on isolated
incidents." We also note that on page 17 you have a risk factor stating that counterfeit
items is a material risk to your business. Please clarify the discrepancy that the impression
that pre-owned electronic consumer goods being counterfeit or defective is "factually
incorrect" with your disclosure that counterfeit consumer electronics are a material risk to
your business.

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The relative lack of public company experience of our management team may put us at a
competitive disadvantage., page 33
13.We note your disclosure that your senior management team "does not have much"
experience managing a publicly traded company. However, we note that your
Management section biographies contain no disclosure of U.S. public company
experience. Please clarify this discrepancy or clarify that the current senior management
team has no U.S. public company experience.
Risks Related to Doing Business in Hong Kong
Although we do not believe we are required to file with the China Securities Regulatory
Commission for this offering under the Trial..., page 41
14.You disclose in this risk factor that you do not believe you are subject to the Trial
Measures. However, it appears you have not relied on the opinion of counsel to come to
this conclusion. If so, please state as much.
Enforceability of Civil Liabilities, page 56
15.We note your disclosure here stating that all of your officers are nationals or residents of
Hong Kong. In this section, please also include whether your directors are nationals or
residents of Hong Kong or mainland China. Relatedly, in the risk factor on page 36,
please clarify which officers or directors are resident in Hong Kong or mainland China,
rather than disclosing that "most" are resident in Hong Kong.
Market Competition, page 60
16.We note your disclosure on page 4 that 99% of your pre-owned electronics revenue comes
from the sale of Apple products. We also note that Apple themselves operate in the pre-
owned consumer electronics space for their own products with their "Certified
Refurbished" program. Please disclose here, and elsewhere you deem relevant, the impact
and risks of competing with Apple when selling pre-owned Apple products.
Inflation, page 67
17.You disclose here and on page 34 that the company experienced material adverse effects
due to inflationary pressures or rising costs. Please expand to identify the principal factors,
including any jurisdictions your purchase from or sell to, contributing to the inflationary
pressures the company has experienced and clarify the resulting impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies, page 68
18.For critical accounting estimates, disclosure should supplement, but not duplicate, the
description of accounting policies or other disclosures in the notes to the financial
statements.  Critical accounting estimates are those estimates made in accordance with

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generally accepted accounting principles that involve a significant level of estimation,
uncertainty and have had, or are reasonably likely to have, a material impact on
your financial condition or results of operations.  Please revise.  Refer to Item 303(b)(3) of
Regulation S-K and SEC Release 33-8350.
Our Business, page 82
19.Please disclose in this section whether your business experiences any seasonality, as you
do in your risk factor on page 26. Refer to Item 4.B.3 of Form 20-F.
20.Please describe any marketing channels used by your business, if any. Refer to Item 4.B.5
of Form 20-F.
Suppliers, page 85
21.Please disclose whether the prices of the pre-owned consumer electronics devices are
subject to any material volatility. Refer to Item 4.B.4 of Form 20-F.
Business Plan, page 87
22.We note you list the website as "www.cgtrecycle.com" but we believe this may be a typo
and should be "www.cgt-recycle.com."
23.To the extent possible, please revise the respective business expansion plans to include
cost and time estimates.
Where you can Find Additional Information, page 132
24.Please use the SEC url "www.sec.gov" instead of url "www.sec.report." Refer to Item
4.A.8 of Form 20-F.
Notes to Consolidated Financial Statements
(4) Inventory, page F-14
25.You disclose here that cost is determined on a first-in, first-out basis.  On page F-9 you
disclose the average cost method is used.  Please revise for consistency.
General
26.Please supplementally provide us with 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 the staff member associated
with the review of this filing to discuss how to submit the materials, if any, to us for our
review.

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            You may contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336
if you have questions regarding comments on the financial statements and related
matters.  Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-
3680 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lan Lou