SecProbe.io

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 Cre8 Enterprise Limited

 1/F, China Building
29 Queen's Road Central, Hong Kong

 March 27, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Manufacturing

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Re:
 Cre8 Enterprise Limited

 Registration Statement on Form F-1, as
amended (File No. 333-281629)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Cre8 Enterprise Limited hereby requests acceleration
of the effectiveness of the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement
will become effective at 4:30 p.m., Eastern Time, on March 31, 2025, or as soon thereafter as practicable.

 The Company understands that
the Commission will consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the
fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the
securities specified in the Registration Statement.

 Very truly yours,

 Cre8 Enterprise Limited

 By:
 /s/ Sze Ting Cho

 Name:
 Sze Ting Cho

 Title:
 Chief Executive Officer

CORRESP
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 March 27, 2025

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance

 Office of Finance
100 F Street, N.E.
Washington, D.C. 20549

 Attention: Jenny O'Shanick

 Re:
 Cre8 Enterprise Limited
Registration Statement on Form F-1, as amended
File No. 333-281629

 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 hereby joins in the request of Cre8 Enterprise Limited that
the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:30 p.m.,
Eastern Time, on March 31, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Ortoli
Rosenstadt LLP, request by telephone that such Registration Statement be declared effective.

 Pursuant to Rule 460 of the General Rules and Regulations of the Securities
and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the security, 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.

 [ Signature Page Follows ]

 Very truly yours,

 AMERICAN TRUST INVESTMENT SERVICES, INC.

 By:
 /s/
Ian E. Lippy

 Name:
 Ian E. Lippy

 Title:
 Chief Operating Officer

 [ Signature Page to Underwriter's Acceleration Request
Letter ]

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February 3, 2025

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Cre8 Enterprise Limited

Amendment No. 6 to Registration Statement on Form F-1

Filed January 21, 2025

File No. 333-281629

Dear Ms. O’Shanick, Ms. Purnell, Mr. James, Mr. Eastman:

As counsel for Cre8 Enterprise Limited (the “Company”)
and on its behalf, this letter is being submitted in response to the letter dated January 22, 2025 from the U.S. Securities and Exchange
Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Registration Statement on Form F-1 submitted on January 21, 2025. Concurrently with the submission of this letter, we hereby transmit,
via EDGAR, an amended Registration Statement on Form F-1 (“Form F-1”) for filing with the Commission, which has been
revised to reflect the Staff’s comments as well as certain other updates to the Form F-1.

For the Staff’s convenience, the Staff’s comment has been
stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references below in
the Company’s responses are to the page numbers in Form F-1. Capitalized terms used but not otherwise defined herein have the meanings
set forth in the Form F-1.

Amendment No. 6 to Registration Statement on Form F-1

General

    1.
    Refer to page 118 of your Amendment No. 4 to Registration Statement on Form F-1, filed on November 18, 2024. Please update the “Compensation of Directors and Executive Officers” section to reflect the information for the fiscal year ended December 31, 2024. Refer to Item 6.B of Form 20-F.

RESPONSE: We note the Staff’s comment, and in response
hereto, respectfully advise the Staff that we have revised the disclosure on Page 118 of the Form F-1 to update the “Compensation
of Directors and Executive Officers” section to reflect the relevant information for the fiscal year ended December 31, 2024.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq. or Yarona Yieh,
Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Very truly yours,

    /s/ Mengyi “Jason” Ye

    Mengyi “Jason” Ye

    Direct dial: +1 (973) 931-2036

January 22, 2025
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Amendment No. 6 to Registration Statement on Form F-1
Filed January 21, 2025
File No. 333-281629
Dear Sze Ting Cho:
            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 September 10, 2024
letter.
Amendment No. 6 to Registration Statement on Form F-1
General
1.Refer to page 118 of your Amendment No. 4 to Registration Statement on Form F-1,
filed on November 18, 2024. Please update the "Compensation of Directors and
Executive Officers" section to reflect the information for the fiscal year ended
December 31, 2024. Refer to Item 6.B of Form 20-F.

January 22, 2025
Page 2
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Mengyi “Jason” Ye

CORRESP
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September 23, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Cre8 Enterprise Limited

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

Filed September 5, 2024

File No. 333-281629

Dear Ms. O’Shanick, Ms. Purnell, Mr. James, Mr. Eastman:

As counsel for Cre8 Enterprise Limited (the “Company”)
and on its behalf, this letter is being submitted in response to the letter dated September 10, 2024 from the U.S. Securities and Exchange
Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Registration Statement on Form F-1 submitted on September 5, 2024. Concurrently with the submission of this letter, we hereby transmit,
via EDGAR, an amended Registration Statement on Form F-1 (“Form F-1”) for filing with the Commission, which has been
revised to reflect the Staff’s comments as well as certain other updates to the Form F-1.

For the Staff’s convenience, the Staff’s
comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references
below in the Company’s responses are to the page numbers in Form F-1. Capitalized terms used but not otherwise defined herein have
the meanings set forth in the Form F-1.

Amendment No. 1 to Registration Statement on Form F-1
Part II - Information Not Required In the Prospectus

Item 8. Exhibits and Financial Statement Schedules Exhibit
Index

Exhibit 99.7 Opinion of Guangdong Wesley Law Firm, PRC Counsel to
the Registrant, regarding certain PRC law matters, page II-3

1. We note the statement on page 1 that the opinion relates to this
                                offering, “which includes the shares issued pursuant to the over-allotment option exercised by
                                the underwriter on August 2, 2024.” Please tell us whether you have issued the over-allotment shares
                                prior to the effectiveness of your registration statement, or revise.

RESPONSE: We note the Staff’s comment, and in
response hereto, respectfully advise the Staff that we have provided a revised PRC legal opinion provided by Guangdong Wesley Law Firm,
our PRC Counsel, which is filed as Exhibit 99.7 to the Form F-1 to clarify that no over-allotment shares were issued prior to the effectiveness
of the registration statement.

2. We note counsel’s opinion on pages 4 and 7. Please substantively
                                revise this section to clearly opine on each representation in the registration statement as attributed
                                to your PRC counsel. Refer to the cover page and pages 7, 13 to 16, 30, and 32 to 33 in the registration
                                statement. Alternatively, the opinion may cross-reference the specific sections in the registration statement
                                where such representations are located.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully advise
the Staff that we have provided a revised PRC legal opinion provided by Guangdong Wesley Law Firm, our PRC Counsel, which is filed as
Exhibit 99.7 to the Form F-1, to clearly opine on each representation in the registration statement as attributed to our PRC counsel, by cross-referencing to the
specific sections in the registration statement in the PRC Counsel’s opinion.

3. We note the statement on page 8 that “this opinion may not
                                be relied upon by any other persons or corporate entities other than the Company, SEC and NASDAQ, and
                                shall not be used for any other purpose or quoted or referred to in any public document or filed with
                                any governmental body or agency without our prior written consent.” Purchasers of the securities
                                in the offering are entitled to rely on the opinion. As such, please have counsel provide an updated
                                opinion that eliminates the limitation on reliance.

RESPONSE: We note the Staff’s comment, and in response
hereto, respectfully advise the Staff that we have provided a revised PRC legal opinion provided by Guangdong Wesley Law Firm, our PRC
Counsel, filed as Exhibit 99.7 to the Form F-1, which removed the aforesaid statement on the page 8 of the opinion.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq. or Yarona Yieh,
Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Very truly yours,

    /s/ Mengyi “Jason” Ye

    Mengyi “Jason” Ye

    Direct dial: +1 (973) 931-2036

September 10, 2024
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Amendment No. 1 to Registration Statement on Form F-1
Filed September 5, 2024
File No. 333-281629
Dear Sze Ting Cho:
            We have reviewed your amended registration statement and have the following
comments.
            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 23, 2024 letter.
Amendment No. 1 to Registration Statement on Form F-1
Part II - Information Not Required In the Prospectus
Item 8. Exhibits and Financial Statement Schedules
Exhibit Index
Exhibit 99.7 Opinion of Guangdong Wesley Law Firm, PRC Counsel to the Registrant, regarding
certain PRC law matters, page II-3
1.We note the statement on page 1 that the opinion relates to this offering, “which includes
the shares issued pursuant to the over-allotment option exercised by the underwriter on
August 2, 2024.” Please tell us whether you have issued the over-allotment shares prior to
the effectiveness of your registration statement, or revise.
We note counsel’s opinion on pages 4 and 7. Please substantively revise this section to
clearly opine on each representation in the registration statement as attributed to your
PRC counsel. Refer to the cover page and pages 7, 13 to 16, 30, and 32 to 33 in the 2.

September 10, 2024
Page 2
registration statement. Alternatively, the opinion may cross-reference the specific sections
in the registration statement where such representations are located.
3.We note the statement on page 8 that “this opinion may not be relied upon by any other
persons or corporate entities other than the Company, SEC and NASDAQ, and shall not
be used for any other purpose or quoted or referred to in any public document or filed
with any governmental body or agency without our prior written consent.” Purchasers of
the securities in the offering are entitled to rely on the opinion. As such, please have
counsel provide an updated opinion that eliminates the limitation on reliance.
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Mengyi “Jason” Ye

CORRESP
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September 5, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Cre8 Enterprise Limited

Registration Statement on Form F-1

Filed August 19, 2024

File No. 333-281629

Dear Ms. O’Shanick, Ms. Purnell, Mr. James, Mr. Eastman:

As counsel for Cre8 Enterprise Limited (the “Company”)
and on its behalf, this letter is being submitted in response to the letter dated August 23, 2024 from the U.S. Securities and Exchange
Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Registration Statement on Form F-1 submitted on August 19, 2024. Concurrently with the submission of this letter, we hereby transmit,
via EDGAR, an amended Registration Statement on Form F-1 (“Form F-1”) for filing with the Commission, which has been
revised to reflect the Staff’s comments as well as certain other updates to the Form F-1.

For the Staff’s convenience, the
Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such
comment. Page references below in the Company’s responses are to the page numbers in the Form F-1. Capitalized terms used but
not otherwise defined herein have the meanings set forth in the Form F-1.

Registration Statement on Form F-1 filed August
19, 2024

Capitalization, page 62

 1. You present a caption for Retained Earnings of US$238,697
as of July 31, 2024. As there are no related financial statements included in the filing for that period, please provide us with a roll-forward
from your December 31, 2023 financial statements showing the supporting detail to arrive at that amount. Provide a similar roll-forward
for the bank borrowings amount presented.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully
provide the following roll-forward of retained earnings and bank borrowings from the December 31, 2023 financial statements.

    US$

    Accumulated deficit as of December 31, 2023
      (152,905 )

    Net income for the seven months ended July 31, 2024 (unaudited)
      391,602

    Retained earnings as of July 31, 2024 (unaudited)
      238,697

    Bank borrowings as of December 31, 2023
      1,152,222

    Bank interests
      27,885

    Repayment
      (27,885 )

    Translation adjustment (unaudited)
      1,625

    Bank borrowings as of July 31, 2024 (unaudited)
      1,153,847

Dilution, page 63

 2. Please provide us with your computation of your net tangible
book value of $0.038 per ordinary share as of July 31, 2024. Separately identify the amounts of your total assets, intangible assets,
total liabilities and the number of total Ordinary Shares outstanding at July 31, 2024.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully
provide the following calculation of the net tangible book value of $0.038 per Ordinary Share as of July 31, 2024.

    US$

    Total assets
      8,078,404

    Intangible assets
      -

    Less: Total liabilities
      (7,234,589 )

    Net tangible book value
      843,815

    The number of total Ordinary Shares outstanding
(Giving retroactive effect to all the shares issued and outstanding for a share split at a ratio of 1-to-1,800 on August 12, 2024)
      22,500,000

    Net tangible book value per Ordinary Share
      0.038

Part II - Information Not Required in the Prospectus

Item 8. Exhibits and Financial Statement Schedules

Exhibit Index

Exhibit 10.1 - Employment Agreement by and
between the Registrant and Chi Kam Ray Lee..., page II-2

 3. We note the statement in this exhibit that Chi Kam Ray Lee
serves as your director. However, we note the disclosures in your filing that this individual serves as your chief financial officer.
Please revise to reconcile this discrepancy.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully
advise the Staff that we have provided a revised employment agreement which is filed as Exhibit 10.1 to the Form F-1 to show that Mr.
Chi Kam Ray Lee is currently serving as our chief financial officer and not a director of the Company.

Exhibit 10.6 - Second Office Rental Agreement between Cre8 (Greater
China) Limited..., page II- 2

 4. Please refile this exhibit in the proper text-searchable
format. Refer to Section 5.2.3.6 of the EDGAR Filer Manual (Volume II) EDGAR Filing (Version 70, July 2024) and Item 301 of Regulation
S-T.

RESPONSE: We note the Staff’s comment, and in response
hereto, respectfully advise the Staff that we have refiled Exhibit 10.6 in proper text-searchable format.

Exhibit 23.4 - Consent of Guangdong Wesley
Law Firm, PRC Counsel to the Registrant, page II- 2

 5. We note the statement in this exhibit that Cre8 (Greater
China) Limited engaged Guangdong Wesley Law Firm; however, there is no reference to the registrant. Please have counsel provide a revised
consent that consents to being named in your registration statement, filed by the registrant.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully
advise the Staff that we have provided a revised consent which is filed as Exhibit 23.4 to the Form F-1 to provide our PRC Counsel’s
consent to being named in our registration statement.

General

 6. We note your revised disclosure on page 141 deleted the reference
to Prime Number Capital, LLC as your underwriter. However, we note that your front and back cover pages still reference to Prime Number
Capital, LLC as your underwriter. Please revise to resolve this discrepancy.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully advise the Staff that we have revised our disclosure under the
“Underwriting” section starting from page 141 of the Form F-1 to resolve the discrepancy.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq. or Yarona Yieh,
Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Very truly yours,

    /s/ Mengyi “Jason” Ye

    Mengyi “Jason” Ye

    Direct dial: +1 (973) 931-2036

August 23, 2024
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Registration Statement on Form F-1
Filed August 19, 2024
File No. 333-281629
Dear Sze Ting Cho:
            We have reviewed your amended registration statement and have the following
comments.
            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.
Registration Statement on Form F-1 filed August 19, 2024
Capitalization, page 62
1.You present a caption for Retained Earnings of US$238,697 as of July 31, 2024. As there
are no related financial statements included in the filing for that period, please provide us
with a roll-forward from your December 31, 2023 financial statements showing the
supporting detail to arrive at that amount. Provide a similar roll-forward for the bank
borrowings amount presented.
Dilution, page 63
2.Please provide us with your computation of your net tangible book value of $0.038 per
ordinary share as of July 31, 2024. Separately identify the amounts of your total
assets, intangible assets, total liabilities and the number of total Ordinary Shares
outstanding at July 31, 2024.

August 23, 2024
Page 2
Part II - Information Not Required in the Prospectus
Item 8. Exhibits and Financial Statement Schedules
Exhibit Index
Exhibit 10.1 - Employment Agreement by and between the Registrant and Chi Kam Ray Lee...,
page II-2
3.We note the statement in this exhibit that Chi Kam Ray Lee serves as your director.
However, we note the disclosures in your filing that this individual serves as your chief
financial officer. Please revise to reconcile this discrepancy.
Exhibit 10.6 - Second Office Rental Agreement between Cre8 (Greater China) Limited..., page II-
2
4.Please refile this exhibit in the proper text-searchable format. Refer to Section 5.2.3.6 of
the EDGAR Filer Manual (Volume II) EDGAR Filing (Version 70, July 2024) and Item
301 of Regulation S-T.
Exhibit 23.4 - Consent of Guangdong Wesley Law Firm, PRC Counsel to the Registrant, page II-
2
5.We note the statement in this exhibit that Cre8 (Greater China) Limited engaged
Guangdong Wesley Law Firm; however, there is no reference to the registrant. Please
have counsel provide a revised consent that consents to being named in your registration
statement, filed by the registrant.
General
6.We note your revised disclosure on page 141 deleted the reference to Prime Number
Capital, LLC as your underwriter. However, we note that your front and back cover pages
still reference to Prime Number Capital, LLC as your underwriter. Please revise to resolve
this discrepancy.
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Mengyi “Jason” Ye

July 26, 2024
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Amendment No. 4 to
Draft Registration Statement on Form F-1
Submitted July 23, 2024
CIK No. 0002003977
Dear Sze Ting Cho:
            We have reviewed your amended draft registration statement and have the following
comments.
            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. Unless we note otherwise, any references to prior comments are to comments in our
July 12, 2024 letter.
Amendment No. 4 to Draft Registration Statement on Form F-1 Submitted July 23, 2024
Capitalization, page 62
1.Please revise to correctly indicate that the amounts presented in the table are in US$, and
not thousands of US$ as currently disclosed. We note from pages F-3 and F-9 that the
amounts translated for the convenience of the reader are presented in actual United States
dollars.

July 26, 2024
Page 2
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Mengyi “Jason” Ye

July 12, 2024
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Amendment No. 3 to
Draft Registration Statement on Form F-1
Submitted June 21, 2024
CIK No. 0002003977
Dear Sze Ting Cho:
            We have reviewed your amended draft registration statement and have the following
comments.
            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.
Amendment No. 3 to Draft Registration Statement on Form F-1
Prospectus Summary
Transfers of Cash to and from Our Operating Subsidiary in Hong Kong, page 7
1.We note your revised disclosure that, for the years ended December 31, 2022 and 2023,
certain amounts were transferred between Cre8 Hong Kong and Cre8 China. Please
update to reflect the information as of the date of the document.
Use of Proceeds, page 58
2.We note your revised disclosure that approximately 25% of the net proceeds is expected
to be used for, among other things, strategic investment and acquisition. Please explain
how this disclosure complies Item 3.C.2 and 3 of Form 20-F or revise.

July 12, 2024
Page 2
Capitalization, page 62
3.Please update the capitalization table as of a date no earlier than 60 days prior to the date
of the document. Refer to Item 3.B of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Period to period Comparison of Results of Operations
Selling and marketing expenses, page 73
4.We note your disclosure that your selling and marketing expenses decreased from the year
ended December 31, 2022 to the year ended December 31, 2023, “mainly due to the
decrease in employee compensation and benefits and sales commission in FY2023 due to
the absence of override commission during the year.” Please revise to elaborate on this
reason and how it differs from the increase of your employee compensation and benefits
expense under general and administrative expenses. Refer to the two tables on page 71.
Liquidity and Capital Resources
Bank borrowings, page 80
5.We note your revised disclosure about the government guaranteed SME loan for the year
ended December 31, 2023. Please explain how this disclosure complies Item 5.B.2 of
Form 20-F or revise.
Related Party Transactions, page 115
6.Please update this section to also provide the information as of the date of the document.
Refer to Item 7.B of Form 20-F.
Part II - Information Not Required in the Prospectus
Item 9. Undertakings, page II-3
7.We note your undertaking provided pursuant to Item 512(a) of Regulation S-K. However,
we note that you did not check the box on the registration statement cover page that you
are offering the shares in this offering on a delayed or continuous basis pursuant to Rule
415 of the Securities Act. Please revise.
General
8.We note your disclosure on pages Alt-4 and 5 that the selling securityholders may sell
their securities through purchases by a broker-dealer as principal and resales by the
broker-dealer for its account. Please revise to confirm your understanding that this 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.

July 12, 2024
Page 3
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
March 5, 2024
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted February 23, 2024
CIK No. 0002003977
Dear Sze Ting Cho:
            We have reviewed your amended draft registration statement and have the following
comments.
            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. Unless we note otherwise, any references to prior comments are to comments in our
January 18, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
64
1.We note your revisions in response to prior comment 12. For your integrated IPO
financial printing services, please revise to elaborate if you expect continuous smaller
contract sizes in future periods than prior periods and if you expect continuous delays in
revenue recognition for the contracts entered into in FY2023, such that those
corresponding revenues could only be recognized in FY2024.

 FirstName LastNameSze Ting Cho
 Comapany NameCre8 Enterprise Limited
 March 5, 2024 Page 2
 FirstName LastName
Sze Ting Cho
Cre8 Enterprise Limited
March 5, 2024
Page 2
Legal Matters, page 154
2.Please revise here and page Alt-6 to reference your updated Hong Kong counsel opinion.
            Please contact Len Jui at 202-551-6693 or Martin James at 202-551-3671 if you have
questions regarding comments on the financial statements and related matters. Please contact
Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Mengyi “Jason” Ye

United States securities and exchange commission logo
January 18, 2024
Sze Ting Cho
Chief Executive Officer
Cre8 Enterprise Limited
1/F, China Building
29 Queen’s Road Central, Hong Kong
Re:Cre8 Enterprise Limited
Draft Registration Statement on Form F-1
Submitted December 22, 2023
CIK No. 0002003977
Dear Sze Ting Cho:
            We have reviewed your draft registration statement and have the following comments.
            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 Submitted December 22, 2023
Cover Page
1.Clearly disclose how you will refer to the holding company, subsidiaries, and other
entities when providing the disclosure throughout the document so that it is clear to
investors which entity the disclosure is referencing and which subsidiaries or entities are
conducting the business operations. Refrain from using terms such as “we” or “our” when
describing activities or functions of a subsidiary or other entity. Please revise your filing.
2.We note your disclosure that the “BVI holding company, Cre8 BVI, has not declared or
made any dividend or other distribution to its shareholders, including U.S. investors, in the
past, nor have any dividends or distributions been made by our subsidiaries to the BVI
holding company. For the year ended December 31, 2022 and 2021, neither we nor our
subsidiaries have not declared or made any dividend or contribution to its shareholders.”
Please revise to clarify whether any transfers, dividends, or distributions have been made
to date between the holding company, its subsidiaries, and consolidated entities, or to

 FirstName LastNameSze Ting Cho
 Comapany NameCre8 Enterprise Limited
 January 18, 2024 Page 2
 FirstName LastName
Sze Ting Cho
Cre8 Enterprise Limited
January 18, 2024
Page 2
investors, and quantify the amounts where applicable.
3.We note your disclosures about your dual class structure and differing voting rights of
each class of ordinary shares. Please revise your prospectus summary and capitalization
sections to provide these disclosures.
Prospectus Summary, page 1
4.State affirmatively whether you have received from Chinese authorities all requisite
permissions or approvals and whether any permissions or approvals have been denied.
5.Quantify any cash flows and transfers of other assets by type that have occurred between
the holding company and its subsidiaries, and direction of transfer. Quantify any
dividends or distributions that a subsidiary has made to the holding company and which
entity made such transfer, and their tax consequences. Similarly quantify dividends or
distributions made to U.S. investors, the source, and their tax consequences. Your
disclosure should make clear if no transfers, dividends, or distributions have been made to
date.
6.Please ensure that the information you provide in your filing is balanced. For example, we
note your audit report contains an explanatory paragraph that your accumulated deficit
and working capital deficit, net cash outflows from operating activities raise substantial
doubt about your ability to continue as a going concern. To the extent you discuss, for
example, your revenue, expectations of business premises expansion or hiring more staff,
review each one and revise as necessary to provide balanced information including the
need for substantial funding and capital. Revise your filing throughout.
7.Please disclose your current level of indebtedness.
Implications of Being an "Emerging Growth Company", page 15
8.We note your disclosure in the last bullet of the first paragraph that as an emerging growth
company you will not be required to conduct an evaluation of your internal control over
financial reporting. Please note that pursuant to Item 15 of Form 20-F you will be required
to conduct an evaluation and provide management's report on the effectiveness of your
internal control over financial reporting starting with your second annual report. Please
revise the statement, or advise.
Risk Factors
We may face difficulties in recruiting and retaining experienced staff..., page 25
9.We note your risk factor that you may face difficulties recruiting and retaining employees.
Update your risks characterized as potential if you have experienced material difficulties.

 FirstName LastNameSze Ting Cho
 Comapany NameCre8 Enterprise Limited
 January 18, 2024 Page 3
 FirstName LastName
Sze Ting Cho
Cre8 Enterprise Limited
January 18, 2024
Page 3
You should read the entire prospectus carefully..., page 51
10.We note your disclosure in this section. Please revise to explain how this risk affects you
and how it makes an investment in the company speculative or risky. Refer to Item 105 of
Regulation S-K.
Capitalization, page 57
11.Please revise to comply with Item 3.B of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
59
12.Please identify any trend information that is reasonably likely to have a material effect on
your results of operations or financial condition. For example, we note your disclosure on
page 63 that revenue from your integrated IPO financial printing services decreased by
half from HK$32,563,103 in the fiscal year ended December 31, 2021 to HK$16,160,234
in the fiscal year ended December 31, 2022. Further, we note your disclosure on page 66
that your government subsidies increased significantly from HK$15,585 in the fiscal year
ended December 31, 2021 to HK$2,886,365 in the fiscal year ended December 31, 2022.
Refer to Item 5.D of Form 20-F.
General Factors Affecting Our Results of Operations, page 60
13.Please revise to discuss all material adverse COVID-19 impacts here, and reconcile your
disclosure on page 37 regarding adverse impacts. We note, for example, the disclosures
that, among others, you experienced reduced demand for your integrated financial printing
services. This appears inconsistent with your disclosure here that “[t]he volatility of global
stock market may adversely affect or delay our potential customers’ plans to commence
their IPO and/or other fund raising and corporate activities. As such, our revenue and
profitability may fluctuate.” Clearly revise your filing throughout.
Liquidity and Capital Resources, page 69
14.Please revise to comply with Item 5.B of Form 20-F. Further, please explain how your
discussion of your bank borrowings on page 73 complies Item 5.B.2 of Form 20-F and is
consistent with your disclosure on page F-20 or revise.
Business
Growth Strategies, page 89
15.We note your disclosure that one of your growth strategies is to set up “new business
premises in Hong Kong/Mainland China/Southeast Asia.” This appears inconsistent with
your disclosure on page 4 that you plan to set up only one new business premise in
Southeast Asia. Please revise your filing.

 FirstName LastNameSze Ting Cho
 Comapany NameCre8 Enterprise Limited
 January 18, 2024 Page 4
 FirstName LastName
Sze Ting Cho
Cre8 Enterprise Limited
January 18, 2024
Page 4
Seasonality, page 94
16.We note your disclosure that you “generally experience higher demands for our services
in March, April, August and September.” This disclosure appears inconsistent with your
other disclosure that you experience higher demands “in the first half of each calendar
year” on page 60. Please revise your filing.
Legal Proceedings, page 96
17.We note your disclosures regarding two Proceedings and that “except the Proceedings, we
are not a party to, and we are not aware of any threat of, any legal proceeding that, in the
opinion of our management, is likely to have a material adverse effect on our business,
financial condition or operations.” This disclosure appears inconsistent with your other
disclosure that you do not “believe that the ultimate outcome of any unresolved matters,
individually and in the aggregate, is reasonably possible to have a material adverse effect
on the financial position, results of operations or cash flows” on page F-27. Please revise
your filing.
Management, page 101
18.Please describe the extent and nature of the role of the board of directors in overseeing
cybersecurity risks, including in connection with the company’s supply
chain/suppliers/service providers.
Compensation of Directors and Executive Officers, page 107
19.Please update this section to reflect the information for the last full financial year. Refer to
Item 6.B of Form 20-F.
Related Party Transactions, page 108
20.Please update this section to reflect the information for the period beginning since the
beginning of your preceding three financial years up to the date of the document. Refer to
Item 7.B of Form 20-F. Further, please explain how your definition of related party
complies with this Item or revise.
Enforceability of Civil Liabilities, page 130
21.We note your disclosure that all of your officers and board members are based in Hong
Kong and that “it may be difficult for investors” to enforce liabilities and enforcement
judgments on those individuals. Please revise to clarify that it may be difficult or
impossible for investors to do so. Further, if material, please address these risks in a
separate risk factor.

 FirstName LastNameSze Ting Cho
 Comapany NameCre8 Enterprise Limited
 January 18, 2024 Page 5
 FirstName LastName
Sze Ting Cho
Cre8 Enterprise Limited
January 18, 2024
Page 5
Consolidated Financial Statements, page F-1
22.We note that you are a nonpublic company registering its initial public offering of
securities and that the audited financial statements included in the filing are now older
than 12 months. To the extent you are relying on the 15-month requirement for the age of
your financial statements, please file the representations outlined in Instruction 2 to Item
8.A.4 of Form 20-F as an exhibit to the registration statement. Otherwise, please update
the financial statements and other financial information in the filing to comply with Item
8.A.4 of Form 20-F.
Exhibit Index, page II-2
23.It appears that you have redacted information from Exhibits 10.1 and 10.2. Please revise
the exhibit index and the exhibits to comply with Item 601(b)(10)(iv) of Regulation S-K.
If you are not redacting information consistent with this Item, please advise.
General
24.We note you are registering shares for both a primary and a secondary resale offering.
Please revise to address the following:
•Revise to include a table of contents for the resale prospectus and ensure it is
consistent with the explanatory note. Refer to Item 502(a) of Regulation S-K;
•Revise the disclosure on page Alt-1 to clarify the number of shares that will be
outstanding following the primary offering, both with and without exercise of the
overallotment option;
•Provide risk factor disclosure of the impact that the resale offering may have on the
ability of the company to sell its shares in the public offering and any other related
material risks; and
•Revise the second risk factor on page 46 titled “Our existing shareholders that are not
included in this registration statement will be able to sell their Class A Ordinary
Shares after completion of this Offering subject to restrictions under the Rule 144” to
clarify whether, or the extent to which, it relates to the resale offering.
25.Please revise your resale prospectus cover page to address the following:
•Clarify whether the resale offering is conditioned upon Nasdaq listing approval;
•Revise to cross-reference the Selling Shareholders Plan of Distribution section. Refer
to Instruction 2 to Item 501(b)(3) of Regulation S-K;
•Provide more specific and prominent disclosures about the legal and operational risks
associated with China-based companies and as consistent with your primary
prospectus cover page. For additional guidance, please see the Division of
Corporation Finance's Sample Letter to China-Based Companies issued by the Staff
in December 2021;
•Prominently disclose that the company will be a controlled company post-offering,
identify the controlling shareholder(s) and such shareholders’ total voting power, and
include appropriate risk factor disclosure;

 FirstName LastNameSze Ting Cho
 Comapany NameCre8 Enterprise Limited
 January 18, 2024 Page 6
 FirstName LastName
Sze Ting Cho
Cre8 Enterprise Limited
January 18, 2024
Page 6
•Discuss your dual class structure and differing voting rights of each class of ordinary
shares; and
•Revise your commission legend to reference state securities commission. Refer to
Item 501(b)(7) of Regulation S-K.
26.Please revise page Alt-6 to reference your PRC counsel opinion.
            Please contact Len Jui at 202-551-6693 or Martin James at 202-551-3671 if you have
questions regarding comments on the financial statements and related matters. Please contact
Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Mengyi “Jason” Ye