SecProbe.io

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 1
 filename1.htm

 April 24, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Attn:	Ms. Inessa Kessman

 Re: OMS Energy Technologies Inc.
 Registration Statement on Form S-1 (File No. 333-282986)

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the "Securities Act"), we hereby join in the request of OMS Energy Technologies Inc. (the "Registrant")
for the acceleration of the effective date of the Registrant's Registration Statement on Form S-1 (File No. 333-282986) (as amended,
the "Registration Statement"), relating to the public offering of shares of common stock of the Registrant, so that the Registration
Statement may be declared effective on April 28, 2025 at 5:00 P.M. Eastern Time, or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and
Regulations under the Securities Act, the undersigned advises that it intends to distribute approximately 350 copies of the Preliminary
Prospectus, dated March 26, 2025 to prospective dealers, institutional investors, retail investors and others.

 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,

 Roth Capital Partners, LLC

 By:
 /s/ Aaron M. Guerwitz

 Name:
 Aaron M. Guerwitz

 Title:
 Head of Equity Capital Markets

 cc: Michael A. Hedge, Esq.

 Brian Daley, Esq.

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 OMS Energy Technologies Inc.

 10 Gul Circle

 Singapore 629566

 April 24, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Attn:	Ms. Inessa Kessman

 Re:
 OMS Energy Technologies Inc.

 Registration Statement on Form F-1, as amended (File No. 333- 282986)
 Request for Acceleration of Effectiveness

 Dear Madam,

 In accordance with Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended, OMS Energy Technologies Inc. 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 5:00 p.m., Eastern Time, on April 28, 2025, or as soon thereafter as practicable.

 Very truly yours,

 OMS Energy Technologies Inc.

 By:
 /s/ How Meng Hock

 Name:
 How Meng Hock

 Title:
 Chief Executive Officer, Executive Director and Chairman of the Board

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 filename1.htm

 OMS Energy Technologies Inc.

 10 Gul Circle
Singapore 629566

 March 26, 2025

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 Washington, DC 20549

 Attn: Inessa Kessman, Robert Littlepage, Aliya Ishmukhamedova and Mitchell
Austin

 Re:

 OMS Energy Technologies Inc.
 Amendment No. 7 to Registration Statement on Form F-1
 Filed March 20, 2025
 File No. 333-282986

 Dear Sir or Madam,

 This letter is in response to your letter on March
25, 2025, in which you provided comments to the Amendment No. 7 to Registration Statement on Form F-1 (the "Registration Statement")
of OMS Energy Technologies Inc. (the "Company") filed with the U.S. Securities and Exchange Commission on March 20, 2025.
On the date hereof, the Company has filed an amendment to the Registration Statement ("F-1/A8"). We set forth below in bold
the comments in your letter relating to the Registration Statement followed by our responses to the comments.

 Amendment No. 7 to Registration Statement on
Form F-1

 Unaudited Pro Forma Consolidated Statement
of Operation For the Year ended March 31, 2024, page 53

 1.

 Please quantitatively disclose how you
 calculated your pro forma cost of revenue adjustment of $877 thousands. Disclose new basis of assets and their useful lives.

 RESPONSE: We respectfully advise the
staff that we have updated the disclosure at page 53, F-29 and F-68 of the F-1/A8. We provide the following clarification regarding our
pro forma cost of revenue adjustment of $877,000, which, as explained in our prior response to Question 2 of our response letter dated
March 20, 2025, was calculated as follows:

 "Assuming the MBO occurred on April 1, 2023
 using the new basis of accounting, the pro forma full-year additional depreciation recognized under cost of revenue was $3.8 million.
 From here, if we deduct the revised additional depreciation recognized for the audited period June 16, 2023 through March 31, 2024 (Successor),
 which was $2.9 million, we arrive at the pro forma adjustment of approximately $0.9 million."

 This adjustment reflects the additional depreciation
 expense that would have been recognized under the new basis of accounting if the MBO had occurred at the beginning of the fiscal year
 on April 1, 2023.

 As disclosed in Note 3 of the Consolidated
Financial Statements on page F-29, at the acquisition date, the fair value of Property, Plant and Equipment was $33.4 million, which
has been treated as the carrying value post-MBO. This amount represents an excess of approximately $18.8 million over the historical
net book value immediately prior to the acquisition date.

 Asset Class
 Fair Value
 as of
June 16,
 2023
(US$'000)
 Net Book
 Value
 as of
June 15,
 2023
 (US$'000)
 Excess
Value
(US$'000)
 Additional
Depreciation
(pro forma adj)
(Apr 1, 2023
–Jun 15, 2023)
(US$'000)

 Land and buildings
 20,740
 10,760
 9,980
 98

 Computer and office equipment
 461
 293
 168
 - *

 Motor vehicles
 255
 160
 95
 - *

 Plant and machinery
 11,944
 3,269
 8,675
 779

 Total
 33,400
 14,482
 18,819
 877

 * Amount is immaterial

 As previously discussed in our response to Question
3 of our response letter dated March 20, 2025, management recognized the full amount of fair value step-up into depreciation expenses
directly for certain Property, Plant and Equipment, which led to an overstatement of depreciation expense for the Successor period from
June 16, 2023 through March 31, 2024. Following a reassessment, and to ensure accuracy and compliance with IFRS, we have revised our consolidated
financial statements to reflect depreciation expense based on a more appropriate remaining useful lives of the revalued assets. Specifically,
for land and buildings, the revised useful lives are based on the remaining lease terms (i.e. 20 to 60 years); and for plant and machinery,
we applied a further useful lives of up until 60 months, depending on the original purchase date and current operating condition of the
assets.

 Consolidated Financial Statements

 Business Combination, page F-70

 2. We refer to the disclosure on pages F-29 and F-69 to F-71.
Please explain why the correction of the error resulted in less depreciation expense from June 16, 2023 to September 30, 2023 of $3.9
million and less depreciation expense from June 16, 2023 to March 31, 2024 of $4.1 million, while resulting in more depreciation expense
$0.3 million for the six months ended 9/30/24. Explain the error in detail and how it was corrected. Explain how useful lives have
changed for your assets.

 RESPONSE: We respectfully
advise the staff and provide the following explanation regarding the correction of the depreciation error and the related variances in
depreciation expense across the reporting periods.

 As part of our fair value allocation under IFRS 3 at the time of the business combination, we recognized an increase in the carrying value of Property, Plant, and Equipment (PPE) of approximately $18.8 million over the Predecessor's historical net book value, as disclosed earlier in the above Comment No. 1.

 In preparing the consolidated financial statements for the Successor period (since June 16, 2023), the initial allocation of the fair value excess was made across various asset classes. However, in our initial assessment, the fair value excess of certain land and building as well as plant and machinery which had been fully depreciated at the acquisition date were recognized as the depreciation expenses immediately after MBO without having considered their actual condition, purchase date, or expected remaining economic benefit. This was based on a more conservative approach to avoid overstating net profit in the first year post-MBO.

 However, this resulted in accelerated depreciation that disproportionately impacted the financial results of the Successor period from June 16, 2023, particularly in the six months ended September 30, 2023. This was subsequently determined to be an error, as certain Property, Plant and Equipment were not depreciated based on the new remaining useful lives as assessed upon the completion of MBO.

 The correction was applied retrospectively from the MBO date (June 16, 2023) and more appropriately reflects the expected future usage of the assets. For land and buildings, the useful lives were aligned with remaining lease terms, ranging from 20 to 60 years, whereas for plant and machinery, this was adjusted for further useful lives of up until 60 months, depending on the condition of the asset. This correction ensures a better matching of depreciation expense with the actual consumption of economic benefit, in full compliance with IFRS.

 Reporting Period

 Impact of Correction on Depreciation Expense

 June 16, 2023 – September 30, 2023

 Decrease of $3.9 million (due to overstatement in original filing)

 June 16, 2023 – March 31, 2024

 Decrease of $4.1 million (cumulative overstatement reversed)

 April 1, 2024 – September 30, 2024

 Increase of $0.3 million

 The $0.3 million increase in depreciation
 expense for the six months ended September 30, 2024, reflects the correctly allocated depreciation under the revised, longer useful
 life, compared to the originally understated depreciation for that period in the previous filing. Under the earlier approach, some
 of the revalued assets were fully depreciated during the Successor period from June 16, 2023 to September 30, 2023 and from June 16,
 2023 to March 31, 2024 due to the application of an accelerated, conservative depreciation schedule, which also resulted in a lower
 depreciation being recorded for the six months period ended September 30, 2024.

 In contrast, the revised approach, which is
based on more appropriate and supportable useful lives, resulted in the depreciation being extended across a longer timeframe, and
therefore a modest increase in depreciation expense for the six months period ended September 30, 2024 and subsequent periods.

 2

 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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

 Sincerely,

 /s/ How Meng Hock

 Chief Executive Officer

 3

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 25, 2025

How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566

 Re: OMS Energy Technologies Inc.
 Amendment No. 7 to Registration Statement on Form F-1
 Filed March 20, 2025
 File No. 333-282986
Dear How Meng Hock:

 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.

Amendment No. 7 to Registration Statement on Form F-1
Unaudited Pro Forma Consolidated Statement of Operation For the Year ended
March 31,
2024, page 53

1. Please quantitatively disclose how you calculated your pro forma cost of
revenue
 adjustment of $877 thousands. Disclose new basis of assets and their
useful lives.
Consolidated Financial Statements
Business Combination, page F-70

2. We refer to the disclosure on pages F-29 and F-69 to F-71. Please
explain why the
 correction of the error resulted in less depreciation expense from June
16, 2023 to
 September 30, 2023 of $3.9 million and less depreciation expense from
June 16, 2023
 to March 31, 2024 of $4.1 million, while resulting in more depreciation
expense $0.3
 million for the six months ended 9/30/24. Explain the error in detail
and how it was
 March 25, 2025
Page 2

 corrected. Explain how useful lives have changed for your assets.
 Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at
202-551-3361
if you have questions regarding comments on the financial statements and
related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin
at 202-
551-3574 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Yarona Yieh
</TEXT>
</DOCUMENT>

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 filename1.htm

 OMS Energy Technologies Inc.

 10 Gul Circle
Singapore 629566

 March 20, 2025

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 Washington, DC 20549

 Attn: Inessa Kessman, Robert Littlepage, Aliya Ishmukhamedova and Mitchell
Austin

 Re:

 OMS Energy Technologies Inc.
 Amendment No. 6 to Registration Statement on Form F-1
 Filed February 26, 2025
 File No. 333-282986

 Dear Sir or Madam,

 This letter is in response to your letter on February
27, 2025, in which you provided comments to the Amendment No. 6 to Registration Statement on Form F-1 (the "Registration Statement")
of OMS Energy Technologies Inc. (the "Company") filed with the U.S. Securities and Exchange Commission on February 26, 2025.
On the date hereof, the Company has filed an amendment to the Registration Statement ("F-1/A7"). We set forth below in bold
the comments in your letter relating to the Registration Statement followed by our responses to the comments.

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

 Prospectus Summary, page 2

 1.

 We note your response to prior comment 1 and your
 new disclosure on pages 2 and 3. Your disclosure states, "Our gross profit margin for the combined six months ended September 30,
 2023 was impacted by the higher additional depreciation amounting to $4.1 million recognized from the business combination. Upon removing
 the latter impact, gross profit and gross profit margin for the combined six months ended September 30, 2023 was $15.7 million."
 Given that readers are trying to compare the reporting periods under the new basis of accounting, it is not clear to us why you would
 remove the impact of additional depreciation from the six months ended September 30, 2023. Be advised that the adjustment should cause
 the historical financial information to be on the new basis of accounting and thus should result in additional depreciation for the predecessor
 period. Please explain or revise accordingly.

 RESPONSE:
 We respectfully advise the staff that the Company has revised several sections of the prospectus on mainly on pages 2, 30, 85
 to 87, and 54 to 71 under the "Management's Discussion and Analysis of Financial Condition and Results of Operations"
 to discuss the historical financial information for each of the predecessor and the successor periods and not on a combined basis.
 The Company has also revised the consolidated financial statements for the period from June 16, 2023 to March 31, 2024 and revise
 the condensed consolidated financial statements for the period from June 16, 2023 to September 30, 2023 and for the six months ended
 September 30, 2024 to present the changes in terms of the correction of error under Note 3A on pages F-29 to F-31, and under Note
 5A on pages F68 to F-71, respectively.

 We
respectfully advise the staff that the Company analyzed the errors related to the depreciation expenses (included in cost of revenue)
of certain property, plant and equipment for the Successor period from June 16, 2023 to March 31, 2024, for the Successor period from
June 16, 2023 to September 30, 2023 and for the six months ended June 30, 2024 in accordance with SAB 108 and SAB 99. We determined that
the errors were not material to the consolidated financial statements for the Successor period from June 16, 2023 to September 30, 2023
and for the Successor period from June 16, 2023 to March 31, 2024. While the errors will be material to the consolidated financial statements
for the six months ended September 30, 2024 if the errors be corrected in the six months ended September 30, 2024. Therefore, we revised
the consolidated financial statements for all the periods presented.

 Unaudited Pro Forma Consolidated Statement
of Operation for the Year Ended March 31, 2024, page 53

 2.

 Your adjustment ii shows additional depreciation
 of $128,000 due to the fair value adjustment to property, plant and equipment and changes in the depreciation value. Please explain why
 the impact of the step up adjustment is only $128,000 from April 1 through June 15, 2023 while the impact is $4.1 million (per page 2
 and 65) from June 16 through September 30, 2023. That is, please explain how the additional depreciation was calculated and consider including
 that information in the footnote to the pro forma information.

 RESPONSE:
 We respectfully advise the staff that the step up adjustments from April 1, 2023 through June 15, 2023 on the proforma basis and the impact
from June 16 through September 30, 2023 has been revised following the correction of error in terms of the depreciation expenses of certain
property, plant & equipment that have been written up in connection with the MBO, where the resulting additional depreciation has
changed. The Company has amended the prospectus to reflect these changes on page 53.

 Apart
from the revision above, the Company has not made additional disclosures in the footnote to the pro-forma information as the existing
disclosures on the calculation still applies, i.e., assuming the MBO occurred on April 1, 2023 using the new basis of accounting, the
pro-forma full-year additional depreciation recognized under cost of revenue was $3.8 million. From here, if we less the revised additional
depreciation recognized for the audited period June 16, 2023 through March 31, 2024 (Successor), which was $2.9 million, we arrive at
the pro-forma adjustment of $0.9 million.

 Management's Discussion and Analysis
of Financial Condition and Results of Operations,

 Page 54

 3.

 You state on page 56 that, "The combined
 data is being presented for informational purposes only and has not been prepared on a pro forma basis as if the MBO occurred on the first
 day of the period because the relevant impact is immaterial." However, based on your new disclosure on page 2 and 3 impact appears
 significant. For all periods presented please advise and prepare for us a materiality analysis including gross margin and net income.
 If the impact is material, it is not appropriate to combine the changes in results for purposes of your Management's Discussion and Analysis
 (MD&A) as the financial statements are prepared on different bases of accounting and are not comparable. To the extent your presentation
 includes a supplemental discussion of the combined financial statements, it should be prepared on a pro forma basis reflecting all relevant
 pro forma adjustments in accordance with Article 11 of Regulation S-X. Also, revise your MD&A to separately present and discuss the
 historical results of your predecessor and successor or explain to us how your presentation complies with Item 303 of Regulation S-K.

 RESPONSE: We respectfully advise the staff that we have provided clarification
regarding our financial presentation and discussion in the MD&A.

 Following the revision of our consolidated financial
statements, we reassessed the impact of the new basis of accounting applied after the MBO. This reassessment confirmed that the differences
between the Predecessor and Successor periods were significant, particularly due to:

 1. The application of IFRS 3 (Business Combinations) – The fair
value adjustments applied upon the acquisition resulted in a new basis of accounting for the Successor period, including revalued assets
and liabilities, which are different from the historical cost basis used in the Predecessor period.

 2. Correction of error in terms of depreciation expenses of certain property,
plant and equipment that have been written up in connection with the MBO – Initially, management had recognized the full amount
of fair value step up into depreciation expenses directly for certain property, plant and equipment as at the date of MBO. However, upon
further evaluation, this approach resulted in an overstatement of depreciation expense and a corresponding understatement of net profit
for the successor period from June 16, 2023 to March 31, 2024. To ensure accuracy and compliance with IFRS, we have revised our consolidated
financial statements to reflect the depreciation of property, plant and equipment based on the remaining useful lives.

 3. Significant impact on financial statements – After the company
revised its consolidated financial statements and evaluated the impact of the new basis of accounting, the difference was significant
as the Company recognized $2.9 million additional depreciation expenses on the new bases for the period from June 16, 2023 to March 31,
2024 after completion the MBO. Therefore the company elected not to discuss the results on a combined basis.

 The company has also elected not to present supplemental proforma information
in the MD&A. The MBO happened on June 16, 2023 and we have determined that presenting supplementary proforma information on the assumption
that the MBO took place on an earlier date on April 1, 2022 will not present a meaningful analysis.

 2

 Business

 Licenses and Permits and Registrations, page
101

 4.

 It appears the Environmental Operational Permit
 issued to your Saudi Arabia-based subsidiary by the Saudi Arabia National Center for Environmental Compliance expired on February 2, 2025.
 We also note your disclosure on page 117 concerning compliance with environmental laws in Saudi Arabia and your risk factor disclosure
 on page 27 discussing risks relating to renewing or obtaining permits. Please revise to clarify whether this permit has expired and, if
 so, whether you have renewed it or are in the process of doing so. Additionally, please revise to disclose any material effects of the
 expiration of this permit on your business. In this regard, we note that you have historically generated over 50% of your revenue from
 Saudi Arabia.

 RESPONSE: We acknowledge the Staff's
 comment regarding the Environmental Operational Permit issued by the Saudi National Center for Environmental Compliance ("NCEC")
 to our Saudi Arabia-based subsidiary, and respectfully advise the Staff that we have provided an update and corresponding revisions
 in the F-1/A. The Company submitted its renewal request and expects to receive the renewal soon. We respectfully advise the Staff
 that the renewal process is generally administrative in nature, and we have not received any concerns from NCEC regarding the renewal.
 Furthermore, we confirm for the Staff that our Saudi Arabia subsidiary may still operate while the license renewal is under review.
 Even if under Saudi Environmental Law, the operation of a facility without a valid environmental permit may be subject to penalties,
 the maximum penalty for operating with an expired permit is a fine up to SAR 20,000 (approximately USD 5,300). Further, we understand
 that, under Saudi law, possessing documentation that verifies our timely renewal request may eliminate or reduce potential penalties.

 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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

 Sincerely,

 /s/ How Meng Hock

 Chief Executive Officer

 3

February 27, 2025
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 6 to Registration Statement on Form F-1
Filed February 26, 2025
File No. 333-282986
Dear How Meng Hock:
            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 February 24, 2025 letter.
Amendment No. 6 to Registration Statement on Form F-1
Prospectus Summary, page 2
We note your response to prior comment 1 and your new disclosure on pages 2 and 3.
Your disclosure states, "Our gross profit margin for the combined six months ended
September 30, 2023 was impacted by the higher additional depreciation amounting to
$4.1 million recognized from the business combination. Upon removing the latter
impact, gross profit and gross profit margin for the combined six months ended
September 30, 2023 was $15.7 million." Given that readers are trying to compare the
reporting periods under the new basis of accounting, it is not clear to us why you
would remove the impact of additional depreciation from the six months ended
September 30, 2023. Be advised that the adjustment should cause the historical
financial information to be on the new basis of accounting and thus should result in 1.

February 27, 2025
Page 2
additional depreciation for the predecessor period. Please explain or revise
accordingly.
Unaudited Pro Forma Consolidated Statement of Operation for the Year Ended March 31,
2024, page 53
2.Your adjustment ii shows additional depreciation of $128,000 due to the fair value
adjustment to property, plant and equipment and changes in the depreciation value.
Please explain why the impact of the step up adjustment is only $128,000 from April
1 through June 15, 2023 while the impact is $4.1 million (per page 2 and 65) from
June 16 though September 30, 2023. That is, please explain how the additional
depreciation was calculated and consider including that information in the footnote to
the pro forma information.
Management's Discussion and Analysis of Financial Condition and Results of Operations,
page 54
3.You state on page 56 that, "The combined data is being presented for informational
purposes only and has not been prepared on a pro forma basis as if the MBO occurred
on the first day of the period because the relevant impact is immaterial." However,
based on your new disclosure on page 2 and 3 impact appears significant. For all
periods presented please advise and prepare for us a materiality analysis including
gross margin and net income. If the impact is material, it is not appropriate to combine
the changes in results for purposes of your Management's Discussion and Analysis
(MD&A) as the financial statements are prepared on different bases of accounting and
are not comparable. To the extent your presentation includes a supplemental
discussion of the combined financial statements, it should be prepared on a pro forma
basis reflecting all relevant pro forma adjustments in accordance with Article 11 of
Regulation S-X.  Also, revise your MD&A to separately present and discuss the
historical results of your predecessor and successor or explain to us how your
presentation complies with Item 303 of Regulation S-K.
Business
Licenses and Permits and Registrations, page 101
4.It appears the Environmental Operational Permit issued to your Saudi Arabia-based
subsidiary by the Saudi Arabia National Center for Environmental Compliance
expired on February 2, 2025. We also note your disclosure on page 117 concerning
compliance with environmental laws in Saudi Arabia and your risk factor disclosure
on page 27 discussing risks relating to renewing or obtaining permits. Please revise to
clarify whether this permit has expired and, if so, whether you have renewed it or are
in the process of doing so. Additionally, please revise to disclose any material effects
of the expiration of this permit on your business. In this regard, we note that you have
historically generated over 50% of your revenue from Saudi Arabia.

February 27, 2025
Page 3
            Please contact Inessa Kessman at 202-551-3371 or Stephen Krikorian at 202-551-
3488 if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-
551-3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

CORRESP
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OMS Energy Technologies Inc.

10 Gul Circle

Singapore 629566

February 26, 2025

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Inessa Kessman, Robert Littlepage, Aliya Ishmukhamedova and Mitchell
Austin

    Re:

    OMS Energy Technologies Inc.

    Amendment No. 5 to Registration Statement on Form F-1

    Filed February 13, 2025

    File No. 333-282986

Dear Sir or Madam,

This letter is in response to your letter on
February 24, 2025, in which you provided comments to the Amendment No. 5 to Registration Statement on Form F-1 (the
“Registration Statement”) of OMS Energy Technologies Inc. (the “Company”) filed with the U.S. Securities
and Exchange Commission on February 13, 2025. On the date hereof, the Company has filed an amendment to the Registration
Statement (“F-1/A6”). We set forth below in bold the comments in your letter relating to the Registration
Statement followed by our responses to the comments.

Amendment No. 5 to Registration Statement on
Form F-1

Prospectus Summary, page 1

    1.
    We
    note your response to prior comment 1. Please disclose the specific monetary effects of the differences in basis of accounting and
    the impact to revenue, gross margin, and net profit. This disclosure should immediately follow the fluctuation discussion.

RESPONSE: We respectfully advise the
staff that we have revised our disclosure on pages 2 and 3 of the F-1/A6 to disclose the specific impacts to revenue, gross profit
and gross profit margin, and net profit. We have further revised our disclosure on pages 66 and 67 of the F-1/A6 to ensure such
impacts are disclosed immediately following the fluctuation discussion under the Management Discussion and Analysis section.

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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ How Meng Hock

    Chief Executive Officer

February 24, 2025
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 5 to Registration Statement on Form F-1
Filed February 13, 2025
File No. 333-282986
Dear How Meng Hock:
            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 February 10, 2025 letter.
Amendment No. 5 to Registration Statement on Form F-1
Prospectus Summary, page 1
1.We note your response to prior comment 1. Please disclose the specific monetary
effects of the differences in basis of accounting and the impact to revenue, gross
margin, and net profit. This disclosure should immediately follow the fluctuation
discussion.

February 24, 2025
Page 2
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-
551-3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

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OMS Energy Technologies Inc.

10 Gul Circle

Singapore 629566

February 13, 2025

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Aliya Ishmukhamedova

 Re: OMS
Energy Technologies Inc.

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

Filed January 28, 2025

File No. 333-282986

Dear Sir or Madam,

This letter is in response to your comments on
February 10, 2025 in relation to the Amendment No. 4 to Registration Statement on Form F-1 (the “Registration Statement”)
of OMS Energy Technologies Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on January 28, 2025.
On the date hereof, the Company has filed an amendment to the Registration Statement. We set forth below in bold the comments in your
letter relating to the Registration Statement followed by our responses to the comments.

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

Prospectus Summary, page 1

1. We
note your discussion of fluctuations in revenue, gross margin, and net profit between the six months ended September 30, 2024 and September
30, 2023. When highlighting these fluctuations, please prominently disclose there were different basis of accounting in the periods and
that the comparison may not be indicative of your results if both periods were under the same basis of accounting. Revise similar disclosures
made on page 53, 65, and 83, accordingly.

RESPONSE:
We respectfully advise the staff that we have revised our disclosure on page 1 to prominently disclose that financial results for the
six month ended September 20, 2023 and the six months ended September 30, 2024 were prepared under different bases of accounting and that
the comparison between these periods may not be indicative of our financial results  and
have added similar disclosures on page 53, 65, and 83, accordingly.

Unaudited Condensed Consolidated Interim
Statements of Changes in Equity, page F-60

2. Please
disclose the details concerning the $5 million capital contribution recorded in the six months ended September 30, 2024. This disclosure
should inform readers as to who, when, and why the contribution was provided. Also, tell us how this capital contribution is reflected
in your statements of cash flows.

RESPONSE: We respectfully advise the staff
that we have revised our disclosure to update the name of line item from “capital contribution” to “conversion of convertible
notes” that is more appropriate and also include a footnote to the $5 million conversion of convertible notes under the unaudited
condensed consolidated interim statements of changes in equity on page F-60, disclosing the relevant details of the capital contribution
with reference to Note 13. We also update the unaudited condensed consolidated interim statements of cash flows to include a supplemental
disclosure of noncash information regarding the conversion of the convertible note for the six months ended September 30, 2024.

During the period from June 16, 2023 through March
31, 2024, the convertible note holders provided the total cash subscription of US$5 million for the convertible notes in advance, which
was reflected as advances from potential investors under the audited consolidated statement of cash flows for the period from June 16,
2023 through March 31, 2024 on page F-8.

Loans and Borrowings, page F-68

3. Please
disclose the facts and circumstances regarding the $5.8 million loan that was paid off and clarify if this is related to the $5 million
capital contribution reported in the Statements of Changes in Equity.

RESPONSE: We respectfully advise the staff
that we have revised the disclosure to the footnote relating to the $5.8 million on page F-68 to provide clarity under the unaudited condensed
consolidated interim financial statements. Please note that this loan is unrelated to the $5 million capital contribution as reported
in the Unaudited Condensed Consolidated Interim Statements of Changes in Equity and such disclaimer was not made on F-68 as prior disclosure
regarding the loan has been made under the Audited Consolidated Financial Statements on F-37 and F-51.

Trade Payables and Other, page F-68

4. We
note “Other payables, non-current” had a balance of $5 million on March 31, 2024, which was subsequently reduced to zero. Please
disclose the details regarding the $5 million and how it was paid off. If it is related to the $5 million capital contribution recorded
in statement of changes in equity, please disclose the relationship.

RESPONSE: We respectfully advise the staff
that we have revised disclosure to the notes relating to the other payables, non-current on page F-68 to detail the nature of the payables
as of March 31, 2024 and its subsequent treatment following the approval and execution of the convertible notes agreements, and thereafter
its conversion into equity on September 30, 2024.

General

5. On page 90 you disclose that for the six months ended September
30, 2024, ARAMCO accounted for 71% of your revenue. Given the significance of this one customer, please disclose this information prominently
in the Prospectus Summary, MD&A, and Business sections
    of your filing.

RESPONSE: We respectfully advise the staff
that we have disclosed this information prominently in the Prospectus Summary, MD&A, and Business sections of our filing.

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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ How Meng Hock

    Chief Executive Officer

February 10, 2025
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 4 to Registration Statement on Form F-1
Filed January 28, 2025
File No. 333-282986
Dear How Meng Hock:
            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.
Amendment No. 4 to Registration Statement on Form F-1
Prospectus Summary, page 1
1.We note your discussion of fluctuations in revenue, gross margin, and net
profit between the six months ended September 30, 2024 and September 30, 2023.
When highlighting these fluctuations, please prominently disclose there were different
basis of accounting in the periods and that the comparison may not be indicative of
your results if both periods were under the same basis of accounting. Revise similar
disclosures made on page 53, 65, and 83, accordingly.
Unaudited Condensed Consolidated Interim Statements of Changes in Equity, page F-60
Please disclose the details concerning the $5 million capital contribution recorded in
the six months ended September 30, 2024. This disclosure should inform readers as to
who, when, and why the contribution was provided. Also, tell us how this capital 2.

February 10, 2025
Page 2
contribution is reflected in your statements of cash flows.
12 Loans and Borrowings, page F-68
3.Please disclose the facts and circumstances regarding the $5.8 million loan that was
paid off and clarify if this is related to the $5 million capital contribution reported in
the Statements of Changes in Equity.
Trade Payables and Other, page F-68
4.We note "Other payables, non-current" had a balance of $5 million on March 31,
2024, which was subsequently reduced to zero. Please disclose the details regarding
the $5 million and how it was paid off. If it is related to the $5 million capital
contribution recorded in statement of changes in equity, please disclose the
relationship.
General
5.On page 90 you disclose that for the six months ended September 30, 2024,
ARAMCO accounted for 71% of your revenue. Given the significance of this one
customer, please disclose this information prominently in the
Prospectus Summary, MD&A, and Business sections of your filing.
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-
551-3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

CORRESP
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OMS Energy Technologies Inc.

10 Gul Circle

Singapore 629566

December 6, 2024

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Aliya Ishmukhamedova

    Re:
    OMS Energy Technologies Inc.

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

Filed November 29, 2024

File No. 333-282986

Dear Sir or Madam,

This letter is in response to your comments on
December 5, 2024 in relation to the Amendment No. 2 to Registration Statement on Form F-1 (the “Registration Statement”) of
OMS Energy Technologies Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on November 29, 2024.
On the date hereof, the Company has filed an amendment to the Registration Statement. We set forth below in bold the comments in your
letter relating to the Registration Statement followed by our responses to the comments.

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

Consolidated Statements of Profit and Loss
and Other Comprehensive Income, page F-5

    1.
    We note your response to prior comment 3. Since the revision appears to be a correction of an error, please provide disclosure in accordance with IAS 8.

RESPONSE: We respectfully advise the staff
that we have updated F-2 and F-41 of the Registration Statement, providing the disclosure in accordance with IAS 8.

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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ How Meng Hock

    Chief Executive Officer

December 5, 2024
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 2 to Registration Statement on Form F-1
Filed November 29, 2024
File No. 333-282986
Dear How Meng Hock:
            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 November 26,
2024 letter.
Amendment to Form F-1 filed November 29, 2024
Consolidated Statements of Profit and Loss and Other Comprehensive Income, page F-5
1.We note your response to prior comment 3. Since the revision appears to be a
correction of an error, please provide disclosure in accordance with IAS 8.

December 5, 2024
Page 2
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-
551-3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

CORRESP
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OMS Energy Technologies Inc.

10 Gul Circle

Singapore 629566

November 29, 2024

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Aliya Ishmukhamedova

 Re: OMS
                                            Energy Technologies Inc.

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

Filed
November 22, 2024

File
No. 333-282986

Dear Sir or Madam,

This letter is in response to your comments on November 26, 2024 in
relation to the Amendment No. 1 to Registration Statement on Form F-1 (the “Registration Statement”) of OMS Energy Technologies
Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on November 22, 2024. On the date hereof, the
Company has filed an amendment to the Registration Statement. We set forth below in bold the comments in your letter relating to the Registration
Statement followed by our responses to the comments.

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

Capitalization, page 48

 1. Footnote (4) on page 48 states that the Capitalization table "Does not account for 1,845,000 Ordinary
Shares that were issued pursuant to the Convertibles Notes after March 31, 2024." Please explain why those shares are not included
in the Capitalization table.

RESPONSE: We respectfully advise the staff that we have included the 1,845,000 Ordinary Shares that were issued pursuant to the Convertibles Notes
after March 31, 2024 in the capitalization table and removed the inaccurate footnote (4) to avoid confusion.

Dilution, page 49

 2. We note disclosure on page 135 that on February 5, 2024 and February 9, 2024 you entered into convertible
note agreements. You further state, "In the event of the Company being approved for an initial public offering by the SEC, the holders
may, upon written notice to the Company elect to have the principal sum converted into the applicable shares immediately prior to or upon
such initial public offering." Please explain how your February 5, 2024 and February 9, 2024 convertible notes are reflected in your
pro forma dilution table and or revise accordingly.

RESPONSE: We respectfully advise the staff that we have updated page 135 of the Registration Statement by removing the sentence “As of the
date of this prospectus, the principal sum of the convertible notes has not been converted into conversion shares.” to confirm that
the existing total number of ordinary shares is 38,745,000 ordinary shares, and to reflect the conversion of the convertible notes. We
also confirm that, consistent with disclosures elsewhere in the prospectus, the convertible notes were fully converted into ordinary shares
as of September 30, 2024.

We also respectively advise the staff that the
conversion of the convertible notes has been reflected in the pro forma dilution table to increase the pro forma net tangible book value
per common share after the offering.

Consolidated Statements of Profit or Loss
and Other Comprehensive Income, page F-5

 3. Please explain why you have 15,000,0000 basic and diluted weighted-average shares outstanding for the
period June 16, 2023 through March 31, 2024 while shares outstanding are 36,900,000 as of June 16, 2023 and March 31, 2024. Please revise
accordingly, including your basic and diluted earnings per share.

RESPONSE: We respectfully advise the staff that we have updated basic and diluted
earnings per share to reflect the changes in shares outstanding for the period from June 16, 2023 through March 31, 2024 on page F-5 and
F-41 of the Registration Statement.

Consolidated Statements of Changes in Equity,
page F-6

 4. We note your disclosure on page 9 that, "On October 23, 2024, as part of the final step of the Company's
reorganization process, the Company issued a total of 38,729,250 Ordinary Shares on a pro rata basis to all of its existing shareholders."
You also state on page F-56 that, "Upon the completion of share reorganization, there are 38,745,000 Ordinary Shares issued and outstanding."
Please explain why the number of shares outstanding as of March 31, 2024 is 36,900,000. Clarify if 1,844,250 Ordinary Shares issued to
convertible bond investors were part of the reorganization.

RESPONSE: We respectfully advise the staff
that the purpose of the reorganization process was first to accurately represent the shareholding of the shareholders in the predecessor
entity before the listing entity was incorporated. Thereafter, because the convertible notes were converted, a total of 750 Ordinary Shares
were issued to the convertible note shareholders. The 1,844,250 Ordinary Shares were thereafter issued to convertible note holders after
the initial conversion of 750 shares as part of a pro rata issuance to all shareholders to better reflect the current valuation of the
Company.

For further clarity to page 9:

    1)
    At the inception, the Company had 15,000 Ordinary Shares outstanding, which were held by the original shareholders. Thereafter, the holders of the convertible notes converted their notes into 750 Ordinary Shares on September 30, 2024, bringing the total number of shares to 15,750.

    2)
    During the final stage of the Company’s reorganization process, on October
    23, 2024, the Company issued a total of 38,729,250 new Ordinary Shares on a pro rata basis to all its existing shareholders (bringing the total outstanding shares to 38,745,000), which
    included holders of convertible notes. This issuance was executed to achieve the final share capital structure
    post-reorganization.

    3)
    As of the date of this prospectus, the Company has a total of 38,745,000 Ordinary
    Shares issued and outstanding. This figure includes the
    1,845,000 Ordinary Shares that were issued to convertible note holders as part of a pre-IPO fundraising activity.

    4)
    The Company then adjusted the original 15,000 Ordinary shares on a retroactive
    basis to be 36,900,000 Ordinary Shares pursuant to SAB Topic 4C as of June 16, 2023 and March 31, 2024.

Exhibit Index, page II-5

 5. Please revise the exhibit index to mark exhibits 10.6-10.13 as redacted exhibits. Additionally, Exhibits
10.12, and 10.13 have been uploaded as images rather than text searchable documents. Please amend your filing to make sure all exhibits
are submitted in a text searchable format. See Section 5.1 of Volume II of the EDGAR Filer Manual and Item 301 of Regulation S-T.

RESPONSE: We respectfully advise the staff
that we have amended our filing to make sure all exhibits are submitted in a text searchable format and have marked exhibits 10.6 to 10.13
as redacted exhibits.

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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ How Meng Hock

    Chief Executive Officer

November 26, 2024
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 1 to Registration Statement on Form F-1
Filed November 22, 2024
File No. 333-282986
Dear How Meng Hock:
            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.
Amendment No. 1 to Registration Statement on Form F-1
Capitalization, page 48
1.Footnote (4) on page 48 states that the Capitalization table "Does not account for
1,845,000 Ordinary Shares that were issued pursuant to the Convertibles Notes after
March 31, 2024." Please explain why those shares are not included in the
Capitalization table.
Dilution, page 49
We note disclosure on page 135 that on February 5, 2024 and February 9, 2024 you
entered into convertible note agreements. You further state, "In the event of the
Company being approved for an initial public offering by the SEC, the holders may,
upon written notice to the Company elect to have the principal sum converted into the
applicable shares immediately prior to or upon such initial public offering." Please 2.

November 26, 2024
Page 2
explain how your February 5, 2024 and February 9, 2024 convertible notes are
reflected in your pro forma dilution table and or revise accordingly.
Consolidated Statements of Profit or Loss and Other Comprehensive Income, page F-5
3.Please explain why you have 15,000,0000 basic and diluted weighted-average shares
outstanding for the period June 16, 2023 through March 31, 2024 while shares
outstanding are 36,900,000 as of June 16, 2023 and March 31, 2024. Please revise
accordingly, including your basic and diluted earnings per share.
Consolidated Statements of Changes in Equity, page F-6
4.We note your disclosure on page 9 that, "On October 23, 2024, as part of the final step
of the Company's reorganization process, the Company issued a total of 38,729,250
Ordinary Shares on a pro rata basis to all of its existing shareholders."  You also state
on page F-56 that, "Upon the completion of share reorganization, there are 38,745,000
Ordinary Shares issued and outstanding." Please explain why the number of shares
outstanding as of March 31, 2024 is 36,900,000. Clarify if 1,844,250 Ordinary Shares
issued to convertible bond investors were part of the reorganization.
Exhibit Index, page II-5
5.Please revise the exhibit index to mark exhibits 10.6-10.13 as redacted exhibits.
Additionally, Exhibits 10.12, and 10.13 have been uploaded as images rather than text
searchable documents. Please amend your filing to make sure all exhibits are
submitted in a text searchable format. See Section 5.1 of Volume II of the EDGAR
Filer Manual and Item 301 of Regulation S-T.
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-
551-3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

CORRESP
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OMS Energy Technologies Inc.

10 Gul Circle

Singapore 629566

November 22, 2024

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Aliya Ishmukhamedova

    Re:
    OMS Energy Technologies Inc.

Form F-1 Filed November 4, 2024

CIK No. 0002012219

Dear Sir or Madam,

This letter is in response to your verbal comment
on November 20, 2024 in relation to the Registration Statement on Form F-1 (the “Registration Statement”) of OMS Energy Technologies
Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on November 4, 2024. On the date hereof, the Company
has filed a Form F-1. We set forth below in bold the comments in your letter relating to the Registration Statement followed by our responses
to the comments.

We note you have reissued comment 11 of the DRS
Letter dated June 25, 2024 which we reproduce below.

11. Once you have an estimated offering
price or range, please explain to us how you determined the fair value of the common stock underlying your equity issuances and the
reasons for any differences between the recent valuations of your common stock leading up to the initial public offering and the
estimated offering price. This information will help facilitate our review of your accounting for equity issuances including stock
compensation. Please discuss with the staff how to submit your response.

RESPONSE: On June 16, 2023, Mr. How Meng
Hock entered into an agreement to acquire OMS Holdings Pte. Ltd. (“OMSET PL”) from Sumitomo Corporation for a consideration
of US$2,000,000 (the “MBO”). This valuation was determined based on a thorough evaluation of OMSET PL’s (i) negative
equity position, (ii) complete write-down of goodwill and physical assets, and (iii) significant challenges in selling its products at
the time of the transaction. The funding for the MBO was contributed by all existing shareholders of the Company, except for those who
were issued shares under the convertible note. The shares of OMSET PL were held collectively by Mr. How Meng Hock under an entrustment
arrangement, along with two minority shareholders. In this arrangement, Mr. How Meng Hock held shares on behalf of himself and the five
minority shareholders (the “Entrustment Shareholders”, together collectively, the “MBO Minority Shareholders”).

Regarding
the issuance of shares, we wish to clarify for the SEC the following:

 1. The
                                            Company issued shares in two steps to the MBO Minority Shareholders.

 ● On
                                            April 11, 2024, the Company issued 9,000 shares to Mr. How Meng Hock and 1,000 shares to
                                            the two minority shareholders.

 ● On
                                            May 7, 2024, the Company issued an additional 5,000 shares to the Entrustment Shareholders.

 2. These
                                            two issuances were part of the same reorganization step and collectively resulted in the
                                            issuance of 15,000 shares to all previous shareholders of OMSET PL. This issuance reflects
                                            the agreed-upon ownership percentages of all MBO Minority Shareholders in OMSET PL
                                            under the entrustment arrangement, which was established prior to the MBO.

 3. In
                                            our prior response to the Staff’s comment letter question 9 pursuant to Amendment No.
                                            2 to Draft Registration Statement on Form F-1, that we submitted on October 16, 2024, we
                                            also noted that this additional 5,000-share issuance was part of the same reorganization
                                            process. This process was intended to align the shareholding percentages of the MBO Minority
                                            Shareholders in OMSET PL following the entrustment arrangement and the MBO. This has also
                                            been disclosed under Note 15 of Company’s audited financial statements.

 4. To
                                            provide further clarity, we have revised the following sections in the F-1/A:

 ● History
                                            and Corporate Structure – Reorganization on page 67

 ● Part
                                            II – Item 7. Recent Sales of Unregistered Securities on page II-2

These
revisions clarify the disclosure that the share issuances were part of a two-step reorganization process. The intention was always
to reflect the ownership percentages of the MBO Minority Shareholders and Mr. How Meng Hock as agreed upon in the MBO and the entrustment
arrangement. We respectfully advise the Staff that these revisions provide additional clarity regarding the reorganization and share
issuance process.

With regard to the convertible notes’ valuation
and subsequent issuances, the Company was aware of potential liquidity risks in meeting its daily working capital needs because the Predecessor,
i.e., Sumitomo Corporation, as a condition of the MBO, would no longer provide any form of financial support to the Company post MBO.
The discontinuance of the sole source of financial support and the lack of a bank facilities track record with other financial institutions
compelled the Company to seek alternative funding sources. The Company initiated the debt instruments offering to several parties following
the completion of the MBO. After several rounds of negotiations, the Company successfully raised a total of US$5 million from two investors
at a post-money valuation of US$105 million, approximately 3x the Net Asset Value based on the fiscal year ended March 31, 2023. The convertible
notes’ valuation was negotiated and determined based on prevailing market conditions and associated investor risks, particularly
uncertainties regarding the Company’s prospects, revenue, and growth after completing its MBO. The uncertainty of the completion
of the IPO and risks of being unable to exit the investment at the time of the IPO were also considered during the negotiation process.

Regarding the issuances on October 23, 2024, on
a pro-rata basis to all shareholders, these issuances were completed for recapitalization purpose to align the number of shares more closely
with the pre-IPO valuation of the Company, estimated at approximately US$309 million, assuming the shares were priced at US$8.0 per share
based on the valuation model provided by the underwriter of the IPO.

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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ How Meng Hock

    Chief Executive Officer

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OMS Energy Technologies Inc.

10 Gul Circle

Singapore 629566

November 4, 2024

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Inessa Kessman, Robert Littlepage, Aliya Ishmukhamedova and Mitchell
Austin

    Re:
    OMS Energy Technologies Inc.

Draft Registration Statement on Form F-1 Submitted May 29, 2024

CIK No. 0002012219

Dear Sir or Madam,

This letter is in response to your letter on June
25, 2024, in which you provided comments to the Registration Statement on Form DRS/A of OMS Energy Technologies Inc. (the “Company”)
submitted to the U.S. Securities and Exchange Commission on May 29, 2024. On the date hereof, the Company has submitted an Amendment No.
1 to the Registration Statement on Form DRS/A (“DRS/A”). We set forth below in bold the comments in your letter relating to
the Registration Statement followed by our responses to the comments.

Amendment 2 to Draft Registration Statement
submitted October 16, 2024

Consolidated Financial Statements

Report of Independent Registered Public Accounting
Firm, page F-2

1. We note your response to prior comment 6. Please ask your auditor to revise their report to refer to changes
in equity in their opinion. Refer to guidance in footnote 16 of paragraph 0.08(e) in AS 3101.

RESPONSE: We respectfully advise the
staff that the auditor followed AS 3101, para 0.08 (e) and appendix B - An Illustrative Auditor’s Unqualified Report Including Critical
Audit Matters. The auditor referred to the Statement on Auditing Standards No. 134 issued by the Auditing Standards Board, Auditor’s
Opinion (Ref: par. .25-.27). A27 and AU Section 508 Reports on Audited Financial Statements para.06. and believed the changes in equity
needs not be referred to separately in the opinion paragraph because changes in equity are considered part of the presentation of financial
position, results of operations, and cash flows.

The auditor thought about that footnote
16 paragraph 0.08 (e) in AS 3101 is meant to provide guidance for different type of company with different financial statements being
audited, which is considered not applicable to the Company.

Therefore, the auditor believes the opinion paragraph is appropriate
and consistent with common practice.

Management’s Discussion and Analysis
of Financial Conditions and Results of Operations, page 51

2. We note that you have redacted information from portions of exhibits 10.6 – 10.13 pursuant to Item
601(b)(10)(iv) of Regulation S-K. Please ensure you have included a prominent statement on the first page of each redacted exhibit that
certain identified information has been excluded from the exhibit because it is both not material and is the type that the registrant
treats as private or confidential. Additionally, ensure that each exhibit includes a legend and brackets indicating where the information
is omitted from the filed version of the exhibit.

RESPONSE: We respectfully advise the staff that
we have included a prominent statement on the first page of each redacted exhibit that certain identified information has been excluded
from the exhibit because it is both not material and is the type that the registrant treats as private or confidential. Additionally,
we have ensured that each exhibit includes a legend and brackets indicating where the information is omitted from the filed version of
the exhibit.

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 our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ How Meng Hock

    Chief Executive Officer

October 30, 2024
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted October 16, 2024
CIK No. 0002012219
Dear How Meng Hock:
            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 September 27, 2024 letter.
Amendment 2 to Draft Registration Statement submitted October 16, 2024
Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2
1.We note your response to prior comment 6. Please ask your auditor to revise their
report to refer to changes in equity in their opinion. Refer to guidance in footnote 16
of paragraph 0.08(e) in AS 3101.

Exhibits
We note that you have redacted information from portions of exhibits 10.6-10.13 2.

October 30, 2024
Page 2
pursuant to Item 601(b)(10)(iv) of Regulation S-K. Please ensure you have included a
prominent statement on the first page of each redacted exhibit that certain identified
information has been excluded from the exhibit because it is both not material and is
the type that the registrant treats as private or confidential. Additionally, ensure that
each exhibit includes a legend and brackets indicating where the information is
omitted from the filed version of the exhibit.
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-
551-3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

September 27, 2024
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted September 12, 2024
CIK No. 0002012219
Dear How Meng Hock:
            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. 1 to Draft Registration Statement on Form F-1
Income tax expense, page 59
1.We note your statement that, "[f]or the combined year ended March 31, 2024 and for the
year ended March 31, 2023, the effective income tax rates are 8.4% and 42.5%,
respectively. The decrease in our effective income tax rates is primarily attributable to a
decrease in non-taxable income." Please explain why a decrease in non-taxable income
would decrease your effective income tax rate. Explain how this statement correlates with
your disclosure on page F-45.
Cash Flow Analysis, page 60
2.We note your explanation for the fluctuation in cash flows restates information already
provided in your consolidated statements of cash flows. Please expand your analysis to
discuss the underlying reasons for the fluctuations.

September 27, 2024
Page 2
Critical Accounting Estimates
Business combination, page 63
3.We note based on your disclosure on page F-28 that you estimated the fair value of the
assets acquired and liabilities assumed using the fair value approach in combination of the
replacement cost approach and market approach. For assets and liabilities where the fair
value changed significantly from historical value, expand disclosure in your critical
accounting estimates to provide an analysis as to how fair value was determined and what
assumptions and judgments were made.
Business
Our Customers, page 82
4.You disclose that your top five customers accounted for 80% and 72% of your total sales
for the years ended March 31, 2024 and 2023, respectively, and note your
relationships with Saudia Arabian Oil Company (ARAMCO) and Halliburton. Please
revise to disclose the percentage of revenue ARAMCO and Halliburton accounted for and
revise to provide a summary of the material terms of your agreements with these
customers, including the term, termination provisions and any minimum purchase
obligations. To the extent you have other customers that accounted for 10% or more of
your revenue, please provide similar disclosure.
Our Suppliers and Raw Material Input, page 82
5.We note that Global Pipe Company and Marubeni-Itochu Tubulars Asia Pte Ltd
accounted for 29% and 45% of your total purchases for years ended March 31, 2023 and
2024, respectively. Please revise to provide a summary of the material terms of your
agreements with these suppliers. With respect to Marubeni-Itochu Tubulars Asia Pte Lte,
please file any material agreements with this supplier.
Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2
6.Based on the last sentence of the first paragraph in the reports of your independent
registered public accounting firm, it appears the accounting firm opined on the results of
operations and cash flows and not on changes in equity. Please ask your auditor to clarify
why they did not opine on changes in equity or revise accordingly.
1 Organization and Principal Activities, page F-9
We note that "Mr. How Meng Hock, Chief Executive Officer (“Mr. How”) of OMS,
Sumitomo, and OMSET PL, a newly established entity 100% owned by Mr. How, entered
into a Share Purchase Agreement with Sumitomo pursuant to which Mr. How agrees to
buy and Sumitomo agrees to sell all the ownership of OMS for a cash consideration of
$2.0 million to OMSET PL." In this regard:
•Tell us how you considered whether Sumitomo and OMSET PL are under common
control. Refer to your basis in accounting literature.
•Disclose if Mr. How, his family or other affiliates of Mr. How own any equity interest
in Sumitomo and if so, how much.
Disclose if Sumitomo or its related parties provided Mr. How with financing for the •7.

September 27, 2024
Page 3
transaction.
•Disclose who controls Sumitomo and their relationship to Mr. How, his family
members or his other affiliates.
•Disclose the business reason why Sumitomo agreed to sell OMS to Mr. How at a
significant discount.
10 Property, Plant and Equipment, page F-32
8.Since you recorded property, plant and equipment at its fair value, tell us why
accumulated depreciation rolled forward from predecessor to successor. Refer to your
basis in accounting literature.
15 Capital and Reserves, page F-39
9.We note after the completion of the April share redesignation "the Successor further
issued and allotted an aggregate of 5,000 Ordinary Shares to eight subscribers" on May 7,
2024. Disclose the purpose of this share issuance and advise us. Explain to us why you
did not record an associated expense. Further, justify retroactively restating all periods for
this share issuance. Refer us to the supporting accounting literature.
23 Related Parties, page F-47
10.We note in the table on page F-48 Sumitomo Corporation is identified as the "ultimate
controlling party of the Predecessor." In light of Mr. How serving as the Chief Executive
Officer of Sumitomo, please disclose and explain to us why "[t]hese parties ceased to be
the Successor’s related parties with effect from June 16, 2023, subsequent to OMSET PL
acquiring 100% shares in OMS Holdings Pte. Ltd. from Sumitomo Corporation." Disclose
any continuing relationships between Mr. How, Sumitomo Corporation, and the other
identified entities and advise us.
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-551-3574 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona Yieh

United States securities and exchange commission logo
June 25, 2024
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Draft Registration Statement on Form F-1
Submitted May 29, 2024
CIK No. 0002012219
Dear How Meng Hock:
            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
Risk Factors
We may not maintain the listing of our Ordinary Shares on the New York Stock Exchange...,
page 33
1.You state here that you intend to apply to list Ordinary Shares on the New York Stock
Exchange concurrently with this offering. However, your disclosure on the cover page
states that you “will not close this offering unless such Ordinary Shares will be listed on
the New York Stock Exchange at the completion of this offering.” Please confirm whether
this offering is conditional on the NYSE's approval of your listing.
Management's Discussion and Analysis of Financial Conditions and Results of Operations, page
51
2.We note that you have six reportable segments based on geographical regions. Please note
that information provided in your MD&A must relate to all separate segments and/or other

 FirstName LastNameHow Meng Hock
 Comapany NameOMS Energy Technologies Inc.
 June 25, 2024 Page 2
 FirstName LastNameHow Meng Hock
OMS Energy Technologies Inc.
June 25, 2024
Page 2
subdivisions (e.g., geographic areas, product lines) of the company. See Item 5 of Form
20-F.
Business, page 71
3.Please include a breakdown of total revenues by category of activity and geographic
market for each of the last three financial years. See Item 4.B.2 of Form 20-F.
Employees, page 88
4.We note that you have operations in Saudi Arabia, Indonesia, Malaysia, Brunei, Thailand,
and Singapore. Please disclose here the geographic location of employees as required by
Item 6.D of Form 20-F.
Consolidated Financial Statements
1 Organization and Principal Activities, page F-8
5.We refer to footnote (1) on page F-8, where you state you have control of two entities
through contractual arrangements. Please provide more robust disclosures regarding these
two subsidiaries in accordance with paragraphs 7 and 10 of IFRS 12.
2.7 Property and Equipment, page F-17
6.Please explain why you depreciate land. We refer to guidance in paragraph 58 of IAS 16.
Also, disclose the judgement and assumptions used to determine the depreciation of land
and buildings up to 60 years.
2.12 Cash and cash equivalents, page F-19
7.You disclose that cash and cash equivalents are comprised of cash in bank balances, cash
on hand and short-term fixed deposits with original maturities of six months or less. Tell
us why the maturity time period is six months or less and how you considered paragraph 7
of IAS 7 when determining this policy.
8.Disclose the jurisdiction(s) that holds your cash and cash equivalents and address to what
extent financial institutions in those jurisdictions insure your cash and cash
equivalents. Disclose any restrictions associated with the transfer of cash outside its
current jurisdiction(s).
2.18 Related Parties, page F-23
9.Disclose if your key management personnel, as well as close family members are related
parties. We refer to guidance in IAS 24.
17 - Segment Reporting, page F-32
10.With regard to your segment reconciliation, please specify and quantify items included in
the "others" column. Also, total assets and total liabilities do not reconcile to your

 FirstName LastNameHow Meng Hock
 Comapany NameOMS Energy Technologies Inc.
 June 25, 2024 Page 3
 FirstName LastName
How Meng Hock
OMS Energy Technologies Inc.
June 25, 2024
Page 3
Consolidated Statements of Financial Position on page F-3. We refer to guidance in
paragraphs 21 and 28 of IFRS 8.
General
11.Once you have an estimated offering price or range, please explain to us how you
determined the fair value of the common stock underlying your equity issuances and the
reasons for any differences between the recent valuations of your common stock leading
up to the initial public offering and the estimated offering price. This information will help
facilitate our review of your accounting for equity issuances including
stock compensation. Please discuss with the staff how to submit your response.
12.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-551-3574 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yarona Yieh