SecProbe.io

CORRESP
 1
 filename1.htm

 Platinum
Analytics Cayman Limited

 September
16, 2025

 Via
EDGAR

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 100
F Street, NE

 Washington,
D.C., 20549

 Attention:

 Amanda
 Kim

 Stephen
 Krikorian

 Marion
 Graham

 Mitchell
 Austin

 Re:

 Platinum
 Analytics Cayman Limited (CIK No. 0002053033)

 Registration
 Statement on Form F-1, as amended

 Initially
 Filed on May 9, 2025

 File
 No. 333-287134

 Dear
Ladies and Gentlemen:

 In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Platinum Analytics Cayman
Limited hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended, be accelerated
to and that the Registration Statement become effective at 4:30 p.m., Eastern Time, on September 18, 2025, or as soon thereafter
as practicable.

 Very
 truly yours,

 Platinum
 Analytics Cayman Limited

 By:
 /s/
 Huiyi Zheng

 Name:
 Huiyi
 Zheng

 Title:
 Chief
 Executive Officer and Director

CORRESP
 1
 filename1.htm

 September
16, 2025

 VIA
EDGAR

 United
States Securities and Exchange Commission

 100
F. Street, NE

 Washington,
DC 20549

 Attn:
 Amanda
 Kim

 Stephen
 Krikorian
 Marion
 Graham
 Mitchell
 Austin

 Re:
 Platinum Analytics Cayman Limited

 Registration Statement on Form F-1, as amended

 File No. 333-287134

 Ladies
and Gentlemen:

 As
representative of the several underwriters of the proposed offering of ordinary shares of Platinum Analytics Cayman Limited (the " Company "),
we hereby join the Company's request for acceleration of the above-referenced Registration Statement, requesting effectiveness
at 4:30 p.m., Eastern Time, on Thursday, September 18, 2025, or as soon thereafter as possible.

 The
undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended.

 [ Signature
Page Follows ]

 Sincerely,

 Kingswood Capital Partners, LLC

 By:
 /s/ Brian Herman

 Name:
 Brian Herman

 Title:
 Senior Managing Director

 [ Signature
Page to Acceleration Request ]

CORRESP
 1
 filename1.htm

 L oeb
 & L oeb LLP

 901
 New York Avenue, N.W.

 Main
 202.618.5000

 Washington,
 D.C. 20001

 Fax
 202.217.2554

 345
 Park Avenue

 Main
 212.407.4000

 New
 York, NY 10154

 Fax
 212.407.4990

 August
5, 2025

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attn:

 Amanda
 Kim

 Stephen
 Krikorian

 Marion
 Graham

 Mitchell
 Austin

 Re:

 Platinum
 Analytics Cayman Limited

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

 Filed
 July 21, 2025

 File
 No. 333-287134

 Dear
Messrs. Kim, Krikorian, Graham, and Austin:

 On
behalf of our client, Platinum Analytics Cayman Limited (the " Company "), we hereby provide a response to the comments
issued in a letter dated August 4, 2025 (the " Staff's Letter ") regarding the Company's Amendment No. 2
to Registration Statement on Form F-1 (the "Amendment No. 2"). Contemporaneously, we are filing the Amendment No. 3 to the
Registration Statement on Form F-1 via Edgar (the " Amendment No. 3 ").

 In
order to facilitate the review by the staff of the Securities and Exchange Commission (the " Staff ") of the Amendment
No. 3, we have responded, on behalf of the Company, to the comments set forth in the Staff's Letter on a point-by-point basis.
The numbered paragraphs set forth below respond to the Staff's comments and correspond to the numbered paragraph in the Staff's
Letter.

 Los
Angeles New York
Chicago Nashville Washington, DC San
Francisco Beijing Hong Kong www.loeb.com

 For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.

 United
 States Securities and Exchange Commission
 August
 5, 2025
 Page
 2

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

 NOTE
2 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

 Recent
accounting pronouncements, page F-17

 1.
 The
 dates and years referred to in the ASUs appear to have been updated to 2024 when they are supposed to be 2023. Please revise.

 Response :
The Company notes the Staff's comment and has updated the disclosures on page F-17 accordingly.

 Please
call me at 212-407-4089 if you would like additional information with respect to any of the foregoing. Thank you.

 Sincerely,

 /s/
 Andrei Sirabionian, Esq.

 Andrei
 Sirabionian, Esq.

 Partner

 cc:
Huiyi Zheng, Chief Executive Officer and Director of Platinum Analytics Cayman Limited.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 4, 2025

Huiyi Zheng
Chief Executive Officer
Platinum Analytics Cayman Limited
60 Anson Road, 17-01, Mapletree
Singapore 079914

 Re: Platinum Analytics Cayman Limited
 Amendment No. 2 to Registration Statement on Form F-1
 Filed July 21, 2025
 File No. 333-287134
Dear Huiyi Zheng:

 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 our comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Amendment No 2. to Registration Statement on Form F-1
NOTE 2 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
Recent accounting pronouncements, page F-17

1. The dates and years referred to in the ASUs appear to have been updated
to 2024
 when they are supposed to be 2023. Please revise.
 August 4, 2025
Page 2

 Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Technology
cc: Andrei Sirabionian
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Loeb
 & Loeb LLP

 901
 New York Avenue, N.W.
 Washington,
 D.C. 20001

 345
 Park Avenue
 New
 York, NY 10154

 Main
 202.618.5000
 Fax 202.217.2554

 Main 212.407.4000
 Fax 212.407.4990

 June
20, 2025

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attn:
 Amanda
 Kim

 Stephen
 Krikorian

 Marion
 Graham

 Mitchell
 Austin

 Re:
 Platinum
 Analytics Cayman Limited

 Registration
 Statement on Form F-1

 Filed
 May 9, 2025

 File
 No. 333-287134

 Dear
Messrs. Kim, Krikorian, Graham, and Austin:

 On
behalf of our client, Platinum Analytics Cayman Limited (the " Company "), we hereby provide a response to the comments
issued in a letter dated May 21, 2025 (the " Staff ' s Letter ") regarding the Company's Registration
Statement on Form F-1. Contemporaneously, we are filing the Amendment No. 1 to the Registration Statement on Form F-1 via Edgar (the
" Amendment No. 1 ").

 In
order to facilitate the review by the staff of the Securities and Exchange Commission ( the "Staff ") of the Amendment
No. 1 we have responded, on behalf of the Company, to the comments set forth in the Staff's Letter on a point-by-point basis. The
numbered paragraphs set forth below respond to the Staff's comments and correspond to the numbered paragraph in the Staff's
Letter.

 Registration
Statement on Form F-1

 Taxation,
page 80

 1. You
 state here that the statements made regarding Cayman Islands tax considerations are the opinion
 of Ogier, your Cayman Islands legal counsel. Please file the tax opinion as an exhibit or
 advise.

 Response :
The Company notes the Staff's comment and has filed the tax opinion as Exhibit 8.1 (included in Exhibit 5.1).

 United
 States Securities and Exchange Commission
 June
 20, 2025
 Page
 2

 Exhibits

 2. We
 note that the legality opinion filed as Exhibit 5.1 is not dated. Please file a signed and
 dated legality opinion prior to effectiveness.

 Response :
The Company notes the Staff's comment and has re-filed Exhibit 5.1-signed and dated.

 Please
call me at 212-407-4089 if you would like additional information with respect to any of the foregoing. Thank you.

 Sincerely,

 /s/ Andrei Sirabionian,
 Esq.

 Andrei Sirabionian, Esq.

 Partner

 cc:
Huiyi Zheng, Chief Executive Officer and Director of Platinum Analytics Cayman Limited

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 21, 2025

Huiyi Zheng
Chief Executive Officer
Platinum Analytics Cayman Limited
60 Anson Road, 17-01, Mapletree
Singapore 079914

 Re: Platinum Analytics Cayman Limited
 Registration Statement on Form F-1
 Filed May 9, 2025
 File No. 333-287134
Dear Huiyi Zheng:

 We have reviewed your 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
Taxation, page 80

1. You state here that the statements made regarding Cayman Islands tax
considerations
 are the opinion of Ogier, your Cayman Islands legal counsel. Please file
the tax
 opinion as an exhibit or advise.
Exhibits

2. We note that the legality opinion filed as Exhibit 5.1 is not dated.
Please file a signed
 and dated legality opinion prior to effectiveness.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 May 21, 2025
Page 2

 Refer to Rule 461 regarding requests for acceleration. Please allow
adequate time for
us to review any amendment prior to the requested effective date of the
registration
statement.

 Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Andrei Sirabionian
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 LOEB
 & LOEB LLP

 901 New
 York Avenue, N.W.
 Washington,
 D.C. 20001

 345 Park
 Avenue
 New York,
 NY 10154

 Main
 202.618.5000
 Fax
 202.217.2554

 Main
 212.407.4000
 Fax
 212.407.4990

 May
9, 2025

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attn:
 Amanda Kim

 Stephen Krikorian

 Marion Graham

 Mitchell Austin

 Re:
 Platinum Analytics Cayman
 Limited

 Draft Registration Statement
 on Form F-1

 Submitted April 8, 2025

 CIK No. 0002053033

 Dear
Messrs. Kim, Krikorian, Graham, and Austin:

 On
behalf of our client, Platinum Analytics Cayman Limited (the " Company "), we hereby provide a response to the comments
issued in a letter dated April 22, 2025 (the " Staff's Letter ") regarding the Company's Draft Registration
Statement on Form F-1 (the " DRS "). Contemporaneously, we are publicly filing the Registration Statement on
Form F-1 via Edgar (the " Registration Statement ").

 In
order to facilitate the review by the staff of the Securities and Exchange Commission (the " Staff ") of the Registration
Statement, we have responded, on behalf of the Company, to the comments set forth in the Staff's Letter on a point-by-point
basis. The numbered paragraphs set forth below respond to the Staff's comments and correspond to the numbered paragraph in the
Staff's Letter.

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

 Cover
Page

 1. We
 note that you have a dual class share structure and that you will be offering Class A ordinary
 shares in this offering. While you disclose the voting rights of your Class B ordinary shares
 on your cover page, please revise your cover page to highlight this dual class structure,
 clearly disclose the voting rights of your Class A ordinary shares and provide a cross-reference
 to a longer discussion of the material risks and effects of this structure.

 Response :
In response to the Staff's comment, the Company has revised its disclosure on the cover page of the Registration Statement.

 United
 States Securities and Exchange Commission
 May
 9, 2025
 Page
 2

 Management's
Discussion and Analysis of Financial Condition and Results of Operations Major customers and suppliers, page 43

 2. We
 note the revisions made here in response to prior comment 11. As previously requested, please
 further revise to summarize the material terms of your material agreements with these major
 suppliers. Additionally, please revise here and on page 58 to highlight that your main supplier,
 Shanghai Borui Finance Information Limited, is a related party and is an entity controlled
 by your CEO. Please also add a risk factor discussing any material risks to your company
 or its shareholders resulting from your main supplier being a related party and an entity
 controlled by your CEO.

 Response :
In response to the Staff's comment, the Company has revised its disclosure on pages 16, 43 and 58 of the Registration
Statement.

 3. We
 note the revisions made here in response to prior comment 13. As previously requested, please
 further revise to summarize the material terms of your material agreements with these significant
 customers. Additionally, please make similar revisions on page 58.

 Response :
In response to the Staff's comment, the Company has revised its disclosure on pages 43 and 58 of the Registration Statement.

 Principal
Shareholders, page 68

 4. We
 note that you have two classes of voting securities, Class A ordinary shares with 1 vote
 per share and Class B ordinary shares with 20 votes per share. While your Principal Shareholders
 table currently presents the beneficial ownership disclosures for holders of your Class A
 ordinary shares, please revise your table to also separately present the required beneficial
 ownership disclosures for holders of your Class B ordinary shares. Additionally, include
 a column to reflect each beneficial owner's total voting power. See Item 7.A of Form
 20-F.

 Response :
In response to the Staff's comment, the Company has revised its disclosure on page 68 of the Registration Statement.

 Please
call me at 212-407-4089 if you would like additional information with respect to any of the foregoing. Thank you.

 Sincerely,

 /s/ Andrei Sirabionian,
 Esq.

 Andrei Sirabionian, Esq.

 Partner

 cc:
Huiyi Zheng, Chief Executive Officer and Director of Platinum Analytics Cayman Limited

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 22, 2025

Huiyi Zheng
Chief Executive Officer
Platinum Analytics Cayman Limited
60 Anson Road, 17-01, Mapletree
Singapore 079914

 Re: Platinum Analytics Cayman Limited
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted April 8, 2025
 CIK No. 0002053033
Dear Huiyi Zheng:

 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 March 28, 2025 letter.

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

1. We note that you have a dual class share structure and that you will be
offering Class
 A ordinary shares in this offering. While you disclose the voting rights
of your Class
 B ordinary shares on your cover page, please revise your cover page to
highlight this
 dual class structure, clearly disclose the voting rights of your Class A
ordinary shares
 and provide a cross-reference to a longer discussion of the material
risks and effects of
 this structure.
 April 22, 2025
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Major customers and suppliers, page 43

2. We note the revisions made here in response to prior comment 11. As
previously
 requested, please further revise to summarize the material terms of your
material
 agreements with these major suppliers. Additionally, please revise here
and on page
 58 to highlight that your main supplier, Shanghai Borui Finance
Information Limited,
 is a related party and is an entity controlled by your CEO. Please also
add a risk factor
 discussing any material risks to your company or its shareholders
resulting from your
 main supplier being a related party and an entity controlled by your
CEO.
3. We note the revisions made here in response to prior comment 13. As
previously
 requested, please further revise to summarize the material terms of your
material
 agreements with these significant customers. Additionally, please make
similar
 revisions on page 58.
Principal Shareholders, page 68

4. We note that you have two classes of voting securities, Class A ordinary
shares with 1
 vote per share and Class B ordinary shares with 20 votes per share.
While your
 Principal Shareholders table currently presents the beneficial ownership
disclosures
 for holders of your Class A ordinary shares, please revise your table to
also separately
 present the required beneficial ownership disclosures for holders of
your Class B
 ordinary shares. Additionally, include a column to reflect each
beneficial owner's total
 voting power. See Item 7.A of Form 20-F.

 Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Andrei Sirabionian
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 28, 2025

Huiyi Zheng
Chief Executive Officer
Platinum Analytics Cayman Limited
60 Anson Road, 17-01, Mapletree
Singapore 079914

 Re: Platinum Analytics Cayman Limited
 Draft Registration Statement on Form F-1
 Submitted January 24, 2025
 CIK No. 0002053033
Dear Huiyi Zheng:

 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
Cover Page

1. Revise the registration cover page to include the name, address, and
telephone number
 of the agent for service.
2. You disclose you will be a "controlled company" under Nasdaq rules upon
the
 completion of this offering because Huiyi Zheng and Qihong Bao will hold
more than
 50% of the voting power. Your Principal Shareholders table on page 67
appears to
 disclose Huiyi Zheng beneficially owns 33.54% your ordinary shares and
Qihong Bao
 beneficially owns 9.95% of your ordinary shares, or 43.44% together.
Please revise to
 reconcile this apparent discrepancy or advise.
 March 28, 2025
Page 2
About this Prospectus, page ii

3. In the second paragraph under the table of contents, we note your
disclosure that "You
 should not assume that the information contained in this prospectus is
accurate on any
 date subsequent to the date set forth on the front cover of this
prospectus or that any
 information we have incorporated by reference is correct on any date
subsequent to
 the date of the document incorporated by reference, even though this
prospectus is
 delivered or shares of Ordinary Shares are sold or otherwise disposed of
on a later
 date." This statement does not appear to be consistent with your
disclosure
 obligations. Please revise to clarify that the prospectus will be
updated to the extent
 required by law and acknowledge that you are responsible for updating
the prospectus
 to contain all material information.
4. In the fourth paragraph under the table of contents, we note your
disclosure that
 representations, warranties and covenants that you have made in any
agreement filed
 as an exhibit to the registration statement were made solely for the
benefit of the
 parties and should not be relied upon as accurately representing your
current state of
 affairs. Disclosure regarding an agreement's representations, warranties
and
 covenants in a registration statement (whether through incorporation by
reference or
 direct inclusion) constitutes a disclosure to investors, and you are
required to consider
 whether additional disclosure is necessary in order to put the
information contained in,
 or otherwise incorporated into that publication, into context so that
such information
 is not misleading. If you continue to use these cautionary statements in
your
 registration statement, please revise them to remove any implication
that the
 agreements do not constitute disclosure under the federal securities
laws and to clarify
 that you will provide additional disclosure to the extent that you are
or become aware
 of the existence of any material facts that are required to be disclosed
under the
 federal securities laws and that might otherwise contradict the
representations,
 warranties and covenants contained in the agreements and will update
such disclosure
 as required by federal securities laws.
Other Pertinent Information, page iii

5. Clearly disclose how you will refer to the holding company and
subsidiaries 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. Disclose clearly the entity (including the
domicile) in which
 investors are purchasing an interest.
Corporate Structure, page 1

6. You refer to the section "Our History and Structure" for more details on
your
 corporate history. We were unable to locate a section entitled "Our
History and
 Structure." Please revise your disclosure accordingly. Additionally,
please include all
 significant subsidiaries in your organizational chart and identify the
person or entity
 that owns the equity in each depicted entity. Identify clearly the
entity in which
 investors are purchasing their interest and the entities in which the
company s
 operations are conducted.
 March 28, 2025
Page 3
Prospectus Summary, page 1

7. We note your statements that you have not independently verified
industry and market
 data obtained from various third-party sources and that the accuracy and
completeness
 of the information are not guaranteed. Please remove such disclosure or
include a
 sentence expressly confirming that you are responsible for all
disclosures in the
 registration statement.
8. Please provide more specific disclosure with regard to why you believe
that your
 products provide you with an advantage versus your competitors. For
example,
 explain how your "fully integrated suite" is "agile in integrating
cutting-edge AI
 technologies or customizing solutions to meet the specific demands of
high-growth
 markets in Asia." In addition, please provide support for you claim
regarding your
 status as "a trailblazer in leveraging advanced AI technologies for
foreign exchange
 (FX) trading and analytics."
Risk Factors
Our lack of effective internal controls over financial reporting..., page 11

9. On page 46, you disclose the audits of your financial statements for the
years ended
 September 30, 2023 and 2024 identified three "material weaknesses" in
your internal
 control over financial reporting. Please revise this risk factor to
include a discussion of
 these identified "material weaknesses."
Contractual Obligations, page 44

10. We refer to your disclosure relating to your "lease agreements for
several offices."
 Please revise to file each material lease agreement as exhibits or tell
us why
 you believe each of the leases is not material. Refer to Item 601(b)(10)
of Regulation
 S-K.
Business, page 53

11. On page F-16, you disclose that you depend on a small number of
suppliers. Please
 revise here or in your MD&A section to identify suppliers who accounted
for 10% or
 more of your purchases for the fiscal year ended September 30, 2024 and
disclose the
 material terms of any material agreements with these suppliers.
Additionally, please
 file these agreements as exhibits. Lastly, please revise to discuss your
dependence on
 a limited number of suppliers in your MD&A and add a risk factor
discussing material
 risks related to your dependence on a limited number of suppliers. See
Items 3.D, 4.B
 and 5 of Form 20-F and Item 601(b)(10) of Regulation S-K.
12. We note that you are able to offer "highly customized, AI-driven
solutions" and that
 you are "pioneering AI-driven trading and analytics solutions." Please
disclose
 whether the algorithms used in your products and services are
proprietary or open-
 source and clarify the operational status of these products.
Additionally, please add
 risk factors discussing any material risks resulting from your use of AI
technologies.
Our Customers, page 57

13. You disclose that your top two customers for the fiscal year ended
September 30,
 2024 accounted for 75.9% and 23.2% of your revenue, respectively. Please
revise to
 March 28, 2025
Page 4

 identify these customers and disclose the material terms of any material
agreements
 with these customers. Additionally, please file these agreements as
exhibits. Lastly,
 please revise to discuss your dependence on a limited number of
customers in your
 MD&A and add a risk factor discussing material risks related to your
dependence on a
 limited number of customers. See Items 3.D, 4.B and 5 of Form 20-F and
Item
 601(b)(10) of Regulation S-K.
Management, page 65

14. Please revise to identify your chief financial officer.
Employment Agreements, page 66

15. Please file the employment agreements and indemnification agreements
with each of
 your directors and executive officers.
Related Party Transactions, page 68

16. We note that you have amounts due from related parties, including an
entity
 controlled by your Chief Executive Officer, as of September 30, 2024.
Exchange Act
 Section 13(k)(1) of the Exchange Act prohibits public companies from
extending or
 maintaining credit in the form of personal loans to or for any director
or executive
 officer. Please disclose the business purpose of the loan and tell us
whether you
 believe the amounts due from this entity implicate the prohibition in
Section 13(k).
NOTE 12 - SUBSEQUENT EVENTS, page F-25

17. Please revise to disclose the date through which you evaluated
subsequent events.
 Refer to ASC 855-10-50-1(a).
General

18. We note that you disposed of your Hong Kong and Mainland China
subsidiaries on
 January 10, 2025 and are currently headquartered in Singapore. Please
revise to
 clarify the nature of your current business operations in China. In this
regard, please
 revise to clarify:

 whether you currently generate any revenue from customers in Hong
Kong or
 China, and if so, quantify the amount of revenue;
 whether any of your officers or directors reside in, or are
citizens of, Hong Kong
 or China; and
 whether you have any other business operations in Hong Kong or
China, such as
 assets located in Hong Kong or China or agreements with Hong Kong or
China-
 based suppliers.
19. We note that you did not identify an underwriter in this initial draft
registration
 statement submission. Please identify an underwriter in your next
submission or
 filing.
20. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, have presented or expect to present to potential
investors in reliance
 March 28, 2025
Page 5

 on Section 5(d) of the Securities Act, whether or not they retain copies
of the
 communications.
 Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Andrei Sirabionian
</TEXT>
</DOCUMENT>