SecProbe.io

CORRESP
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 Bancroft Capital, LLC

 501 Office Center Drive, Suite 130

 Fort Washington, PA 19034

 September 26, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:
 Megan Masterson

 Chris Dietz

 Lauren Pierce

 Larry Spirgel

 Re:
 Republic Power Group Limited (the "Company")

 Registration Statement on Form F-1, as amended

 Filed July 2, 2025

 File No. 333-288465

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the "Securities Act"),
Bancroft Capital, LLC, as the underwriter of the offering, hereby join the request of the Company that the effective date of the above-captioned
Registration Statement be accelerated so as to permit it to become effective on September 30, 2025 at 4:00 p.m., Eastern time, or as soon
thereafter as practicable, or at such other time as the Company or its outside counsel, Hunter Taubman Fischer & Li LLC, requests
by telephone that such Registration Statement be declared effective.

 Pursuant to Rule 460 under the Securities Act,
please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution
of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution
of the preliminary prospectus.

 We have complied and will continue to comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [ Signature Page Follows ]

 Very truly yours,

 BANCROFT CAPITAL, LLC

 By:
 /s/ Jason Diamond

 Name:
 Jason Diamond

 Title:
 Head of Investment Banking

 [Signature Page to the Acceleration Request
Letter-Underwriter]

CORRESP
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 Republic Power Group Limited

 #04-09 Techplace II,
5008 Ang Mo Kio Ave 5
Singapore 569874

 VIA EDGAR

 September 26, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:
 Megan Akst

 Chris Dietz

 Lauren Pierce

 Larry Spirgel

 Re:
 Republic Power Group Limited

 Registration Statement on Form F-1, as amended (File No. 333- 288465)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Republic Power Group Limited, an exempt company limited by shares organized
under the laws of the British Virgin Islands (the " Company "), hereby requests that the effective date of the above-referenced
Registration Statement on Form F-1, as amended, be accelerated so that it will become effective at 4:00 p.m. Eastern Time on September
30, 2025, or as soon thereafter as practicable.

 Very truly yours,

 /s/ Ziyang Long

 Name:
 Ziyang Long

 Title:
 Chief Executive Officer and Director

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 30, 2025

Ziyang Long
Chief Executive Officer
Republic Power Group Limited
#04-09 Techplace II
5008 Ang Mo Kio Ave 5
Singapore 569874

 Re: Republic Power Group Limited
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted May 9, 2025
 CIK No. 0001912884
Dear Ziyang Long:

 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.

Amendment No. 1 to Draft Registration Statement submitted May 9, 2025
Risk Factors
If we fail to implement and maintain and effective system of internal
controls..., page 22

1. We note your discussion of various measures you intend to undertake to
improve your
 internal controls over financial reporting. Please revise to describe
what plans, if any,
 have been implemented and clarify what remains to be completed in your
remediation
 efforts. Also, revise to disclose how long you estimate it will take to
complete your
 plan and disclose any associated material costs that you have incurred
or expect to
 incur.
 May 30, 2025
Page 2
Results of Operations
Six Months Ended December 31, 2024 Compared to Six Months Ended December 31,
2023
Gross Profit, page 38

2. We note your disclosure that the decline in gross margin was, in part,
due to
 a strategic shift in your business model. Your disclosure currently does
not reflect that
 you engaged in a strategic shift in your business. Please revise to
describe your
 strategy in shifting your business model, including steps taken and
planned, and the
 anticipated timeline for the shift.
Liquidity and Capital Resources, page 46

3. Please revise to provide further disclosure regarding the commitment by
True Sage
 International Limited to support you financially. Disclose the material
terms of any
 agreement between you and True Sage.
Quantitative and Qualitative Disclosure about Market Risk, page 54

4. Please revise to disclose the material terms of your agreements with
your major
 vendors and tell us what consideration you gave to filing these
agreements as exhibits.
 Refer to Item 610(b)(10) of Regulation S-K.
Management
Executive Compensation, page 70

5. Your disclosure that the aggregate cash compensation for executive
officers for the
 year ended June 30, 2024 was nil does not appear to be consistent with
your
 disclosure that Mr. Ziyang Long receives a monthly salary of SGD 1,400.
Please
 revise or advise.
Selling Shareholders, page 74

6. Please revise to disclose the address of each person or entity offering
to sell shares
 and the nature of any position, office, or other material relationship
that the selling
 shareholder has had within the past three years with you or any of your
predecessors
 or affiliates. Refer to Item 9.D of Form 20-F.
General

7. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.
 May 30, 2025
Page 3

 Please contact Megan Masterson at 202-551-3407 or Chris Dietz at
202-551-3408 if
you have questions regarding comments on the financial statements and related
matters. Please contact Lauren Pierce at 202-551-3887 or Larry Spirgel at
202-551-3815 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Joan Wu
</TEXT>
</DOCUMENT>

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    Prime Number Capital LLC

    12 E 49 St, Floor 27

    New York, NY 10017

March 27, 2024

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Wilson

    Jan Woo

    Megan Akst

    Chris Dietz

    Re:
    Republic Power Group Ltd. (the “Company”)

    Registration Statement on Form F-1, as amended

    Filed July 21, 2022

    File No. 333-266256

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Prime Number Capital LLC, as the underwriter of the offering, hereby joins the request of the Company that the effective date of the above-captioned
Registration Statement be accelerated so as to permit it to become effective on March 29, 2024 at 4:00 p.m., Eastern time, or as soon
thereafter as practicable, or at such other time as the Company or its outside counsel, Hunter Taubman Fischer & Li LLC, requests
by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460 under the Securities Act,
please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution
of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution
of the preliminary prospectus.

We have complied and will continue to comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    PRIME NUMBER CAPITAL LLC

    By:
    /s/ Xiaoyan Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

[Signature Page to the Acceleration Request
Letter—Underwriter]

CORRESP
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Republic Power Group Limited

158 Kallang Wat #06-08,

Singapore, Republic of Singapore S349245

VIA EDGAR

March 27, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

    Attn:
    Megan Akst

    Chris Dietz

    Charli Wilson

    Jan Woo

    Re:
    Republic Power Group Limited

    Registration Statement on Form F-1, as amended (File No.
333-266256)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Republic Power Group Limited, an exempt company limited by shares organized
under the laws of the British Virgin Islands (the “Company”), hereby requests that the effective date of the above-referenced
Registration Statement on Form F-1, as amended, be accelerated so that it will become effective at 4 p.m. Eastern Time on March 29, 2024,
or as soon thereafter as practicable.

    Very truly yours,

    /s/ Ziyang Long

    Ziyang Long

    Chief Executive Officer

CORRESP
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REPUBLIC POWER GROUP LTD.

March 14, 2024

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Megan Akst

    Chris Dietz

    Charli Wilson

    Jan Woo

    Re:
    Republic Power Group Ltd.

    Amendment No.10 to Registration Statement on Form F-1

    Filed February 1, 2024

    File No. 333-266256

Ladies and Gentlemen:

This letter is in response
to the letter dated February 21, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 11 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment No. 10 to Registration Statement
on Form F-1 filed February 1, 2024

Business

Our Business, page 48

    1.
    We note extensive discussion of AI focused technology in Southeast Asia and your disclosure that you are focused on developing your core technologies in "big data analytics, AI and IoT applications." Please indicate the products incorporating each technology in your pipeline and the stage of development of each technology.  With respect to artificial intelligence, please indicate if your algorithms are proprietary or open source, and update you risk factors to reflect the relevant risks.

Response: In response to Staff’s
comment, we have updated our disclosure on page 48 of the Amended Registration Statement to list our products incorporating each technology
in our pipeline. We have not developed any proprietary bit data analytics or IoT application technologies, instead, we used open-source
or third-party technologies of big data analytics, IoT applications in the development of our software products. We also incorporated
open-source AI models into our customized software solutions. As of the date of this response letter, we do not have proprietary AI algorithms,
but we are in the initial stage of developing our proprietary AI algorithms. We have also updated our risk factors on page 18 of the
Amended Registration Statement to reflect the relevant risks relating to the usage of open-source software and the incorporation of AI
technologies into our products.

Consolidated Financial Statements

Note 14. Subsequent Events, page F-26

    2.
    You disclose that subsequent events were evaluated through January 4, 2024, the date the consolidated financial statements were issued. However, we note that the audit opinion is dated January 31, 2024. Please advise or revise.

Response: In response to Staff’s
comment, we have updated the evaluation date of the subsequent events to March 14, 2024.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsels, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
February 21, 2024
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 10 to Registration Statement on Form F-1
Filed February 1, 2024
File No. 333-266256
Dear Ziyang Long:
            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. 10 to Registration Statement on Form F-1 filed February 1, 2024
Business
Our Business, page 48
1.We note extensive discussion of AI focused technology in Southeast Asia and your
disclosure that you are focused on developing your core technologies in "big data
analytics, AI and IoT applications." Please indicate the products incorporating each
technology in your pipeline and the stage of development of each technology. With
respect to artificial intelligence, please indicate if your algorithms are proprietary or open
source, and update you risk factors to reflect the relevant risks.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 February 21, 2024 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
February 21, 2024
Page 2
Consolidated Financial Statements
Note 14. Subsequent Events, page F-26
2.You disclose that subsequent events were evaluated through January 4, 2024, the date the
consolidated financial statements were issued. However, we note that the audit opinion is
dated January 31, 2024.  Please advise or revise.
            Please contact Megan Akst at 202-551-3407 or Chris Dietz at 202-551-3408 if you have
questions regarding comments on the financial statements and related matters. Please contact
Charli Wilson at 202-551-6388 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
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    Prime Number Capital LLC

    12 E 49 St, Floor 27,

    New York, NY 10017

September 29, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd. (the “Company”)

    Registration Statement on Form F-1, as amended

    Filed July 21, 2022

    File No. 333-266256

Ladies and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR
on September 28, 2023, in which we requested the acceleration of the effective date of the above-referenced Registration Statement for
September 29, 2023, at 4:30 p.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer
requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration
of the effective date.

[Signature Page Follows]

    Very truly yours,

    PRIME NUMBER CAPITAL LLC

    By:
    /s/ Xiaoyan Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

[Signature Page to the Withdraw Request Letter—Underwriter]

CORRESP
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REPUBLIC POWER GROUP LTD.

VIA EDGAR

September 29, 2023

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

    Registration Statement on Form F-1, as amended

    Initially Filed on July 21, 2022

    File No. 333-266256

Ladies and Gentlemen:

On September 28, 2023, we, filed a letter with the
U.S. Securities and Exchange Commission via EDGAR requesting the acceleration of the effective date of the above-referenced Registration
Statement so that it may be declared effective on September 29, 2023, at 4:30 p.m. Eastern Time, or as soon thereafter as practicable.
We are no longer requesting that such Registration Statement be declared effective at this specific date and time and we hereby formally
withdraw such request for acceleration.

Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

CORRESP
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    Prime Number Capital LLC

    12 E 49 St, Floor 27,

    New York, NY 10017

September 28, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd. (the “Company”)

    Registration Statement on Form F-1, as amended

    Filed July 21, 2022

    File No. 333-266256

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Prime Number Capital LLC, as the underwriter of the offering, hereby join the request of the Company that the effective date of the above-captioned
Registration Statement be accelerated so as to permit it to become effective on September 29, 2023 at 4:30 p.m., Eastern time, or as soon
thereafter as practicable.

Pursuant to Rule 460 of the General Rules and
Regulations of the Securities and Exchange Commission under the Securities Act, we, acting as the underwriter, wish to advise you that,
through September 28, 2023, we distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in
the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus dated September
27, 2023, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

We have complied and will continue to comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    PRIME NUMBER CAPITAL LLC

    By:
    /s/ Xiaoyan Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

[Signature Page to the Acceleration Request
Letter—Underwriter]

CORRESP
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REPUBLIC POWER GROUP LTD.

September 28, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

    Registration Statement on Form F-1, as amended

    Initially Filed on July 21, 2022

    File No. 333-266256

Ladies and Gentlemen:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Republic Power Group Ltd. hereby requests that
the effectiveness of the above-referenced Registration Statement on Form F-1, as amended (the “Registration Statement”),
be accelerated to and that the Registration Statement become effective at 4:30 p.m., Eastern Time, on September 29, 2023, or as soon thereafter
as practicable.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

CORRESP
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REPUBLIC POWER GROUP LTD.

September 27, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

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

    Filed September 22, 2023

    File No. 333-266256

Ladies and Gentlemen:

This letter is in response
to the letter dated September 26, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 9 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment No. 8 to Form F-1 filed September
22, 2023

Cover page

    1.
    Please revise the Offering Price table on the cover to include the “non-accountable expense allowance” of 1% of the gross proceeds of the offering.

Response: In response to Staff’s
comment, we have updated our disclosure on the cover page and page 94 to include the “non-accountable expense allowance” of
1% of the gross proceeds of the offering.

Exhibits

Consent of Friedman LLP, page 23.1

    2.
    Please revise to include a currently dated consent of your independent auditor. See guidance in Item 601(b)(23) of Regulation S-K.

Response: In response to Staff’s
comment, we have included a currently dated consent of our independent auditor as exhibit 23.1.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsels, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
September 26, 2023
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 8 to Registration Statement on Form F-1
Filed September 22, 2023
File No. 333-266256
Dear Ziyang Long:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 8 to Form F-1 filed September 22, 2023
Cover page
1.Please revise the Offering Price table on the cover to include the "non-accountable
expense allowance" of 1% of the gross proceeds of the offering.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 September 26, 2023 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
September 26, 2023
Page 2
Exhibits
Consent of Friedman LLP, page 23.1
2.Please revise to include a currently dated consent of your independent auditor. See
guidance in Item 601(b)(23) of Regulation S-K.
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Charli Gibbs-Tabler, Staff
Attorney, at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
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REPUBLIC POWER GROUP LTD.

September 22, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

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

    Filed September 18, 2023

    File No. 333-266256

Ladies and Gentlemen:

This letter is in response
to the letter dated September 21, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 8 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment 7 to Form F-1 filed September 18,
2023

The Offering, page 9

    1.
    You disclose net proceeds from the offering will be approximately $6,028,671, however you disclose gross proceeds of $7,040,000, underwriting discounts of $563,200 and expenses related to this offering of $812,431 which results in net proceeds of $5,664,369. Revise the filing as necessary to ensure the net offering proceeds disclosed reconciles to the detailed disclosures elsewhere in the filing and ensure the capitalization and dilution tables are revised accordingly.

Response: In response to Staff’s
comment, we have updated our disclosure on pages 9, 30 and 32 of the Amended Registration Statement. We respectfully advise the Staff
that our net proceed of $5,593,969 are derived from the gross proceeds of $7,040,000,
after deducting the underwriting discount of $563,200, a non-accountable expenses allowance of $70,400, and all expenses related to this
offering totally $812,431.

Management’s Discussion and Analysis of Financial Condition
and Results of Operations

Liquidity and Capital Resources, page 44

    2.
    Please clarify your disclosure that you believe your existing cash and cash equivalents, anticipated cash raised from financings, and anticipated cash flow from operations will be sufficient to meet your capital requirement under March 31, 2024. In this respect, please revise to disclose the minimum period of time that you will be able to conduct planned operations using currently available capital resources. We refer you to FRC 501.03(a) of Regulation S-K and Section IV of SEC Release 33-8350.

Response: In response to Staff’s
comment, we have clarified our disclosure on page 44 of the Amended Registration Statement by providing the basis for our belief in our
ability to conduct planned operations and meet the required capital needs until March 31, 2024.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsels, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
September 21, 2023
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 7 to Registration Statement on Form F-1
Filed September 18, 2023
File No. 333-266256
Dear Ziyang Long:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment 7 to Form F-1 filed September 18, 2023
The Offering, page 9
1.You disclose net proceeds from the offering will be approximately $6,028,671, however
you disclose gross proceeds of $7,040,000, underwriting discounts of $563,200 and
expenses related to this offering of $812,431 which results in net proceeds of $5,664,369.
Revise the filing as necessary to ensure the net offering proceeds disclosed reconciles to
the detailed disclosures elsewhere in the filing and ensure the capitalization and dilution
tables are revised accordingly.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 September 21, 2023 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
September 21, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 44
2.Please clarify your disclosure that you believe your existing cash and cash
equivalents, anticipated cash raised from financings, and anticipated cash flow from
operations will be sufficient to meet your capital requirement under March 31, 2024.  In
this respect, please revise to disclose the minimum period of time that you will be able to
conduct planned operations using currently available capital resources. We refer you to
FRC 501.03(a) of Regulation S-K and Section IV of SEC Release 33-8350
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Charli Gibbs-Tabler, Staff
Attorney, at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
1
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REPUBLIC POWER GROUP LTD.

September 18, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

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

    Filed May 25, 2023

    File No. 333-266256

Ladies and Gentlemen:

This letter is in response
to the letter dated June 15, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 7 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment No. 6 to Form F-1 filed May 25, 2023

Management’s Discussion and Analysis
of Financial Condition and Results of Operations

Liquidity and Capital Resources, page 44

    1.
    As previously requested in comment 7 of our letter dated April 19, 2022, please revise to disclose the minimum period of time that you will be able to conduct planned operations using only currently available capital resources. We refer you to FRC 501.03(a) and Section IV of SEC Interpretive Release 33-8350.

Response: In response to the Staff’s
comment, we updated our disclosure on page 44 of the Amended Registration Statement to clarify that the Company will be able to conduct
planned operations using only currently available capital resources until March 31, 2024.

Year Ended June 30, 2022 Compared to Year Ended June 30, 2021

Revenues, page 48

 2. Clarify your disclosure to explain what you mean when you attribute the decline in revenue from fiscal
year end 2022 vs. 2021 to the “productization of certain software products executed in the fiscal year of 2022”. Also, please
revise the factors underlying the significant decline for all material components of your revenue. For example, we note that revenue from
software development contracts are generally recognized over time and revenue from consulting and technical support services is recognized
over the contract term. Please explain why, for the six month period ended December 31, 2022, you attributed the decrease in revenue to
the fact that most of your software development projects are still “work in progress”.

Response: In response to Staff’s
comment, we updated our disclosure on page 41 of the Amended Registration Statement to clarify the decrease in revenue for the six month
period ended December 31, 2022. We have updated our disclosure on page 48 of the Amended Registration Statement to disclose the factors
underlying the decline in our revenue for fiscal year ended June 30, 2022.

Business

Sales and Marketing, page 62

 3. We note that you have new operations in the Malaysian market. Please revise your disclosure regarding
your intent to hire new sales consultants in Vietnam, Malaysia, and the rest of the Southeast Asia region. To the extent material, discuss
any material effect of government regulations on your business in Malaysia. See Item 4.B of Form 20-F.

Response: In response to the Staff’s
comment, we updated our disclosure on pages 62 and 66 of the Amended Registration Statement. For the six months ended March 31, 2023,
we had customers in Malaysia for software development services and have not yet recognized any revenue from these contracts. If we are
able to further expand our business in Malaysia in the future, we plan to then recruit sales consultant in Malaysia. As of the date of
this response letter, we do not have any operating team, or sales consultant based in Vietnam or Malaysia or in any other countries in
the Southeast Asia region. To the extent material, we have added disclosure of government regulations on our business in Malaysia on page
66 of the Amended Registration Statement.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsels, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
June 15, 2023
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 6 to Registration Statement on Form F-1
Filed May 25, 2023
File No. 333-266256
Dear Ziyang Long:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 6 to Form F-1 filed May 25, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 44
1.As previously requested in comment 7 of our letter dated April 19, 2022, please revise to
disclose the minimum period of time that you will be able to conduct planned operations
using only currently available capital resources. We refer you to FRC 501.03(a) and
Section IV of SEC Interpretive Release 33-8350.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 June 15, 2023 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
June 15, 2023
Page 2
Year Ended June 30, 2022 Compared to Year Ended June 30, 2021
Revenues, page 48
2.Clarify your disclosure to explain what you mean when you attribute the decline in
revenue from fiscal year end 2022 vs. 2021 to the "productization of certain software
products executed in the fiscal year of 2022".  Also, please revise the factors underlying
the significant decline for all material components of your revenue. For example, we note
that revenue from software development contracts are generally recognized over time
and revenue from consulting and technical support services is recognized over the contract
term. Please explain why, for the six month period ended December 31, 2022, you
attributed the decrease in revenue to the fact that most of your software development
projects are still "work in progress".

Business
Sales and Marketing, page 62
3.We note that you have new operations in the Malaysian market.  Please revise your
disclosure regarding your intent to hire new sales consultants in Vietnam, Malaysia, and
the rest of the Southeast Asia region. To the extent material, discuss any material effects
of government regulations on your business in Malaysia. See Item 4.B of Form 20-F.

            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments
on the financial statements and related matters. Please contact Charli Gibbs-Tabler, Staff
Attorney, at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
1
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REPUBLIC POWER GROUP LTD.

January 26, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

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

    Filed January 13, 2023

    File No. 333-266256

Ladies and Gentlemen:

This letter is in response
to the letter dated January 24, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 5 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment No. 4 to Form F-1 filed January 13,
2023

Management, page 53

    1.
    Please clarify whether Ziyang Long currently serves as the Chief Executive Officer or whether he will become the Chief Executive Officer upon the effectiveness of the registration statement as the disclosure indicates. We note that Mr. Long is identified as the current Chief Executive Officer on the signature page and that you entered an employment agreement with Mr. Long on December 1, 2021 as your CEO and interim CFO. To the extent that there are revised or new employment agreements with Mr. Long or any other executive officers, please discuss the material terms of those agreements.

Response: In response to the Staff’s
comment, we updated our disclosure on pages 53 and 56 of the Amended Registration Statement to clarify that Mr. Ziyang Long currently
serves as the Chief Executive Officer of the Company. The existing employment agreement has not been modified and will be filed as an
exhibit to the Amended Registration Statement.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsels, Joan Wu, Esq. and Ying Li, Esq., of Hunter
Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
January 24, 2023
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 4 to Registration Statement on Form F-1
Filed January 13, 2022
File No. 333-266256
Dear Ziyang Long:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.
Amendment No. 4 to Form F-1 filed January 13, 2023
Management, page 53
1.Please clarify whether Ziyang Long currently serves as the Chief Executive Officer or
whether he will become the Chief Executive Officer upon the effectiveness of the
registration statement as the disclosure indicates.  We note that Mr. Long is identified as
the current Chief Executive Officer on the signature page and that you entered an
employment agreement with Mr. Long on December 1, 2021 as your CEO and interim
CFO.  To the extent that there are revised or new employment agreements with Mr. Long
or any other executive officers, please discuss the material terms of those agreements.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 January 24, 2023 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
January 24, 2023
Page 2
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Charli Gibbs-Tabler, Staff
Attorney, at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
1
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REPUBLIC POWER GROUP LTD.

January 13, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Charli Gibbs-Tabler

    Jan Woo

    Megan Akst

    Christine Dietz

    Re:
    Republic Power Group Ltd.

    Amendment No.3 to Registration Statement on Form F-1

    Filed December 23, 2022

    File No. 333-266256

Ladies and Gentlemen:

This letter is in response
to the letter dated January 11, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 4 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment No. 3 to the Registration Statement Form F-1

Management’s Discussion and Analysis
of Financial Condition and Results of Operations

Liquidity and Capital Resources, page 39

    1.
    As previously requested in prior comment 7 of our letter dated April 19, 2022 and prior comment 1 of our letter dated August 2, 2022, please revise to disclose the minimum period of time that you will be able to conduct planned operations using only currently available capital resources. We refer you to FRC 501.03(a) and Section IV of SEC Interpretive Release 33-8350.

Response: In response to the Staff’s
comment, we updated our disclosure on page 39 of the Amended Registration Statement to clarify that the management of the Company believes
the Company will be able to conduct planned operations using only currently available capital resources until June 30, 2023.

Selling Shareholders, page 59

    2.
    Please revise the table to reflect only the selling shareholders who are offering shares in this prospectus as part of the underwriting agreement. We note that you have a separate Resale Prospectus for the shares being offered by selling shareholders who have not entered into an underwriting agreement. Please also revise the table in the Resale Prospectus to reflect only the shares being sold pursuant to that prospectus.

Response: In response to the Staff’s
comment, we revised the selling shareholder(s) tables on pages 59 and Alt-2 of the Amended Registration Statement, so that the table in
the Public Offering Prospectus only include the selling shareholder who is offering shares as part of the underwriting agreement, and
the table in the Resale Prospectus only reflect the selling shareholders whose shares are being sold pursuant to the Resale Prospectus.

Consolidated Financial Statements

Note 14. Subsequent events, page F-25

    3.
    You disclose that subsequent events were evaluated through December 20, 2022, the date the consolidated financial statements were issued. However, we note that the audit opinion is dated December 22, 2022. Please advise or revise.

Response: In response to the Staff’s
comment, we revised our disclosure on page F-25 to clarify that the subsequent events were evaluated through December 22, 2022.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
January 11, 2023
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 3 to Registration Statement on Form F-1
Filed December 23, 2022
File No. 333-266256
Dear Ziyang Long:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to the Registration Statement on Form F-1
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 39
1.As previously requested in prior comment 7 of our letter dated April 19, 2022 and prior
comment 1 of our letter dated August 2, 2022, please revise to disclose the minimum
period of time that you will be able to conduct planned operations using only currently
available capital resources. We refer you to FRC 501.03(a) and Section IV of SEC
Interpretive Release 33-8350.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 January 11, 2023 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
January 11, 2023
Page 2
Selling Shareholders, page 59
2.Please revise the table to reflect only the selling shareholders who are offering shares in
this prospectus as part of the underwriting agreement.  We note that you have a separate
Resale Prospectus for the shares being offered by selling shareholders who have not
entered into an underwriting agreement.  Please also revise the table in the Resale
Prospectus to reflect only the shares being sold pursuant to that prospectus.
Consolidated Financial Statements
Note 14. Subsequent events, page F-25
3.You disclose that subsequent events were evaluated through December 20, 2022, the date
the consolidated financial statements were issued.  However, we note that the audit
opinion is dated December 22, 2022.  Please advise or revise.
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters. Please contact Charli Gibbs-Tabler, Staff Attorney,
at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
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REPUBLIC POWER GROUP LTD.

December 22, 2022

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Megan Akst

    Christine Dietz

    Charli Gibbs-Tabler

    Jan Woo

    Re:
    Republic Power Group Ltd.

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

    Filed September 9, 2022

    File No. 333-266256

Dear Ms. Megan Akst:

This letter is in response
to the letter dated September 23, 2022, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 3 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Amendment No. 2 to Form F-1 filed September 9, 2022

The Offering, page 6

    1.
    Please provide us with your calculation supporting net proceeds from the offering of $13,675,700  after deducting underwriting discounts and estimated offering expenses payable. Ensure underwriting discounts and expenses related to this offering reconcile to detailed disclosures elsewhere in the filing.

Response: We prepared the following table
of underwriting discounts and offering expenses for the Staff’s review, assuming the offering price is $5 per share, and we are
offering 3,000,000 ordinary shares in this offering. We updated the amount of net proceeds from the offering to $13,217,569 and confirmed
that the underwriting discounts and expenses related to this offering reconcile to detailed disclosures elsewhere in the filing.

    Underwriting Discounts and Offering Expenses
    Amount ($)

    Underwriting discount
      975,000

    SEC registration fee
      3,392

    The Nasdaq Capital Market listing fee
      80,000

    FINRA filing fee
      5,990

    Printing and engraving expenses
      15,000

    Legal fees and expenses
      486,729

    Accounting fees and expenses
      52,000

    Transfer agent and registrar fees and expenses
      200

    Miscellaneous expenses
      164,120

    Total
      1,782,431

Capitalization, page 26

    2.
    Please supplementally provide us with a reconciliation of the change in pro forma as adjusted amounts. Ensure that the net proceeds used reconciles to the $13,675,700 net proceeds disclosed throughout the filing and in note (1) to the table.

Response: We updated our disclosure on
page 26 of the Amended Registration Statement to reflect that the pro forma as adjusted shareholders’ equity after
the offering as of June 30, 2022, will be $16,600,426. The supporting calculation is as follows:

    Amount ($)

    Shareholders’ Equity as of June 30, 2022
      3,382,857

    Gross Proceeds from the IPO
      15,000,000

    Underwriting Discounts
      (975,000 )

    Offering Expenses
      (807,431 )

    Pro Forma As Adjusted Shareholders’ Equity as of June 30, 2022
      16,600,426

We also updated the amount of net proceeds to
$13,217,569 and confirmed that the net proceeds used reconciles to the $13,217,569 net proceeds disclosed throughout the filing and in
note (1) to the capitalization table on page 26 of the Amended Registration Statement.

Dilution, page 27

    3.
    Please provide us with the calculation that supports the as adjusted net tangible book value after the offering of $16,665,320 as of December 31, 2021.

Response: We respectfully inform the Staff
that we updated our disclosure on page 27 of the Amended Registration Statement to reflect that the as adjusted net tangible
book value after the offering as of June 30, 2022, will be $0.87. The supporting calculation is as follows:

    Amount ($)

    Net Tangible Book Value as of June 30, 2022
      0.18

    Gross Proceeds from IPO
      15,000,000

    Underwriting Discount
      (975,000 )

    Offering Costs
      (807,431 )

    As Adjusted Net Tangible Book Value as of June 30, 2022
      0.87

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
September 23, 2022
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No. 2 to Registration Statement on Form F-1
Filed September 9, 2022
File No. 333-266256
Dear Mr. Long:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 2 to Form F-1 filed September 9, 2022
The Offering, page 6
1.Please provide us with your calculation supporting net proceeds from the offering
of $13,675,700 after deducting underwriting discounts and estimated offering expenses
payable.  Ensure underwriting discounts and expenses related to this offering reconcile to
detailed disclosures elsewhere in the filing.
Capitalization, page 26
2.Please supplementally provide us with a reconciliation of the change in pro forma as
adjusted amounts.  Ensure that the net proceeds used reconciles to the $13,675,700
net proceeds disclosed throughout the filing and in note (1) to the table.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 September 23, 2022 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
September 23, 2022
Page 2
Dilution, page 27
3.Please provide us with the calculation that supports the as adjusted net tangible book value
after the offering of $16,665,320 as of December 31, 2021.
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Charli Gibbs-Tabler, Staff
Attorney, at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
1
filename1.htm

REPUBLIC POWER GROUP LTD.

August 9, 2022

VIA EDGAR

Ms. Jan Woo

Legal Branch Chief

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Republic Power Group Ltd.

    Registration Statement on Form F-1

    Submitted July 21, 2022

    File No. 333-266256

Dear Ms. Jan Woo:

This letter is in response
to the letter dated August 2, 2022, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An Amendment No. 1 to the Registration Statement
on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

Registration Statement on Form F-1 filed July 21, 2022

Management’s Discussion and Analysis of Financial Condition
and Results of Operations Liquidity and Capital Resources, page 41

    1.
    As previously requested in comment 7 of our letter dated April 19, 2022, please revise to disclose the minimum period of time that you will be able to conduct planned operations using only currently available capital resources. We refer you to FRC 501.03(a) and Section IV of SEC Interpretive Release 33-8350.

Response: In response to the Staff’s
comments, we revised our disclosure on page 41 of the Amended Registration Statement to disclose the minimum period of time that we will
be able to conduct planned operations using only currently available capital resources.

Exhibit Index, page II-4

    2.
    Please file your tax opinions by Forbes Hare, your British Virgin Islands counsel, and ZICO Insights Law LLC, your Singapore counsel, as exhibits to the registration statement. Refer to Regulation S-K Item 601(b)(8).

Response: In response to the Staff’s
comments, we filed the tax opinions by Forbes Hare and ZICO Insights Law LLC as exhibits 8.1 and 8.2, respectively, to the Amended Registration
Statement.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
August 2, 2022
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Registration Statement on Form F-1
Filed July 21, 2022
File No. 333-266256
Dear Mr. Long:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.
Registration Statement on Form F-1 filed July 21, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 41
1.As previously requested in comment 7 of our letter dated April 19, 2022, please revise to
disclose the minimum period of time that you will be able to conduct planned operations
using only currently available capital resources. We refer you to FRC 501.03(a) and
Section IV of SEC Interpretive Release 33-8350.
Exhibit Index, page II-4
2.Please file your tax opinions by Forbes Hare, your British Virgin Islands counsel, and
ZICO Insights Law LLC, your Singapore counsel, as exhibits to the registration statement.
Refer to Regulation S-K Item 601(b)(8).

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 August 2, 2022 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
August 2, 2022
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Charli Gibbs-Tabler, Staff Attorney,
at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

CORRESP
1
filename1.htm

REPUBLIC POWER GROUP LTD.

July 21, 2022

VIA EDGAR

Ms. Jan Woo

Legal Branch Chief

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Republic Power Group Ltd.

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

    Submitted June 29, 2022

    CIK No. 0001912884

Dear Ms. Jan Woo:

This letter is in response
to the letter dated July 14, 2022, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Republic Power Group Ltd. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. A Registration Statement on Form F-1 (the
“Registration Statement”) is being filed to accompany this letter.

Amendment No.1 to Draft Registration Statement
on Form F-1 submitted June 29, 2022

Our business is dependent on our collaboration
with our vendors…, page 11

    1.
    Please refer to prior comment 4 and disclose the identity of the vendors, particularly Vendor A that accounted for 55% of your total purchases for the six months ended December 31, 2021, and the material terms of your agreements with your largest vendors.

Response: In response to the Staff’s
comments, we revised our disclosure on page 11 of the Registration Statement to disclose the identity of the vendors and the material
terms of our agreement with our largest vendors.

Management’s Discussion and Analysis
of Financial Condition and Results of Operations, page 41

    2.
    Please enhance the disclosures to discuss the trends, uncertainties, demands, commitment or events that are reasonably likely to have a material effect on the company’s liquidity or capital resources. For example, we note that for the year ended June 30, 2020, Heha accounted for 95.1% of your total revenues but for the six months ended December 31, 2021, three clients accounted for more than 87% of the company's total revenues: Client A for 40%, Heha for 33% and Client B for 14.4%. Please discuss any trends regarding your customer base and disclose the identities of Client A and Client B.

Response: In response to the Staff’s
comments, we revised our disclosure on page 41 of the Registration Statement to disclose the trends, uncertainties, demands, commitment
or events that are reasonably likely to have a material effect on our liquidity or capital resources.

Related Party Transaction, page 66

    3.
    Please revise the related party loan disclosure to identify the shareholder who owns Republic SC Pte Ltd.

Response: In response to the Staff’s
comments, we revised our disclosure on page 66 of the Registration Statement to identify the shareholder who owns Republic SC Pte Ltd.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. and Ying
Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212) 530-2206, respectively.

    Very truly yours,

    /s/ Ziyang Long

    Name:
    Ziyang Long

    Title:
    Chief Executive Officer

Joan Wu, Esq.

Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
July 14, 2022
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Amendment No.1 to Draft Registration Statement on Form F-1
Submitted June 29, 2022
CIK No. 0001912884
Dear Mr. Long:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No.1 to Draft Registration Statement on Form F-1 submitted June 29, 2022
Our business is dependent on our collaboration with our vendors..., page 11
1.Please refer to prior comment 4 and disclose the identity of the vendors, particularly
Vendor A that accounted for 55% of your total purchases for the six months ended
December 31, 2021, and the material terms of your agreements with your largest vendors.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
41
2.Please enhance the disclosures to discuss the trends, uncertainties, demands, commitment
or events that are reasonably likely to have a material effect on the company’s liquidity or
capital resources. For example, we note that for the year ended June 30, 2020, Heha

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 July 14, 2022 Page 2
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
July 14, 2022
Page 2
accounted for 95.1% of your total revenues but for the six months ended December 31,
2021, three clients accounted for more than 87% of the company's total revenues: Client A
for 40%, Heha for 33% and Client B for 14.4%. Please discuss any trends regarding your
customer base and disclose the identities of Client A and Client B.
Related Party Transaction, page 66
3.Please revise the related party loan disclosure to identify the shareholder who owns
Republic SC Pte Ltd.
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters. Please contact Charli Gibbs-Tabler, Staff Attorney,
at 202-551-6388 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu

United States securities and exchange commission logo
April 19, 2022
Ziyang Long
Chief Executive Officer
Republic Power Group Ltd.
158 Kallang Way #06-08
Singapore, Republic of Singapore S349245
Re:Republic Power Group Ltd.
Draft Registration Statement on Form F-1
Submitted March 18, 2022
CIK No. 0001912884
Dear Mr. Long:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
DRS on Form F-1 submitted March 18, 2022
Cover Page
1.We note that Sai Bin Loi, Chairman of the Board, beneficially owns 68.75% of the shares
prior to the offering.  To the extent you will be a "controlled company" following the
completion of this offering, please revise your cover page to disclose your status as a
"controlled company" and provide appropriate risk factor disclosure.
Prospectus Summary, page 1
2.Please disclose in the prospectus summary that you generated 95.1% and 94.1% of your
total revenues in 2021 and 2020, respectively, from one client.  Also disclose that your
independent auditors have expressed substantial doubt about the ability of Republic Power

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 April 19, 2022 Page 2
 FirstName LastNameZiyang Long
Republic Power Group Ltd.
April 19, 2022
Page 2
Group Limited to continue as a going concern.
Risk Factors, page 8
3.Please include a risk factor focused on the risks associated with Covid-19.  We note your
reference on page 27 to a risk factor that your business could be materially harmed by the
ongoing coronavirus pandemic which does not appear to be in the prospectus.
Our business is dependent on our collaboration with our vendors..., page 10
4.You state that two vendors accounted for 42.7% and 39.8% of your total purchases,
respectively, in 2021.  Please disclose the material terms of your agreements with the two
vendors, including the identity of the vendors, term and termination provisions of the
agreements, and any minimum purchase commitments.  File the agreements as exhibits.
Our business is dependent on certain major clients and changes..., page 10
5.Please disclose the material terms of your agreements with the clients who accounted
for 95.1% and 94.1% of your total revenues, respectively, in 2021 and 2020 including the
identity of the clients, the term of the agreements and termination provisions.  File the
agreements as exhibits.
We are an emerging growth company..., page 18
6.We note your disclosure here that you have irrevocably elected not to avail your company
of the exemption from new or revised accounting standards and, therefore, will be subject
to the same new or revised accounting standards as other public companies.  However, on
page 5 you disclose that you intend to take advantage of the reduced reporting
requirements and exemptions, including the longer phase-in periods for the adoption of
new or revised financial accounting standards under §107 of the JOBS Act.  Please advise
or revise.
Management's Discussion of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 37
7.Please revise to disclose the minimum period of time that you will be able to conduct
planned operations using only currently available capital resources.  We refer you to FRC
501.03(a) and Section IV of SEC Interpretive Release 33-8350.
Management, page 50
8.You state that Ad Navitas is a related party of your sole director and owned by a
shareholder.  To the extent that Sai Bin Loi is affiliated with Ad Navitas, please disclose
the nature of the relationship.
9.Please provide compensation disclosure for your executive officers for the fiscal year
ended December 31, 2021.  Refer to Item 6.B of Form 20-F.

 FirstName LastNameZiyang Long
 Comapany NameRepublic Power Group Ltd.
 April 19, 2022 Page 3
 FirstName LastName
Ziyang Long
Republic Power Group Ltd.
April 19, 2022
Page 3
Consolidated Financial Statements
Note 10 - Related Party Balances and Transactions
c. Deposit paid for acquisition of subsidiary - related party, page F-21
10.We note that you entered into a purchase agreement to acquire Consap Pte Ltd
("Consap"), for $2.4 million of which a deposit of $1.4 million has been paid to date.
Provide us with your analysis of the significance of the company pursuant to Rule 3-05 of
Regulation S-X.  If it is greater than 50% significant, please provide us with your analysis
as to whether you deem the acquisition to be probable.
Note 13 - Subsequent events, page F-25
11.Please revise to disclose the date through which you evaluated subsequent events.  Refer
to ASC 855-10-50-1(a).
Exhibits
12.Please file the consent of each director nominee who will serve as a director.  See Rule
438 of Regulation C.
General
13.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            You may contact Megan Akst, Senior Staff Accountant, at 202-551-3407 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Olivia Bobes, Law Clerk, at 202-
551-7361 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Joan Wu