SecProbe.io

CORRESP
 1
 filename1.htm

 January 22, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Springview Holdings Ltd

 Registration Statement on Form F-1

 File No. 333-292807

 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the " Securities Act "), Univest Securities, LLC, as placement
agent, hereby joins in the request of Springview Holdings Ltd for acceleration of the effective date of the above-referenced registration
statement on Form F-1 (the " Registration Statement "), so that it becomes effective as of 9:00 a.m. Eastern Time on
Friday, January 23, 2026, or as soon thereafter as possible.

 The undersigned has and will comply, and it has
been informed or will be informed by any participating dealers that they have complied or will comply, with the requirements of Rule 15c2-8
under the Securities Exchange Act of 1934, as amended.

 [Signature Page to Follow]

 Very truly yours,

 UNIVEST SECURITIES, LLC

 By:
 /s/ Edric Yi Guo

 Name:
 Edric Yi Guo

 Title:
 CEO and Head of Investment Banking

 [Signature Page to Placement Agent's Acceleration
Request]

CORRESP
 1
 filename1.htm

 January 22, 2026

 Via EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Springview Holdings Ltd

 Registration Statement on Form F-1 (File No. 333-292807)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended, Springview Holdings Ltd, hereby requests acceleration of the effective date
of the above-referenced Registration Statement so that it will become effective at 9:00 a.m., Eastern Time, on January 23, 2026, or as
soon thereafter as practicable.

 Very truly yours,

 Springview Holdings Ltd

 By:
 /s/ Zhuo Wang

 Name:
 Zhuo Wang

 Title:
 Chief Executive Officer, Chairman of the Board (Principal Executive Officer)

CORRESP
1
filename1.htm

SPRINGVIEW HOLDINGS LTD

December 6, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington, D.C., 20549

Attn: Ms. Isabel Rivera

    Re:
    Springview Holdings Ltd

    Registration Statement on Form F-1, as amended (File No. 333-282887)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended, Springview Holdings Ltd hereby requests an acceleration of the effectiveness
of the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become effective at 4:00
p.m., Eastern Time, on December 10, 2024, or as soon thereafter as practicable.

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

    Very truly yours,

    Springview Holdings Ltd

    By:
    /s/ Zhuo Wang

    Name:
    Zhuo Wang

    Title:
    Chairman

CORRESP
1
filename1.htm

Springview
Holdings Ltd

203
Henderson Road

#06-01

Henderson
Industrial Park

Singapore
159546

November
22, 2024

Division
of Corporation Finance

Office
of Real Estate & Construction

U.S.
Securities and Exchange Commission

Washington,
DC 20549

Attn:
Ms. Isabel Rivera

    Re:
    Springview Holdings
    Ltd

    Registration Statement
    on Form F-1

    Filed October 30, 2024

    File No. 333-282887

Ladies
and Gentlemen,

This
letter is in response to your letter on November 14, 2024, in which you provided comments to the Registration Statement on Form F-1 (the
“Form F-1”) of Springview Holdings Ltd (the “Company”) filed with the U.S. Securities and Exchange Commission
on October 30, 2024. On the date hereof, the Company is filing its Amendment No. 1 to the Registration Statement on Form F-1 (the “Form
F-1/A”). We set forth below in bold the comments in your letter relating to the Form F-1 followed by our responses to the comments.

Registration
Statement on Form F-1 filed October 30, 2024

General

    1.
    We note the amount of time
    SWL (BVI) Limited and Sky Sapphire Group Limited have held their shares as well as the size of the offering relative to the number
    of common shares outstanding and held by non-affiliates. Please provide us with a detailed legal and factual analysis explaining
    your basis for determining that this secondary offering is eligible to be made under Rule 415(a)(1)(i) and why it should not be treated
    as an indirect primary offering. For guidance, refer to Securities Act Rules Compliance & Disclosure Interpretation 612.09.

RESPONSE:
We respectfully advise the Staff that the Company does not deem SWL (BVI) LIMITED and ARGENT ASIA CONSULTANCY PTE. LTD. (collectively
“the Resale Shareholders”) as “underwriters” within the meaning of Section 2(a)(11) of the Securities
Act, for reasons as set out below.

Section
2(a)(11) of the Securities Act defines an underwriter as “any person who has purchased from an issuer with a view
to, or offers or sells for an issuer in connection with, the distribution of any security, or participates or has a direct or indirect
participation in any such undertaking, or participates or has a participation in the direct or indirect underwriting of any such underwriting…”
The Division of Corporation Finance (the “Division”) provided further guidance in Compliance and Disclosure Interpretation
612.09 (January 26, 2009) on the question of whether a “purported secondary offering is really a primary offering, i.e., the Resale
Shareholders are actually underwriters selling on behalf of an issuer” is a highly fact-specific question that should take into
account the following considerations: (i) the circumstances under which they received them; (ii) how long the Resale Shareholders have
held the shares; (iii) their relationship to the issuer; (iv) the amount of shares involved; (v) whether the sellers are in the business
of underwriting securities; and (vi) whether under all the circumstances it appears that the seller is acting as a conduit for the issuer.

Factor
1: Circumstances under which the Resale Shareholders Acquired the Shares

The 1,800,000 shares to be registered here by
the Resale Shareholders were acquired from UNISTAR INVESTMENT AND ARGENT ASIA CONSULTANCY PTE. LTD. (the “Original Holders”)
respectively on March 8, 2024.

The 900,000 shares to be registered by SWL (BVI)
Limited was obtained from UNISTAR INVESTMENT for no consideration as SWL (BVI) Limited and UNISTAR INVESTMENT are beneficiary owned and
controlled by the same person, Cheng Hoe Tan. These 900,000 shares were in turned obtained by from Avanta (BVI) on January 23, 2024 in
return for consideration of $198,000.

The 900,000 shares to be registered by SKY SAPPHIRE GROUP LIMITED was obtained from ARGENT
ASIA CONSULTANCY PTE. LTD for no consideration as ARGENT ASIA CONSULTANCY PTE. LTD. and SKY SAPPHIRE GROUP LIMITED are beneficiary owned
and controlled by the same person, Samann Loh Mei Lin. These 900,000 shares were in turned obtained by from Avanta (BVI) on January 23,
2024 in return for consideration of $198,000.

The Company’s proposed initial public offering had placed a financial
burden on the controlling shareholder of the Company, Lee Siew Yian and as a result, she had to dispose a portion of their ownership of
the Company to meet their personal financial needs via Avanta (BVI), as well as to be able to continue funding the operation of the Company
to the extent that they need to.

The Resale Shareholders did not acquire the shares under circumstances
that would indicate that they were receiving compensation from the Company or that the Company had any financial interest in the sale
of these shares.

Factor
2: How Long the Resale Shareholders Have Held the Shares

The shares to be registered have been issued since the inception of
the Company. The shares were disposed by Avanta (BVI) and the Original Holders for reasons described above. The current Resale Shareholders
acquired their shares in transactions with existing stockholders and not from the Company. Even though the Resale Shareholders have held
their shares for less than one year, such Resale Shareholders cannot be assured that the initial public offering would have been approved
and/or completed. Further, although the Registration Statement covers all of the shares of the Company owned by the Resale Shareholders,
the Company believes that the period of time that each Resale Shareholder will have held the shares and have borne the economic and market
risk of such ownership, together with the additional factors described herein, evidences that each Resale Shareholder is acting for its
own behalf and is not acting as a statutory underwriter.

Factor
3: Relationship with Company

The Resale Shareholders all acquired their respective
shares from the Original Holders for his or her own investment purpose and under own account. None of the Resale Shareholders are institutional
investors, or engage in the trading of securities as in the ordinary course of business. To the Company’s knowledge, at no time
has the Resale Shareholders been affiliated with or acted as securities broker-dealers or representatives thereof.

None of the Resale Shareholders have been affiliated
with the Company in any way. They are all unrelated third parties. The consideration of the Resale Shares from the Resale Shareholders
are standalone investment decisions as evidenced by arms-length negotiations between the controlling shareholder and the Original Holders,
and between the Original Holders and the Resale Shareholders. Such negotiations between the Original Holders and the Resale Shareholders
lasted several weeks and the amount of shares ultimately purchased by the Resale Shareholders and the considerations was based solely
on the negotiations and the investment decisions made by the Resale Shareholders.

Furthermore,
the Company is neither aware of any evidence that the Resale Shareholders had any plan to act in concert with a third party to effect
a distribution of the Resale Shares. Rule 100 of Regulation M defines a “distribution” as “an offering
of securities, whether or not subject to registration under the Securities Act, that is distinguished from ordinary trading transactions
by the magnitude of the offering and the presence of special selling efforts and selling methods”. The Company is not aware of
any evidence that would suggest that any such special selling efforts or selling methods (such as investor presentations or road shows)
by or on behalf of the Resale Shareholders that have or are currently intended to take place if the Registration Statement is declared
effective.

For
this reason and the discussions above, the Company believes the Resale Shareholders did not acquire their shares with a view to distribution
and thus should not be viewed as “underwriters” in connection with the Offering of the Company.

    2

Factor
4: Whether the Resale Shareholders are in the business of underwriting securities

The
Resale Shareholders are all natural persons or investment holdings that are wholly-owned by natural persons who do not engage in the
business of trading or underwriting of securities. Furthermore, the Resale Shareholders have not entered into any underwriting relationships
with the Company, or have any contractual, legal or other relationship with the Company that would control the timing, nature or amount
of resales of the Resale Shares or even whether any Resale Shares will be resold at all under the Registration Statement.  The Resale
Shareholders will receive no commission or other payment from the Company for Resale Shareholders’ sale of Resale Shares in the
open market, and the Company will receive no portion of the proceeds from any sales of Resale Shares. Therefore, the Company believes
that the Resale Shareholders are not in the business of underwriting securities

Factor
5: Whether under All the Circumstances it Appears that the Resale Shareholders Are Acting as a Conduit for the Company

The
Company has no contractual, legal or other relationship or obligation with the Resale Shareholders that would control the timing, nature
and amount of resales of such Resale Shares following the effectiveness of the Registration Statement or whether such Resale Shares will
be resold at all by the Resale Shareholder under the Registration Statement. The Company has no contracts, commitments, arrangements
or understandings with any of the Resale Shareholders to carry out any transaction in the Resale Shares. In addition, at the time of
acquisition of the Resale Shares, to the Company’s knowledge, none of the Resale Shareholders had any agreements or understandings,
directly or indirectly, with any person to distribute such Resale Shares.

Conclusion

For
the foregoing reasons, the Company believes that the Resale Shareholders, are not and should not be considered, an “underwriter”
under Section 2(a)(11) of the Securities Act with respect to the sale of the shares in the proposed offering. The Resale Shareholder
did not acquire the Resale Shares under circumstances that would indicate that they were receiving compensation from the Company in connection
with the Resale Shares or that the Company had any financial interest in the sale of the Resale Shares. Additionally, there is no evidence
of special selling efforts or selling methods that would suggest a view to “distribution.” Finally, to the Company’s
knowledge, the Resale Shareholders are not in the business of underwriting securities. In light of these circumstances and the others
described herein, we respectfully submit that the Resale Shareholders are not acting as the underwriters on behalf of, or as a conduit
for, the Company.

    2.
    Please revise your registration
    statement to identify the selling shareholders and provide all the appropriate information required by Item 507 of Regulation S-K.

RESPONSE:
We respectfully advise the Staff that we have revised our registration statement to identify the selling shareholders and provide all
the appropriate information required by Item 507 of Regulation S-K.

Part
II. Information Not Required in Prospectus, page II-1

    3.
    Please revise to provide
    the undertakings required by Item 9 of Form F-1 and Item 512(a) of Regulation S-K.

RESPONSE:
We respectfully advise the Staff that we have revised our Form F-1/A to provide the undertakings required by Item 9 of Form F-1 and Item
512(a) of Regulation S-K.

Signatures,
page II-4

    4.
    We note that your registration
    statement is not signed by at least a majority of your board members. Please revise to include all appropriate signatures as described
    in Instruction 1 to Signatures of Form F-1.

RESPONSE:
We respectfully advise the Staff that we have revised our Form F-1/A to include all appropriate signatures as described in Instruction
1 to Signatures of Form F-1.

    3

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

    Sincerely,

    /s/ Zhuo Wang

    Zhuo Wang

    Chairman

4

November 14, 2024
Zhuo Wang
Chief Executive Officer
Springview Holdings Ltd
203 Henderson Road
#06-01
Henderson Industrial Park
Singapore 159546
Re:Springview Holdings Ltd
Registration Statement on Form F-1
Filed October 30, 2024
File No. 333-282887
Dear Zhuo Wang:
            We have conducted a limited review of 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 filed October 30, 2024
General
1.We note the amount of time SWL (BVI) Limited and Sky Sapphire Group
Limited have held their shares as well as the size of the offering relative to the number
of common shares outstanding and held by non-affiliates. Please provide us with a
detailed legal and factual analysis explaining your basis for determining that this
secondary offering is eligible to be made under Rule 415(a)(1)(i) and why it should
not be treated as an indirect primary offering. For guidance, refer to Securities Act
Rules Compliance & Disclosure Interpretation 612.09.
2.Please revise your registration statement to identify the selling shareholders and
provide all the appropriate information required by Item 507 of Regulation S-K.

November 14, 2024
Page 2
Part II. Information Not Required in Prospectus, page II-1
3.Please revise to provide the undertakings required by Item 9 of Form F-1 and Item
512(a) of Regulation S-K.
Signatures, page II-4
4.We note that your registration statement is not signed by at least a majority of your
board members. Please revise to include all appropriate signatures as described
in Instruction 1 to Signatures of Form F-1.
            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.
            Please contact Catherine De Lorenzo at 202-551-3772 or Isabel Rivera at 202-551-
3518 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Ivan Tan, Esq.

CORRESP
1
filename1.htm

Springview Holdings Ltd

203 Henderson Road #06-01

Henderson Industrial Park

Singapore 159546

September 26, 2024

VIA EDGAR

William Demarest

Kristina Marrone

Isabel Rivera

Mary Beth Breslin

Office of Real Estate & Construction

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C., 20549

    Re:
    SPRINGVIEW HOLDINGS LTD

Registration Statement
on Form F-1 (File No. 333-278521)

Initially Filed on April
5, 2024

Request for Acceleration
of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Springview Holdings Ltd (the “Company”)
hereby requests an acceleration of the effectiveness of the above-referenced Registration Statement on Form F-1 (the “F-1 Registration
Statement”), so that such Registration Statement will become effective at 4:00 p.m., Eastern Time, on September 30, 2024 or as soon
thereafter as practicable.

If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. The request may be made
by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Ortoli Rosenstadt LLP.

The Company understands that
AC Sunshine Securities, LLC, the underwriter of the offering, has joined in this request in a separate letter filed with the Securities
and Exchange Commission (the “Commission”) today.

The Company hereby acknowledges
the following:

    ●
    should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ●
    the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

    SPRINGVIEW HOLDINGS LTD

    By:
    /s/ Zhuo Wang

    Name:
    Zhuo Wang

    Title:
    Chairman of the Board of Directors and Chief Executive Officer

CORRESP
1
filename1.htm

September 26, 2024

VIA EDGAR

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention: William Demarest; Kristina Marrone;
Isabel Rivera; Mary Beth Breslin

 Re: Springview Holdings Ltd

Registration Statement on Form F-1

File No. 333-278521

Ladies and Gentlemen:

Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and
the other underwriters, hereby join in the request of Springview Holdings Ltd that the effective date of the above-referenced registration
statement be accelerated so as to permit it to become effective at 4:00 p.m., Eastern time, on Monday, September 30, 2024, or as soon
thereafter as practicable.

Pursuant to 460 under the
Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated August 7, 2024 to
underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such preliminary prospectus.

The undersigned advises
that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    AC Sunshine Securities LLC

    As representative of the underwriters

    By:
    /s/ Ying Cui

    Name:
    Dr. Ying Cui

    Title:
    President

CORRESP
1
filename1.htm

Springview Holdings Ltd

203 Henderson Road

#06-01

Henderson Industrial Park

Singapore 159546

April 5, 2024

Division of Corporation Finance

Office of Real Estate & Construction

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Ms. Isabel Rivera

    Re:
    Springview Holdings Ltd

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

    Submitted March 11, 2024

    CIK No. 0002002236

Ladies and Gentlemen,

This letter is in response to your letter on
March 26, 2024, in which you provided comments to the Amendment No. 2 to Draft Registration Statement on Form F-1(the
“Amendment No.2”) of Springview Holdings Ltd (the “Company”) submitted to the U.S. Securities and Exchange
Commission on March 11, 2024. On the date hereof, the Company is publicly filing its Registration Statement on Form F-1 (the
“Form F-1”). We set forth below in bold the comments in your letter relating to the Amendment No. 2 followed by our
responses to the comments.

Amendment No. 2 to Draft Registration Statement
on Form F-1 submitted March 11, 2024

Cover Page

1. We note the shares to be offered by selling
shareholders that were added in this amendment. Given the substantial portion of your shares being registered for resale, the short period
those shares have been held since being initially issued to and transferred by your controlling shareholder Avanta (BVI) Limited on January
23, 2024, please provide us with an analysis of your basis for determining that it is appropriate to characterize the resale transaction
as a secondary offering under Securities Act Rule 415(a)(1)(i) as opposed to an indirect primary offering. For guidance, refer to Securities
Act Rules Compliance & Disclosure Interpretation 612.09.

RESPONSE: We respectfully advise the Staff that we have removed the resale alternate prospectus and amended the language pertaining to
resale/selling shareholders throughout the Form F-1.

2. Please revise to clarify when, in relation to the primary firm commitment
offering, the selling shareholders are offering their shares, and at what price.

RESPONSE: We respectfully advise the Staff that, as discussed above, we have removed the resale alternate prospectus and amended the language
pertaining to resale/selling shareholders throughout the Form F-1.

Risk Factors, page 11

3. We note your response to prior comment 3. Please address the risks
of your reliance on related party transactions to conduct your business, or advise.

RESPONSE: We respectfully advise the Staff
that we have revised the disclosure on page 18 of the Form F-1 to include the risks of our reliance on related party transactions to
conduct our business.

Management's Discussion and Analysis of Financial Condition and
Results of Operations, page 34

4. We note your disclosure regarding payments to related parties for
the years ended December 31, 2022 and 2023. Please revise to identify the related parties and, if applicable, reconcile your disclosure
with that in Related Party Transactions starting on page 79 of your prospectus.

RESPONSE: We respectfully advise the Staff
that we have revised the disclosure on page 41 of the Form F-1 to identify the related parties relevant to the disclosures, which
reconciles with the Company’s disclosures under the Related Party Transactions section on page 80 of the Form F-1.

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

    Sincerely,

    /s/ Zhuo Wang

    Zhuo Wang

    Chairman

United States securities and exchange commission logo
March 26, 2024
Zhuo Wang
Chairman and Chief Executive Officer
Springview Holdings Ltd
203 Henderson Road
#06-01
Henderson Industrial Park
Singapore 159546
Re:Springview Holdings Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted March 11, 2024
CIK No. 0002002236
Dear Zhuo Wang:
            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
February 23, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted March 11, 2024
Cover Page
1.We note the shares to be offered by selling shareholders that were added in this
amendment. Given the substantial portion of your shares being registered for resale, the
short period those shares have been held since being initially issued to and transferred by
your controlling shareholder Avanta (BVI) Limited on January 23, 2024, please provide
us with an analysis of your basis for determining that it is appropriate to characterize the
resale transaction as a secondary offering under Securities Act Rule 415(a)(1)(i)

 FirstName LastNameZhuo Wang
 Comapany NameSpringview Holdings Ltd
 March 26, 2024 Page 2
 FirstName LastName
Zhuo Wang
Springview Holdings Ltd
March 26, 2024
Page 2

as opposed to an indirect primary offering. For guidance, refer to Securities Act Rules
Compliance & Disclosure Interpretation 612.09.
2.Please revise to clarify when, in relation to the primary firm commitment offering, the
selling shareholders are offering their shares, and at what price.
Risk Factors, page 11
3.We note your response to prior comment 3. Please address the risks of your reliance
on related party transactions to conduct your business, or advise.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
34
4.We note your disclosure regarding payments to related parties for the years ended
December 31, 2022 and 2023. Please revise to identify the related parties and, if
applicable, reconcile your disclosure with that in Related Party Transactions starting on
page 79 of your prospectus.
            Please contact William Demarest at 202-551-3432 or Kristina Marrone at 202-551-3429
if you have questions regarding comments on the financial statements and related matters. Please
contact Isabel Rivera at 202-551-3518 or Mary Beth Breslin at 202-551-3625 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Mengyi “Jason” Ye

United States securities and exchange commission logo
February 23, 2024
Zhuo Wang
Chairman and Chief Executive Officer
Springview Holdings Ltd
203 Henderson Road
#06-01
Henderson Industrial Park
Singapore 159546
Re:Springview Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted February 5, 2024
CIK No. 0002002236
Dear Zhuo Wang:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
January 16, 2024 letter.
Amended Draft Registration Statement on Form F-1 submitted February 5. 2024
Risk Factors
Our operations are and could continue to be subject to inflationary pressure..., page 17
1.We note your response to prior comment 5 that you "witnessed impacts of inflation" on
your operations and that there is no guarantee that you will be able to efficiently pass on
the resulting rise in costs to your customers. Clarify whether, in the periods in which you
witnessed such impacts, you were able to pass along costs to customers. If you have not
been able to pass along costs in the periods where you witnessed impacts, expand to
quantify the impacts you experienced so investors can assess the risk.

 FirstName LastNameZhuo Wang
 Comapany NameSpringview Holdings Ltd
 February 23, 2024 Page 2
 FirstName LastName
Zhuo Wang
Springview Holdings Ltd
February 23, 2024
Page 2
Management, page 70
2.We note your response to prior comment 13. Please revise the disclosure in your
registration statement to reflect Ms. Lee's appointment as a director based on her control
of your majority shareholder. Refer to Item 6.A.5 of Form 20-F.
Related Party Transactions, page 78
3.We acknowledge your response to prior comment 17 and your disclosure that Kong
Chuan Heng is your executive director's spouse. Please tell us how you intend to comply
with Section 13(k) of the Securities Exchange Act of 1934 with respect to the outstanding
loans made to Mr. Heng during fiscal 2022 and the six months ended June 30, 2022 and
2023.
Item 8. Exhibits and Financial Statement Schedules, page II-2
4.We acknowledge your response to prior comment 19 and the filing of the financial
support letter. Your financial statements reflect five bank loans comprising your loans and
borrowings. Please file each agreement or advise us why they are not material.
            Please contact William Demarest at 202-551-3432 or Kristina Marrone at 202-551-3429
if you have questions regarding comments on the financial statements and related matters. Please
contact Isabel Rivera at 202-551-3518 or Mary Beth Breslin at 202-551-3625 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Mengyi “Jason” Ye

United States securities and exchange commission logo
January 16, 2024
Zhuo Wang
Chairman and Chief Executive Officer
Springview Holdings Ltd
203 Henderson Road
#06-01
Henderson Industrial Park
Singapore 159546
Re:Springview Holdings Ltd
Draft Registration Statement on Form F-1
Submitted December 20, 2023
CIK No. 0002002236
Dear Zhuo Wang:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1 submitted December 20, 2023
Cover Page
1.Please reconcile your disclosure that you intend to apply for Nasdaq listing with the
statement on page 8 that you have already applied for listing. If you have already applied
for listing, please also disclose the status of the application.
Risk Factors, page 11
2.Please include risk factor disclosure about the disparate voting rights in your classes of
ordinary shares, including the number of votes per share to which each class of ordinary
shares is entitled, and the risks your capital structure presents to investors.

 FirstName LastNameZhuo Wang
 Comapany NameSpringview Holdings Ltd
 January 16, 2024 Page 2
 FirstName LastName
Zhuo Wang
Springview Holdings Ltd
January 16, 2024
Page 2
3.Please expand your risk factor regarding litigation exposure on page 13 to address the
proceedings discussed starting on page 63 of your registration statement.
4.Please update your risk factor on page 16 to disclose when the company expects to
remediate its material weaknesses.
5.We note your disclosure on page 35 regarding the potential impact of inflation on your
business. Please add a risk factor and also update this disclosure on page 35 if recent
inflationary pressures have materially impacted your operations. In this regard, identify
the types of inflationary pressures you are facing and how your business has been
affected.
Our controlling shareholder has substantial influence over our company, page 21
6.Please illustrate the risk by quantifying the percentage of voting power Avanta (BVI)
Limited will control after the offering. Also specify who has control over the shares held
by Avanta and their relationship to you.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
34
7.We note your statement that a majority of your customers are residential homeowners.
Please provide a breakdown of the percentage of your revenues generated from residential
and commercial customers.
Liquidity and Capital Resources, page 39
8.Please expand to disclose the material terms of the financial support letter referenced in
this section. Please also revise your related party transaction disclosure beginning on page
77 and provide the information required by Item 7.B of Form 20-F.
Industry Overview, page 47
9.Please clarify what entities comprise the upstream participants in Singapore's New
Construction, Reconstruction, A&A, Renovation, Bespoke Carpentry and Furniture
industry.
10.Please revise your disclosure to address what portion of the industry described in this
section is currently captured by your business plan. In particular, in light of your statement
on page 35 that a majority of your customers are residential homeowners, disclose the
portion attributable to the residential market.
Regulation, page 65
11.We note your disclosure that Springview Singapore has accumulated 17 demerit points
under the MOM system. Please clarify a timeframe for the accumulation of these demerit
points and the impact on your business.

 FirstName LastNameZhuo Wang
 Comapany NameSpringview Holdings Ltd
 January 16, 2024 Page 3
 FirstName LastNameZhuo Wang
Springview Holdings Ltd
January 16, 2024
Page 3
Management, page 69
12.Please reconcile your statement that Jordan Yi Chun Tse joined the company on
November 15, 2023 with the disclosure in the employment agreement filed as Exhibit 10.3
that Mr. Tse became the company's Chief Financial Officer on October 15, 2023.
13.To the extent that Ms. Lee was selected to serve as a member of your board of directors
under an arrangement or understanding with major shareholders, such as Avanta (BVI)
Limited, please revise to disclose the arrangement or understanding. Refer to Item 6.A.5
of Form 20-F. Please also clarify the nature of her employment with you. We note her role
is described as a director, but that she is also party to an employment agreement providing
for a base salary and discretionary bonus.
Employment Agreements, page 73
14.Please expand to disclose the material terms of these agreements, including base salary
and bonuses.
Principal Shareholders, page 75
15.In light of the disclosure on page 46 regarding the December 1, 2023 reorganization after
which both Siew Yian Lee and Kong Chuan Heng now own Avanta (BVI) Limited, please
tell us whether Kong Chuan Heng shares voting and dispositive control over the shares
held by Avanta with Siew Yian Lee and revise footnote (7) to the table if necessary.
16.We note that footnote 5 to the table on page 76 indicates that Siew Yian Lee has the
power to direct the voting and disposition of the ordinary shares held by Avanta (BVI)
Limited, and may be deemed the beneficial owner of all ordinary shares held by
Avanta (BVI) Limited. Please clarify how Ms. Lee controls Avanta (BVI) Limited when
she owns 50% of such entity. Tell us also if there is a familial relationship between Ms.
Lee and Kong Chuan Heng or whether they have a binding agreement to vote in unison.
Tell us also if any such agreement was in place relating to their prior ownership of
Springview Singapore.
Related Party Transactions, page 77
17.Please revise to disclose the basis on which each of Springview Contracts Pte. Ltd., GGL
Enterprises Pte. Ltd., and Mr. Heng Kong Chuan is a related party.
Note 13 - Related Party Balances and Transactions, page F-27
18.We note significant accounts receivable and amounts due from Springview Contracts Pte.
Ltd.  Please provide more robust disclosure regarding the nature of your relationship with
Springview Contracts Pte. Ltd., a description of the transactions that resulted in amounts
due, the contractual repayment terms of the receivables, whether any of the receivables are
considered past due, and your analysis of the collectability of the outstanding balances.

 FirstName LastNameZhuo Wang
 Comapany NameSpringview Holdings Ltd
 January 16, 2024 Page 4
 FirstName LastName
Zhuo Wang
Springview Holdings Ltd
January 16, 2024
Page 4
Item 8. Exhibits and Financial Statement Schedules, page II-2
19.Please file all material contracts as exhibits to your registration statement. We note
disclosure in the Management's Discussion and Analysis section and in your financial
statements regarding loans and borrowings and the financial support letter from Zhuo
Wang. Please file these loan agreements and the financial support letter or advise us why
they are not material.
20.Please file the contracting agreement with Springview Contracts Pte. Ltd. referenced on
page 77 or tell us why you do not believe it is required to be filed. See Item 601(b)(10)(ii)
of Regulation S-K.
            Please contact William Demarest at 202-551-3432 or Kristina Marrone at 202-551-3429
if you have questions regarding comments on the financial statements and related matters. Please
contact Isabel Rivera at 202-551-3518 or Mary Beth Breslin at 202-551-3625 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Mengyi “Jason” Ye