SecProbe.io

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 June 16, 2025

Carlson Thow
Chief Executive Officer
Treasure Global Inc
276 5th Avenue, Suite 704 #739
New York, New York 10001

 Re: Treasure Global Inc
 Registration Statement on Form S-3
 Filed June 10, 2025
 File No. 333-287904
Dear Carlson Thow:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Rucha Pandit at 202-551-6022 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Jeffrey Wofford
</TEXT>
</DOCUMENT>

CORRESP
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 Treasure Global Inc

 276 5th Avenue, Suite 704 #739

 New York, New York 10001

 June 16, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Treasure Global Inc

 Acceleration Request for Registration Statement on Form S-3

 File No. 333-287904

 Requested Date: June 18, 2025

 Requested Time: 4:00 P.M. Eastern Time

 Dear Staff:

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended, Treasure Global Inc (the " Registrant ") hereby requests that the above-referenced
Registration Statement on Form S-3 (File No. 333-287904) (the " Registration Statement ") be declared effective
at the "Requested Date" and "Requested Time" set forth above, or as soon as practicable thereafter, or at such
later time as the Registrant or its counsel may orally request via telephone call to the staff (the " Staff ")
of the Division of Corporation Finance of the Securities and Exchange Commission (the " Commission "). The Registrant
hereby authorizes Jeffrey P. Wofford, Esq. of Sichenzia Ross Ference Carmel LLP, counsel for the Registrant, to make such request on the
Registrant's behalf.

 The Registrant acknowledges that
the Registrant 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.

 We request that we be notified
of the effectiveness of the Registration Statement by telephone Jeffrey P. Wofford, Esq. of Sichenzia Ross Ference Carmel LLP at (212)
930-9700. Thank you for your assistance.

 Very truly yours,

 /s/ Carlson Thow

 Carlson Thow

 Chief Executive Officer

 cc:
 Carlson Thow (Chief Executive Officer, Treasure Global Inc)

 Jeffrey P. Wofford, Esq. (Sichenzia Ross Ference Carmel LLP)

February 5, 2025
Carlson Thow
Chief Executive Officer
Treasure Global Inc
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc
Registration Statement on Form S-3
Filed January 28, 2025
File No. 333-284551
Dear Carlson Thow:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Rucha Pandit at 202-551-6022 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jeffrey Wofford

CORRESP
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Treasure Global Inc

276 5th Avenue, Suite 704 #739

New York, New York 10001

February 5, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Rucha Pandit

    Re:
    Treasure Global Inc

    Acceleration Request for Registration Statement on Form S-3

    File No. 333-284551

    Requested Date: February 7, 2025

    Requested Time: 4:30 P.M. Eastern Time

Dear Mr. Pandit:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, 60 Degrees Pharmaceuticals, Inc. (the “Registrant”) hereby requests
that the above-referenced Registration Statement on Form S-3 (File No. 333-284551) (the “Registration Statement”)
be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon as practicable
thereafter, or at such later time as the Registrant or its counsel may orally request via telephone call to the staff (the “Staff”)
of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). The Registrant
hereby authorizes Jeffrey P. Wofford, Esq. of Sichenzia Ross Ference Carmel LLP, counsel for the Registrant, to make such request on the
Registrant’s behalf.

The Registrant acknowledges
that the Registrant 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.

We request that we be notified
of the effectiveness of the Registration Statement by telephone Jeffrey P. Wofford, Esq. of Sichenzia Ross Ference Carmel LLP at (212)
930-9700. Thank you for your assistance.

    Very truly yours,

    /s/ Carlson Thow

    Carlson Thow

    Chief Executive Officer

    cc:
    Carlson Thow (Chief Executive Officer, Treasure Global Inc.)

    Jeffrey P. Wofford, Esq. (Sichenzia Ross Ference Carmel LLP)

November 27, 2024
Carlson Thow
Chief Executive Officer
Treasure Global Inc.
276 5th Avenue, Suite 704 #739
New York, NY 10001
Re:Treasure Global Inc.
Registration Statement on Form S-1
Filed November 18, 2024
File No. 333-283309
Dear Carlson Thow:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Scott Anderegg at 202-551-3342 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
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Treasure Global Inc

276 5th Avenue, Suite 704 #739

New York, New York

November 26, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Treasure Global Inc

    Acceleration Request for Registration Statement on Form S-1

    File No. 333-283309

    Requested Date: November 26, 2024

    Requested Time: 5:00 P.M. Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Treasure Global Inc (the “Registrant”) hereby requests that the above-referenced
Registration Statement on Form S-1 (File No. 333-283309) (the “Registration Statement”) be declared effective
at the “Requested Date” and “Requested Time” set forth above, or as soon as practicable thereafter, or at such
later time as the Registrant or its counsel may orally request via telephone call to the staff (the “Staff”)
of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”). The Registrant
hereby authorizes Jeffrey P. Wofford, Esq. of Sichenzia Ross Ference Carmel LLP, counsel for the Registrant, to make such request on the
Registrant’s behalf.

The Registrant acknowledges
that the Registrant 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.

We request that we be notified
of the effectiveness of the Registration Statement by telephone to Jeffrey P. Wofford, Esq. of Sichenzia Ross Ference Carmel LLP at (212)
930-9700. Thank you for your assistance.

    Very truly yours,

    /s/ Carlson Thow

    Carlson Thow

    Chief Executive Officer

    cc:
    Carlson Thow (Chief Executive Officer, Treasure Global Inc)

    Jeffrey P. Wofford, Esq. (Sichenzia Ross Ference Carmel LLP)

United States securities and exchange commission logo
March 28, 2024
Chong Chan Teo
Chief Executive Officer
Treasure Global Inc
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc
Registration Statement on Form S-3
Filed March 22, 2024
File No. 333-278171
Dear Chong Chan Teo:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Jenna Hough at 202-551-3063 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Wofford

CORRESP
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Treasure Global Inc

276 5th Ave 704 739

New York, NY 10001, USA

March 27, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Treasure Global Inc Request for
Acceleration

Registration Statement
on Form S-1

File No. 333-278171

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), Treasure Global Inc, a Delaware corporation (the “Company”), respectfully
requests that the effective date of its Registration Statement on Form S-1 (File No. 333-278171), as amended (the “Registration
Statement”), be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Friday, March 29, 2024, or as soon thereafter
as possible.

In making this acceleration request, the Company acknowledges
that:

    (i)
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

    (ii)
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

    (iii)
    the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Once the Registration Statement is effective, please
orally confirm the event with our counsel, Sichenzia Ross Ference Carmel LLP by calling Jeffrey Wofford at (646) 876-0618. We also respectfully
request that a copy of the written order from the Commission verifying the effective time and date of the Registration Statement be sent
to our counsel, Sichenzia Ross Ference Carmel LLP, Attention: Jeffrey Wofford, by facsimile to (212) 930-9725 or email at JWofford@SRFC.LAW.

If you have any questions regarding this request,
please contact Jeffrey Wofford of Sichenzia Ross Ference Carmel LLP at (646) 876-0618.

    Very truly yours,

    By:
    /s/ Chong Chan “Sam” Teo

    Name:
    Chong Chan “Sam” Teo

    Title:
    Chief Executive Officer

cc: Jeffrey Wofford, Sichenzia Ross Ference Carmel
LLP

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EF Hutton,

Division of Benchmark Investments, LLC

590 Madison Avenue

39th Floor

New York, New York 10022

November 8, 2023

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Treasure Global Inc

    Registration Statement on Form S-1

    File No. 333-275411

    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 (the “Securities Act”), EF Hutton, division of
Benchmark Investments, LLC (“EF Hutton”), as representative of the underwriters of the offering, hereby joins the request
of Treasure Global Inc that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it may
become effective at 5:00 p.m., Eastern Time, on Monday, November 13, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 of the
General Rules and Regulations 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
dated November 8, 2023, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned confirms
that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers that
they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection
with the above-referenced issue.

    Best Regards,

    EF Hutton,

    division of Benchmark Investments LLC

    /s/ Sam Fleischman

    Sam Fleischman

    Supervisory Principal

CORRESP
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Treasure Global Inc

276 5th Ave 704 739

New York, NY 10001, USA

November 8, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Treasure Global Inc Request for Acceleration

    Registration Statement on Form S-1

    File No. 333-275411

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), Treasure Global Inc, a Delaware corporation (the “Company”), respectfully
requests that the effective date of its Registration Statement on Form S-1 (File No. 333-275411), as amended (the “Registration
Statement”), be accelerated so that it will become effective at 5:00 p.m., Eastern Time, on Monday, November 13, 2023, or as soon
thereafter as possible.

In making this acceleration request, the Company acknowledges
that:

    (i)
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

    (ii)
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

    (iii)
    the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Once the Registration Statement is effective, please orally confirm the
event with our counsel, Sichenzia Ross Ference Carmel LLP by calling Jeffrey Wofford at (646) 876-0618. We also respectfully request that
a copy of the written order from the Commission verifying the effective time and date of the Registration Statement be sent to our counsel,
Sichenzia Ross Ference Carmel LLP, Attention: Jeffrey Wofford, by facsimile to (212) 930-9725 or email at JWofford@SRFC.LAW.

If you have any questions regarding this request,
please contact Jeffrey Wofford of Sichenzia Ross Ference Carmel LLP at (646) 876-0618.

    Very truly yours,

    By:
    /s/ Chong Chan “Sam” Teo

    Name:
    Chong Chan “Sam” Teo

    Title:
    Chief Executive Officer

cc: Jeffrey Wofford, Sichenzia Ross Ference Carmel
LLP

United States securities and exchange commission logo
August 16, 2023
Sam Teo
Chief Executive Officer
TREASURE GLOBAL INC
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:TREASURE GLOBAL INC
Draft Registration Statement on Form S-1
Submitted August 10, 2023
CIK No. 0001905956
Dear Sam Teo:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.
            Please contact Brian Fetterolf at 202-551-6613 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Wofford

CORRESP
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Treasure Global Inc

276 5th Avenue, Suite 704 #739

New York, New York

June 9, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Brian Fetterolf

Re: Treasure Global Inc Request for
Acceleration

Registration Statement
on Form S-1

File No. 333-271872

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), Treasure Global Inc, a Delaware corporation (the “Company”), respectfully
requests that the effective date of its Registration Statement on Form S-1 (File No. 333-271872) (the “Registration Statement”),
be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Tuesday, June 13, 2023, or as soon thereafter as possible.

In making this acceleration request, the Company acknowledges
that:

    (i)
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

    (ii)
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

    (iii)
    the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Once the Registration Statement is effective, please
orally confirm the event with our counsel, Carmel, Milazzo & Feil LLP by calling Jeffrey Wofford at (646) 876-0618. We also respectfully
request that a copy of the written order from the Commission verifying the effective time and date of the Registration Statement be sent
to our counsel, Carmel, Milazzo & Feil LLP, Attention: Jeffrey Wofford, by facsimile to (646) 838-1314 or email at jwofford@cmfllp.com.

If you have any questions regarding this request,
please contact Jeffrey Wofford of Carmel, Milazzo & Feil LLP at (646) 876-0618.

    Very truly yours,

    By:
    /s/ Chong Chan “Sam” Teo

    Name:
    Chong Chan “Sam” Teo

    Title:
    Chief Executive Officer

cc: Jeffrey Wofford, Carmel, Milazzo & Feil LLP

CORRESP
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May 11, 2023

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Mr. Brian Fetterolf / Ms. Lilyanna Peyser

    Re:
    TREASURE GLOBAL INC

    Draft Registration Statement on Form S-1 Submitted March 30, 2023

    CIK No. 0001905956

Dear Staff:

On behalf of Treasure Global Inc. (the “Company”),
we have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission
(the “SEC”) contained in its letter of April 27, 2023 with respect to the Company’s Draft Registration Statement
on Form S-1 (the “DRS”) as noted above.

For your convenience, the text of the Staff’s
comments is set forth below in bold, followed in each case by the Company’s responses. Please note that all references to page numbers
in the responses are references to the page numbers in the Form S-1 (the “Form S-1”) submitted concurrently with the
submission of this letter in response to the Staff’s comments.

Draft Registration Statement on Form S-1 submitted March 30,
2023

General

1. Revise to include disclosure, including
risk factor disclosure, quantifying and discussing the extent to which and under what circumstances the Selling Stockholder can make a
profit as a result of the conversion discount underlying the Convertible Debentures. In order to provide a complete picture of the incentives
of the Selling Stockholder compared to public investors, include more than one scenario regarding potential profits.

The Company has revised its disclosure under the
section headed “Selling Stockholder” to include a new subsection entitled “Potential Conversion Profits to Selling Stockholder”
which quantifies and illustrates in three different market price scenarios the profit the Selling Stockholder can make on conversions
of the Convertible Debentures as a result of the conversion discount. The Company has also included an additional risk factor that discusses
the risks to investors who purchase from the Selling Stockholder.

2. Please supplementally tell us, with a view
toward disclosure, whether the Private Placement is complete and the reasons that it is complete. In this regard, we note that you state
both that the Convertible Debentures "were issued to the Selling Stockholder" and that one of the two Convertible Debentures
will be purchased only "after certain closing conditions have been met." In addition, we note that the closing conditions set
forth in Section 6 of the securities purchase agreement appear to be within the Selling Stockholder's control and the closing conditions
set forth in Section 7 of the agreement may be waived by the Selling Stockholder; therefore it appears that the Selling Stockholder may
not be irrevocably bound to purchase the Convertible Debentures. Refer, for example, to Securities Act Sections Compliance and Disclosure
Interpretations 134.01 and 139.11. Also tell us when you anticipate the closing of the Private Placement to occur in connection with effectiveness
of this registration statement.

The second tranche Convertible Denture has not
been issued and the Company has modified the language on the cover page of the prospectus in the S-1 to make clear that only the first
tranche $2 million in principal amount Convertible Debenture has been issued. However, the Company does view the Private Placement as
complete for the reasons discussed in Securities Act Compliance and Disclosure Interpretations 134.01 and 139.11. Pursuant to the terms
of the Securities Purchase Agreement, the Selling Stockholder is irrevocably bound to purchase the second tranche $3.5 million in principal
amount Convertible Debenture at a fixed price of $3.22 million, subject only to conditions that are outside the control of the Selling
Stockholder. These conditions are set forth in Section 7 of the Securities Purchase Agreement and include (i) the Form S-1 being declared
effective by the SEC; (ii) requirements for the Company to deliver certain closing documents, (iii) the representations and warranties
made by the Company being truthful and (iv) the continued trading of the Company’s stock on Nasdaq, all of which are outside of
the control of the Selling Stockholder. Please note that the condition that the Company obtain shareholder approval for the transactions
contemplated by Private Placement has been satisfied as demonstrated by the Schedule 14C filed by the Company with the SEC on March 17,
2023, as well as the condition that the Company deliver an opinion of counsel, which has been satisfied prior to the closing of the first
tranche. Section 6 of the Securities Purchase Agreement sets forth the conditions on which the Company is obligated to sell the second
tranche Convertible Debenture to the Selling Stockholder. These conditions do not provide the Selling Stockholder with any control over
its purchase obligation as the Company can waive any of or all the conditions at any time. The Selling Stockholder’s ability to
waive the conditions set forth in Section 7 does not make its purchase obligation within its control and any waiver of these conditions
by the Selling Stockholder only decreases the steps the Company is required to take prior to the Selling Stockholder’s purchase
of the second tranche Convertible Debenture. The Company has revised the cover page of the prospectus and pages 6 and 7 of the Form S-1
to state that the second tranche Convertible Debenture will be issued shortly after the effective date of the registration statement related
to this prospectus and has deleted any disclosure that suggests the Selling Stockholder’s obligation to purchase the second tranche
Convertible Debenture is uncertain. The Company anticipates issuing the second tranche of Convertible Dentures and receiving the purchase
price from the Selling Stockholder within two days after the effective date of the Form S-1.

3. With a view toward disclosure, tell us the
method by which you determined the number of shares of common stock covered by this registration statement. In this regard, note that
you should register an amount of shares based on a reasonable good-faith estimate of the maximum amount of shares needed for conversion.

The Company calculated the number of shares being
registered by dividing (x) the sum of $5.5 million (the principal amount of the Convertible Debentures) plus $220,000 (12 months of accrued
interest at 4% per annum) by (y) $0.25 (the conversion floor price). The Selling Stockholder is requiring the Company to register this
amount and it is the Company’s good faith estimate of the maximum number of shares needed for conversion. The Company has included
this calculation in the last paragraph under the section headed “Prospectus Summary—Private Placement of Convertible
Debentures—Terms of Convertible Debentures” on page 7 of the Form S-1.

4. Please disclose the total dollar value of
the securities underlying the Convertible Debentures (i.e., the number of shares of common stock covered by this registration statement)
as of the date of the sale of the Convertible Debentures (i.e., using the market price per share for those securities on the date of the
sale of the Convertible Debentures).

The number of shares of common stock covered by
the Form S-1 is 22,880,000 and the closing price of the Company’s common stock on February 28,2023 (the date of the sale) was $1.56.
Therefore, the total value of the securities underlying the Convertible Debentures on the date of sale was $35,692,800. The Company has
disclosed this amount in the last paragraph under the section headed “Prospectus Summary—Private Placement of Convertible
Debentures—Terms of Convertible Debentures” on page 7 of the Form S-1.

5. Revise to discuss the payments (other than
repayments on principal) that you may be required to make to the Selling Stockholder in connection with the Private Placement and conversion
of Convertible Debentures, including the total dollar amount that you will pay in interest on each Convertible Debenture in both the case
that there is not an Event of Default and the case that there is an Event of Default. Compare such amounts to the gross proceeds to be
paid to you from the sale of the Convertible Debentures. Clarify whether interest accrues on the full subscription amount of $5,500,000
or the purchase price(s) paid by the Selling Stockholder.

The Company has discussed the payments
(other than repayments on principal) that it may be required to make to the Selling Stockholder in connection with the Private
Placement and conversion of Convertible Debentures, including the total dollar amount that you will pay in interest on each
Convertible Debenture in both the case that there is not an Event of Default and the case that there is an Event of Default and
compared such amounts to the gross proceeds to be paid to you from the sale of the Convertible Debentures under the section headed
“Prospectus Summary—Private Placement of Convertible Debentures—Potential Charges to the Company Under the
Convertible Debentures” on pages 7 and 8 of the Form S-1. The Company has clarified that interest accrues on the full $5.5
million principal amount of the Convertible Debentures in the second paragraph under the section headed “Prospectus
Summary—Private Placement of Convertible Debentures—Terms of Convertible Debentures” on page 6 of the Form
S-1.

6. Where you disclose that the purchase price
with respect to each Convertible Debenture is 92% of the initial principal amount of such Convertible Debenture, please include the dollar
amount you paid in connection with the $2,000,000 Convertible Debenture and the dollar amount you will pay in connection with the $3,500,000
Convertible Debenture.

The Company has made the requested revisions on
page 6 of the Form S-1.

7. File the form of convertible debenture,
securities purchase agreement and registration rights agreement as exhibits to the registration statement. Refer to Item 601(b) of Regulation
S-K.

The Company has filed the form of convertible
debenture, securities purchase agreement and registration rights agreement as Exhibits 10.2, 10.1 and 10.3 to the Form S-1, respectively.

8. In order to make the discussion of dilution
more accessible to investors, please revise the first risk factor on page 10 to include the number of shares currently outstanding and
the number of shares currently held by non-affiliates of the company.

The Company has made the requested revision to
the risk factor.

9. Please include disclosure regarding the
Trigger Events and Events of Default described in the form of convertible debenture, as well as their potential impact on your stockholders
and any risks they pose to your stockholders. Please also disclose any risks associated with the conversion ratio being tied to the market
value of the common stock and being subject to a floor.

The Company has added disclosure regarding the
Trigger Events and Events of Default on pages 6 and 7 of the Form S-1 under the heading Prospectus Summary—Private Placement
of Convertible Debentures—Terms of Convertible Debentures.” Initially there were two Trigger Events, one of which occurs
when the number of shares of the Company’s common stock issued to the Selling Stockholder exceeds 95% of the amount issuable under
a share issuance cap included in the terms of the Convertible Debentures. This Trigger Event has not been described as it has not occurred
and is no longer applicable. Pursuant to the terms of the Convertible Debentures this Trigger Event was eliminated on the effective date
the stockholder approval obtained by the Company to the transactions contemplated by the Private Placement. The effectiveness of this
approval eliminated the Company’s requirement to comply with the Nasdaq 20% Rule and is demonstrated by the Company’s Schedule
14C described above in Comment Response 2.. The Company has also added a risk factor related to the Trigger Event and an Event of Default.
The Company describes the risks associated with the conversion ratio being tied to the market value of the Company’s common stock
in the first two risk factors on pages 10 and 11 of the Form S-1. The Company believes the $0.25 floor is a benefit to investors in that it would limit dilution
to investors voting power and it would be unlikely that the Selling Stockholder would effect a conversion if the market price of the Company’s
common stock is less than the floor price.

We trust that the above is responsive to your
comments.

Should you have any questions relating to the
foregoing or wish to discuss any aspect of the Company’s filing, please contact me at 646-876-0618.

    Sincerely,

    /s/Jeffrey Wofford

    Jeffrey Wofford, Esq.

    Carmel, Milazzo & Feil LLP

United States securities and exchange commission logo
April 27, 2023
Sam Teo
Chief Executive Officer
TREASURE GLOBAL INC
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:TREASURE GLOBAL INC
Draft Registration Statement on Form S-1
Submitted March 30, 2023
CIK No. 0001905956
Dear Sam Teo:
            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.
Draft Registration Statement on Form S-1 submitted March 30, 2023
General
1.Revise to include disclosure, including risk factor disclosure, quantifying and discussing
the extent to which and under what circumstances the Selling Stockholder can make a
profit as a result of the conversion discount underlying the Convertible Debentures. In
order to provide a complete picture of the incentives of the Selling Stockholder compared
to public investors, include more than one scenario regarding potential profits.
2.Please supplementally tell us, with a view toward disclosure, whether the Private
Placement is complete and the reasons that it is complete. In this regard, we note that you
state both that the Convertible Debentures "were issued to the Selling Stockholder" and
that one of the two Convertible Debentures will be purchased only "after certain closing

 FirstName LastNameSam Teo
 Comapany NameTREASURE GLOBAL INC
 April 27, 2023 Page 2
 FirstName LastNameSam Teo
TREASURE GLOBAL INC
April 27, 2023
Page 2
conditions have been met." In addition, we note that the closing conditions set forth in
Section 6 of the securities purchase agreement appear to be within the Selling
Stockholder's control and the closing conditions set forth in Section 7 of the agreement
may be waived by the Selling Stockholder; therefore it appears that the Selling
Stockholder may not be irrevocably bound to purchase the Convertible Debentures. Refer,
for example, to Securities Act Sections Compliance and Disclosure Interpretations 134.01
and 139.11.  Also tell us when you anticipate the closing of the Private Placement to occur
in connection with effectiveness of this registration statement.
3.With a view toward disclosure, tell us the method by which you determined the number of
shares of common stock covered by this registration statement.  In this regard, note that
you should register an amount of shares based on a reasonable good-faith estimate of the
maximum amount of shares needed for conversion.
4.Please disclose the total dollar value of the securities underlying the Convertible
Debentures (i.e., the number of shares of common stock covered by this registration
statement) as of the date of the sale of the Convertible Debentures (i.e., using the market
price per share for those securities on the date of the sale of the Convertible Debentures).
5.Revise to discuss the payments (other than repayments on principal) that you may be
required to make to the Selling Stockholder in connection with the Private Placement and
conversion of Convertible Debentures, including the total dollar amount that you will
pay in interest on each Convertible Debenture in both the case that there is not an Event of
Default and the case that there is an Event of Default.  Compare such amounts to the gross
proceeds to be paid to you from the sale of the Convertible Debentures. Clarify whether
interest accrues on the full subscription amount of $5,500,000 or the purchase price(s)
paid by the Selling Stockholder.
6.Where you disclose that the purchase price with respect to each Convertible Debenture is
92% of the initial principal amount of such Convertible Debenture, please include the
dollar amount you paid in connection with the $2,000,000 Convertible Debenture and the
dollar amount you will pay in connection with the $3,500,000 Convertible Debenture.
7.File the form of convertible debenture, securities purchase agreement and registration
rights agreement as exhibits to the registration statement.  Refer to Item 601(b) of
Regulation S-K.
8.In order to make the discussion of dilution more accessible to investors, please revise the
first risk factor on page 10 to include the number of shares currently outstanding and the
number of shares currently held by non-affiliates of the company.
9.Please include disclosure regarding the Trigger Events and Events of Default described in
the form of convertible debenture, as well as their potential impact on your stockholders
and any risks they pose to your stockholders.  Please also disclose any risks associated
with the conversion ratio being tied to the market value of the common stock and being
subject to a floor.

 FirstName LastNameSam Teo
 Comapany NameTREASURE GLOBAL INC
 April 27, 2023 Page 3
 FirstName LastName
Sam Teo
TREASURE GLOBAL INC
April 27, 2023
Page 3
            Please contact Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jeffrey Wofford

CORRESP
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EF Hutton,

Division of Benchmark Investments, LLC

590 Madison Avenue, 39th Floor

New York, NY 10022

August 8, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Treasure Global Inc

    Registration Statement on Form S-1, as amended

    Initially Filed April 19, 2022

    File No. 333-264364

Ladies and Gentlemen:

In accordance with
Rule 461 under the Securities Act of 1933, as amended (the “Act”), EF Hutton, division of Benchmark Investments, LLC,
as representative of the several underwriters, hereby joins Treasure Global Inc (the “Company”) in requesting that
the Securities and Exchange Commission take appropriate action to cause the Registration Statement on Form S-1, as amended (File No. 333-264364)
(the “Registration Statement”), to become effective on Wednesday, August 10, 2022, at 4:30 p.m., Eastern Time, or as
soon thereafter as practicable, or at such other time as the Company or its outside counsel, Carmel, Milazzo & Feil LLP, request
by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460
of the General Rules and Regulations of the Securities and Exchange Commission under the Act, please be advised that we will take
reasonable steps to secure adequate distribution of the prospectus to underwriters, dealers, institutions and others prior to the
requested effective time of the Registration Statement.

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

    Very truly yours,

    EF Hutton, division of Benchmark Investments, LLC

    By:
    /s/ Sam Fleischman

    Name:
    Sam Fleischman

    Title:
    Supervisory Principal

CORRESP
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Treasure Global Inc

276 5th Avenue Suite 704 #739

New York, NY 10001

August 8, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Scott

Re: Treasure Global Inc Request for Acceleration

Registration Statement
on Form S-1, as amended

File No. 333- 264364

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), Treasure Global Inc, a Delaware corporation (the “Company”),
respectfully requests that the effective date of its Registration Statement on Form S-1 (File No. 333-264364), as amended (the
“Registration Statement”), be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday,
August 10, 2022, or as soon thereafter as practicable. By separate letter, the representative of the underwriters of the issuance
of the securities being registered join this request for acceleration.

Once the Registration Statement is effective, please
orally confirm the event with our counsel, Carmel, Milazzo & Feil LLP by calling Jeffrey Wofford at (646) 876-0618.

    Very truly yours,

    By:
    /s/ Chong Chan “Sam” Teo

    Name: Chong Chan “Sam” Teo

    Title: Chief Executive Officer

cc: Jeffrey Wofford, Carmel, Milazzo & Feil LLP

CORRESP
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EF Hutton,

Division of Benchmark Investments, LLC

590 Madison Avenue, 39th Floor

New York, NY 10022

July 13, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Treasure Global Inc

Registration Statement
on Form S-1, as amended

Initially Filed
April 19, 2022

File No. 333-264364

Ladies and Gentlemen:

Reference is
made to our letter, filed as correspondence via EDGAR on July 11, 2022, in which EF Hutton, division of Benchmark Investments,
LLC, as representative of the several underwriters, joined Treasure Global Inc in requesting the acceleration of the effective
date of the above-referenced Registration Statement on Form S-1 for 4:30 p.m., Eastern Time, on Wednesday, July 13, 2022, 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.

    Very truly yours,

    EF Hutton, division of Benchmark Investments, LLC

    By:
    /s/ Sam Fleischman

    Name:
    Sam Fleischman

    Title:
    Supervisory Principal

CORRESP
1
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Treasure Global Inc.

276 5th Avenue Suite 704 #739

New York, NY 10001

July 13, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Treasure Global Inc.

Registration Statement on Form S-1, as amended

File No. 333- 264364

Ladies and Gentlemen:

Reference
is made to our letter, filed as correspondence via EDGAR on July 11, 2022, in which we requested the acceleration of the effective date
of the above-referenced Registration Statement on Form S-1 for 4:30 p.m., Eastern Time, on Wednesday, July 13, 2022, 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.

If you have any questions regarding
this request, please contact Jeffrey Wofford of Carmel, Milazzo & Feil LLP at (646) 876-0618.

    Very Truly Yours,

    By: /s/ Chong Chan “Sam” Teo

    Name: Chong Chan “Sam” Teo

    Title: Chief Executive Officer

cc: Jeffrey Wofford, Carmel, Milazzo & Feil LLP

CORRESP
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EF Hutton,

Division of Benchmark Investments, LLC

590 Madison Avenue, 39th Floor

New York, NY 10022

July 11, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Treasure Global Inc

Registration Statement
on Form S-1, as amended

Initially Filed
April 19, 2022

File No. 333-264364

Ladies and Gentlemen:

In accordance with
Rule 461 under the Securities Act of 1933, as amended (the “Act”), EF Hutton, division of Benchmark Investments, LLC,
as representative of the several underwriters, hereby joins Treasure Global Inc (the “Company”) in requesting that
the Securities and Exchange Commission take appropriate action to cause the Registration Statement on Form S-1, as amended (File No. 333-264364)
(the “Registration Statement”), to become effective on Wednesday, July 13, 2022, at 4:30 p.m., Eastern Time, or as
soon thereafter as practicable, or at such other time as the Company or its outside counsel, Carmel, Milazzo & Feil LLP, request
by telephone that such Registration Statement be declared effective.

Pursuant to Rule 460
of the General Rules and Regulations of the Securities and Exchange Commission under the Act, please be advised that we will take
reasonable steps to secure adequate distribution of the prospectus to underwriters, dealers, institutions and others prior to the
requested effective time of the Registration Statement.

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

    Very truly yours,

    EF Hutton, division of Benchmark Investments, LLC

    By:
    /s/ Sam Fleischman

    Name:
    Sam Fleischman

    Title:
    Supervisory Principal

CORRESP
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Treasure Global Inc

276 5th Avenue Suite 704 #739

New York, NY 10001

July 11, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Treasure Global Inc Request
for Acceleration

Registration
Statement on Form S-1, as amended

File
No. 333- 264364

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under
the Securities Act of 1933, as amended (the “Securities Act”), Treasure Global Inc, a Delaware corporation (the “Company”),
respectfully requests that the effective date of its Registration Statement on Form S-1 (File No. 333-264364), as amended (the
“Registration Statement”), be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday,
July 13, 2022, or as soon thereafter as practicable. By separate letter, the representative of the underwriters of the issuance
of the securities being registered join this request for acceleration.

Once the Registration Statement is effective,
please orally confirm the event with our counsel, Carmel, Milazzo & Feil LLP by calling Jeffrey Wofford at (646) 876-0618.

    Very truly yours,

    By:
    /s/ Chong Chan “Sam” Teo

    Name: Chong Chan “Sam” Teo

    Title: Chief Executive Officer

cc: Jeffrey Wofford, Carmel, Milazzo &
Feil LLP

United States securities and exchange commission logo
June 2, 2022
Chong Chan Teo
Chief Executive Officer
Treasure Global Inc.
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc.
Amendment No. 1 to Registration Statement on Form S-1
Response Filed May 25, 2022
File No. 333-264364
Dear Mr. Teo:
            We have reviewed your response letter 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 this comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our May 13, 2022 letter.
Amendment No. 1 to Registration Statement on Form S-1
Notes to Unaudited Condensed Consolidated Financial Statements
Note 2 – Summary of significant accounting policies
Revenue recognition
Product Revenues, page F-10
1.We have reviewed your response to comment 1. Please revise your accounting
policy disclosure to include considerations referenced in your response. In particular, your
assertion that the Company pre-purchases and prepays for inventory prior to posting your
E-vouchers for sale and prior to taking orders from customers, along with your
consideration of the indicators referenced would be useful information to investors in
understanding your basis in determining the Company to be the principal in the sale of E-

 FirstName LastNameChong Chan Teo
 Comapany NameTreasure Global Inc.
 June 2, 2022 Page 2
 FirstName LastName
Chong Chan Teo
Treasure Global Inc.
June 2, 2022
Page 2
vouchers.
            You may contact Abe Friedman at 202-551-8298 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer López Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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May 4, 2022

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Treasure Global Inc.

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

    Filed May 4, 2022

    File No. 333-264364

Dear Staff:

On behalf of Treasure Global Inc. (the “Company”),
we have set forth below responses to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “SEC”) contained in its letter dated as of May 13, 2022 with respect to the Company’s
Amendment No.1 to Registration Statement on Form S-1 filed with the SEC by the Company on May 4, 2022 (“Form S-1/A”).
For your convenience, the text of the Staff’s comments is set forth below in bold, followed in each case by the Company’s
responses. Please note that the Company is not filing Amendment No.2 with concurrently with the submission of this letter in response
to the Staff’s comments, but will file Amendment No.2 after the Company receives its response to this letter from the Staff.

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

Notes to Unaudited Condensed Consolidated Financial Statements

Revenue recognition

Product Revenues, page F-10

1. We have
reviewed your response to comment 2. In your response you state the Company purchases gift cards (or E-vouchers) in batches and
has control over the applicable gift cards (or E-vouchers), however, we note from the filing that your inventory balance appears
to be less than would be needed to support a single day of sales. Please tell us how you would fulfill an order to a customer for
a gift card (or E-voucher) when it does not appear that you have the inventory on hand prior to the customer's order. In your response,
tell us your considerations of ASC 606-10-55-37 which states "an entity does not necessarily control a specified good if the
entity obtains legal title to that good only momentarily before legal title is transferred to a customer." Additionally, please
tell us the time frame from when you obtain the inventory, when an order is received from a customer and when the ordered gift
card (or E-voucher) is delivered to that particular customer.

The Company has
responded to the staff’s concerns by restating the concerns raised in comment 1 separately and then responding to them. Also
based on the Company’s conversation with the accounting Staff on May 18, 2022, it has also included a discussion about the
three indications of control set forth in ASC 606-10-55-39 and has distinguished the Company’s purchases and sales from ASC
606-10-55-330 to 334 - Example 48 - Arranging for the Provision of Goods or Services (Entity is an Agent), the example cited by
the accounting Staff in the May 18 conversation.

(i) The Company’s
inventory balance appears to be less than would be needed to support a single day of sales. Please describe how the Company would
fulfill an order to a customer for an E-Voucher if it does not have the inventory on hand prior to the customer’s order.

Based on the Staff’s
letter and the Company’s conversion with the accounting Staff on May 18, 2022, the Company’s understands that the inventory
balance referred to by the Staff is its December 31, 2021 inventory balance of $137,5011
and the single day sales number that the Staff refers to is average daily revenue of approximately $237,393 ($42,730,654 of revenue
during the six-month period ending December 31, 2021 divided by 180 days). The Company does not believe it is appropriate to match
the period ending inventory with average daily revenue because the Company’s inventory balance at the end of any quarter
is artificially low. At the end of each quarter in the normal course of business, the Company provides discounts and other promotions
to its customers to maximize its quarterly revenues, which also has the effect of substantially lowering inventory levels during
the last days of each quarterly period. The Company also had a high of $1,511,478 of daily inventory during such period. Therefore,
the Company believes it more appropriate to match average daily revenue with average daily inventory during the applicable period.
The Company maintained an average daily inventory of $0.65 million for the six-month period ending December 31, 2021, which supported
2.24 days of sales during such period.

The following
table shows the highest, lowest, average and quarterly end inventory levels for the Company and the highest, lowest and average
number of days it holds inventory, in each case by fiscal quarter since it began operations in Q3 for fiscal year 2021 until its
latest completed fiscal quarter, Q3 for fiscal year 2022 (based on the Company’s June 30 fiscal year end):

    Fiscal Quarter
    Highest
 Daily
 Inventory
 Amount
 during the
 Quarter
    Date-of
 Highest
  Daily

Inventory

Amount
    Lowest
 Daily
 Inventory
 Amount
    Date-of
 Lowest
 Daily
 Inventory
 Amount
    Average
 Daily
 Inventory
 Amount 2
    Inventory
 Amount
 On Last
 Day of
 Quarter
    Average
 Daily
 Revenue
 during
  the
 Quarter
 Quarter
    Highest
 Number of
 Days of
 Inventory
  on Hand
 during the
 Quarter
    Lowest
 Number of
 Days of
 Inventory
 on Hand
 during the
 Quarter
    Average
 Number of
 Days of
 Inventory
 on Hand
 during the
 Quarter

    (a)

    (b)

    (c)
    (d)
    (e)
    [(a) / (e)]
    [(b) / (e)]
    [(c) / (e)]

    Q3 for fiscal year 20213
    $ 395,824
     25 Mar 2021
    $ 30
     1 Feb 2021
    $ 132,144
    $ 220,616
    $ 3,357
      117.9
      0.1
      39.4

    Q4 for fiscal year 2021
    $ 1,327,465
     24 Jun 2021
    $ 136,710
     25 Apr 2021
    $ 647,162
    $ 392,764
    $ 145,460
      9.1
      0.9
      4.5

    Q1 for fiscal year 2022
    $ 1,529,794
     26 Aug 2021
    $ 313,573
     30 Sep 2021
    $ 797,973
    $ 313,573
    $ 222,032
      6.9
      1.4
      3.6

    Q2 for fiscal year 2022
    $ 1,079,415
     28 Dec 2021
    $ 65,816
     23 Nov 2021
    $ 499,736
    $ 137,501
    $ 233,413
      4.6
      0.3
      2.1

    Q3 for fiscal year 2022
    $ 1,511,478
     19 Jan 2022
    $ 66,498
     31 Mar 2022
    $ 524,443
    $ 66,498
    $ 232,215
      6.5
      0.3
      2.3

 1 Differs from $169,218 inventory balance in the Company’s December 31, 2021 balance sheet
as that number includes inventory from other items.

 2 Equals the sum of the daily inventory amounts during the quarter divided by the number of days
in the quarter.

 3 The Company began operations in Q3 2021 and results are not indicative of its current operations.

The Company buys E-vouchers from two different
vendors every day, posts the availability of such E-vouchers on its platform and then fills customer orders for E-vouchers as they are
made. Once the Company does not have a certain E-Voucher in its inventory, the platform will display “SOLD OUT” for such E-Voucher
and the customer will have no ability to purchase or pre-order that E-voucher. Under no circumstances can a customer order or will the
Company sell an E-voucher that is not part of the Company’s inventory.

(ii) How has the Company considered
ASC 606-10-55-37, which states "an entity does not necessarily control a specified good if the entity obtains legal title
to that good only momentarily before legal title is transferred to a customer."

The table above shows that since the Company
began operations (excluding the first quarter of operations) it has held its E-vouchers in inventory on an average of approximately 3.1
days and up to 9.1 days. This does not represent a momentary transfer of title to the Company with a ready or predetermined buyer for
the Company to transfer the E-vouchers to. The Company bears the risk of loss if events occur during the time the Company holds E-voucher
inventory. As shown in the table above, there have been days where inventory has been less than the average of daily revenue, but as previously
stated, under no circumstances can a customer order an E-voucher or the Company sell an E-voucher that is not part of the Company’s
inventory. Also, the Company could choose to hold a higher level of inventory for these vouchers, but naturally maximizes the turnover
of this inventory for normal business efficiencies. Equally, the Company could, at a later date, offer other E Vouchers which are specific
to a specific merchant or retailer, which may by the nature of being more restrictive, lead to substantially higher daily inventory rates.
This would merely be of a function of the E Voucher partner, but the underlying ownership and risk associated with holding these retailer
specific vouchers is the same in nature as the more generic E- Vouchers currently offered. The Company does not believe that they should
have a different accounting policy based on the nature of the vouchers offered, given that they all hold the same proprietary risk.

(iii)
Describe the time frame from when you obtain the inventory, when an order is received from a customer and when the ordered E-voucher
is delivered to that particular customer

As described on page 68 of the Form S-1A,
the Company purchases E-vouchers from two different vendors, Pay’s Gift and Razor Gold. These E-vouchers are not all the same and
provide discounts to goods and services from different companies or different sets of companies. The Company typically orders E-vouchers
from its vendors every day. The Company will issue a purchase order to a vendor for E-vouchers and such vendor will issue an invoice to
the Company for such order within one day of such order. The Company will then make payment in full for the E-vouchers, typically within
one day of receipt of the invoice. Once payment is made the vendor will provide the Company with the pin codes for the E-vouchers and
only then will the Company post the availability of the E-vouchers for sale on its platform. In order for customers to obtain available
E-vouchers, they must pay the purchase price in full and then automatically and immediately the Company provides them with the pin codes
for such E-vouchers. The time frame from when the Company obtains an E-voucher and posts its availability for sale on its platform, to
an order being received from a customer for such E-voucher and such E-voucher being delivered to the customer is typically 2-3 days, which
coincides with average number of days of inventory described above. Furthermore, the Company’s customers can only place an order
for an E-voucher over its platform after the Company has paid the applicable vendor in full for such E-voucher and then posted the availability
for sale of such E-voucher on its platform. The Company seeks to optimize its cashflow with regard to purchasing E-vouchers, and as such
maintains the optimal inventory level to support projected sales. As stated above, there may be other E-vouchers that the Company chooses
to offer which require it to support higher daily inventory levels, but this is a factor of the nature of the supplier relationship and
terms of trade, supporting the case that the Company acts as a principal.

(iv) ASC 606-10-55-39.

The Company has
analyzed the indicators that an entity controls the specified good or service before it is transferred to the customer (and is
therefore acting as a principal) in depth as follows in accordance with ASC 606-10-55-39:

 a. The entity is primarily responsible for fulfilling the promise to provide the specified good or
service. This typically includes responsibility for the acceptability of the specified good or service (for example, primary responsibility
for the good or service meeting customer specifications). If the entity is primarily responsible for fulfilling the promise to
provide the specified good or service, this may indicate that the other party involved in providing the specified good or service
is acting on the entity’s behalf.

Principal Indicator:
Yes, the Company is primarily responsible for fulfilling the promise to provide the specified good because it will need to directly
obtain the applicable E-voucher pin code from its vendors, which demonstrates that the Company has control over the E-voucher.

 b. The entity has inventory risk before the specified good or service has been transferred to a customer
or after transfer of control to the customer (for example, if the customer has a right of return). For example, if the entity obtains,
or commits to obtain, the specified good or service before obtaining a contract with a customer, that may indicate that
the entity has the ability to direct the use of, and obtain substantially all of the remaining benefits from, the good or service
before it is transferred to the customer.

Principal Indicator:
Yes, the Company has inventory risk of E-voucher as it will have to purchase E-vouchers) and post their availability on its platform
for sale before it can receive orders from its customers. In addition, should the E-vouchers not be sold to any of the Company’s
customers, the Company will not be able to return E-vouchers to its vendors, which demonstrates that the Company has inventory
risk.

 c. The entity has discretion in establishing the price for the specified good or service. Establishing
the price that the customer pays for the specified good or service may indicate that the entity has the ability to direct the use
of that good or service and obtain substantially all of the remaining benefits. However, an agent can have discretion in establishing
prices in some cases. For example, an agent may have some flexibility in setting prices in order to generate additional revenue
from its service of arranging for goods or services to be provided by other parties to customers.

Principal Indicator:
Yes, the Company has discretion in establishing the price of the E-voucher from a discounted face value price to the full face
value of the E-voucher, which demonstrates the Company has the ability to direct the use of that good or service and obtain substantially
all of the remaining benefits.

Based upon on
the above assessments, the Company concluded that it met all of the principal indicators in accordance with ASC 606-10-55-39 and
therefore recognizes the sales of E-vouchers on a gross basis.

(v) ASC 606-10-55-330
to 334 - Example 48 - Arranging for the Provision of Goods or Services (Entity is an Agent)

The Company has
analyzed whether its operations match with the example as stated in ASC 606-10-55-330 to 334 - Example 48 - Arranging for the Provision
of Goods or Services (Entity is an Agent).

The Company believes
its operations differ to those provided in Example 48 because the Company purchases E-vouchers and posts their availability on
its platform prior to receipt of orders from its customers, which is different to the scenario as described in ASC 606-10-55-330
for which “the entity does not purchase or commit itself to purchase vouchers in advance of the sale of a voucher to a customer;
instead, it purchases vouchers only as they are requested by the customers.” As a result, the Company accounts for the revenue
generated from the E-voucher sales on a gross basis as it is acting as a principal in the transaction.

General

2. Please have counsel
opine on the legality of the underwriters’ warrants as your binding obligation. For guidance, refer to Staff Legal Bulletin
No. 19, Legality and Tax Opinions in Registered Offerings, Section II.B.1.f.

The Company will file with Amendment No.
2, our revised opinion which will opine on the legality of the underwriters’ warrants as the Company’s binding obligation.

Should you have any questions relating
to the foregoing or wish to discuss any aspect of this letter, please contact me at (646) 876-0618.

Sincerely,

Jeffrey P. Wofford

Carmel, Milazzo & Feil
LLP

United States securities and exchange commission logo
May 13, 2022
Chong Chan Teo
Chief Executive Officer
Treasure Global Inc.
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed May 4, 2022
File No. 333-264364
Dear Mr. Teo:
            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.  Unless we note
otherwise, our references to prior comments are to comments in our May 2, 2022 letter.
Amendment No. 1 to Registration Statement on Form S-1
Notes to Unaudited Condensed Consolidated Financial Statements
Revenue recognition
Product Revenues, page F-10
1.We have reviewed your response to comment 2. In your response you state the Company
purchases gift cards (or E-vouchers) in batches and has control over the applicable gift
cards (or E-vouchers), however, we note from the filing that your inventory balance
appears to be less than would be needed to support a single day of sales. Please tell us how
you would fulfill an order to a customer for a gift card (or E-voucher) when it does not
appear that you have the inventory on hand prior to the customer's order.  In your
response, tell us your considerations of ASC 606-10-55-37 which states "an entity does

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not necessarily control a specified good if the entity obtains legal title to that good only
momentarily before legal title is transferred to a customer." Additionally, please tell us the
time frame from when you obtain the inventory, when an order is received from a
customer and when the ordered gift card (or E-voucher) is delivered to that particular
customer.
General
2.Please have counsel opine on the legality of the underwriters’ warrants as your binding
obligation. For guidance, refer to Staff Legal Bulletin No. 19, Legality and Tax Opinions
in Registered Offerings, Section II.B.1.f.

            You may contact Abe Friedman at 202-551-8298 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer Lopez Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

United States securities and exchange commission logo
May 2, 2022
Chong Chan Teo
Chief Executive Officer
Treasure Global Inc.
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc.
Registration Statement on Form S-1
Filed on April 19, 2022
File No. 333-264364
Dear Mr. Teo:
            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 these comments, we may have additional comments.
Registration Statement on Form S-1
Liquidity and Capital Resources, page 51
1.Please tell us why you have deleted the disclosure related to your convertible notes. In this
regard, the convertible notes appear to have been issued during the periods covered by
your financial statements. Refer to Item 303 of Regulation S-K.
Notes to Unaudited Condensed Consolidated Financial Statements
Revenue recognition
Product Revenues, page F-10
2.We note you account for revenue generated from 'Gift card (or E-voucher)' sales on a
gross basis, as you have determined the Company to be acting as the principal in these
transactions.  In your disclosure, you reference the Company having "control of the

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Chong Chan Teo
Treasure Global Inc.
May 2, 2022
Page 2
goods."  Please tell us the nature in how 'Gift cards (or E-vouchers)' are purchased and
held prior to being transferred to the customer, and how control was determined.
Specifically, we note your 'Gift card (or E-voucher)' inventory balance as disclosed on
page F-16, amounts to less than .05% of your revenues for the 6 months ended December
31, 2021.  Refer to ASC 606-10-55-36 through 40. In your response, please also tell us
your consideration of the other indicators mentioned in ASC 606-10-55-39.
            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 Abe Friedman at 202-551-8289 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer Lopez Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

United States securities and exchange commission logo
April 11, 2022
Chong Chan Teo
Chief Executive Officer
Treasure Global Inc.
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted on March 23, 2022
CIK No. 0001905956
Dear Mr. Teo:
            We have reviewed your amended draft 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 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 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 our comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Capitalization, page 42
1.We note your response to comment 5.  Please revise your capitalization table to only show
accounts related to indebtedness and stockholders' deficit.  In addition, revise the pro
forma column to include the issuances of shares related to the conversions of debt and
anti-dilution agreements.

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Treasure Global Inc.
April 11, 2022
Page 2
            You may contact Abe Friedman at 202-551-8298 or Joel parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer López Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

United States securities and exchange commission logo
February 22, 2022
Chong Chan Teo
Chief Executive Officer
Treasure Global Inc.
276 5th Avenue, Suite 704 #739
New York, New York 10001
Re:Treasure Global Inc.
Draft Registration Statement on Form S-1
Submitted on January 26, 2021
CIK No. 0001905956
Dear Mr. Teo:
            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.
Draft Registration Statement on Form S-1 Submitted on January 26, 2021
Cover Page
1.Please revise the cover page to clarify if the company will be considered a controlled
company after the offering.
Prospectus Summary
Reward Points, page 4
2.Please tell us, and revise to the extent applicable, if your "reward points" disclosed here
are synonymous with your "loyalty points" described in your loyalty program disclosure
on page 48 and elsewhere within the filing.

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Page 2
Risk Factors, page 19
3.We note that the common stock will be issued upon the listing of your common stock on
Nasdaq as a result of the automatic conversion of your Convertible Notes. Please revise to
discuss the risk of dilution upon conversion of the convertible notes discussed throughout
your registration statement.
Use of Proceeds, page 41
4.We note that you currently intend to use the net proceeds from this offering for working
capital, "including, but not limited to acquisitions, marketing, hiring and IT development
and general corporate purposes." Revise to specifically discuss in greater detail the uses of
net proceeds from this offering. As applicable, state the approximate amount of proceeds
to be used for each identified use of proceeds. Please also tell us whether you have
identified any particular business to acquire or otherwise entered into preliminary
negotiations with potential acquisition targets.
Capitalization, page 42
5.Please revise your Capitalization table to provide separate columns for your 'Pro Forma'
and 'Pro Forma as Adjusted' adjustments.
Management's Discussion and Analysis
Key Operating Metrics, page 47
6.Please tell us how the number of "active users" are less than the number of "new
registered users" for the three months ended September 30, 2020 and December 31, 2020.
7.Please balance your discussion of your registered and active user growth with discussion
regarding your churn of active users. Specifically, we note the large increases to your
number of new registered users without corresponding increases to the number of active
users.
Results of Operation
For the years ended June 30, 2021 and 2020
Revenue
Product and loyalty program revenue, page 48
8.Please tell us the following in regard to your Product and Loyalty Revenue Program:

•Your initial accounting treatment of reward or loyalty points that are issued to users
for the differing methods of participation referenced on page 4.

•Your subsequent accounting treatment for the recognition of reward or loyalty
points upon redemption or expiration.

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Page 3
•Total revenue relating to the expiration of reward points

•Total revenue that specifically relates to reward points earned not as part of a
spending transaction.

•Breakage estimate for reward or loyalty points, and specifically for reward or loyalty
points issued as new user sign-up bonuses.
Management's Discussion and Analysis of Financial Condition and Results of Operation
Liquidity and Capital Resources, page 51
9.Please clearly state how long you can satisfy your cash requirements based upon cash on
hand and revenues from operations and explain whether you will have to raise additional
funds in the next twelve months.  Please also include a reasonably detailed discussion of
your ability to continue in existence as a going concern and your ability or inability to
generate sufficient cash to support your operations during the next twelve months.  Please
refer to Item 303(a)(1) of Regulation S-K.
About the ZCITY App, page 64
10.Your chart on page 64 shows that you offer a Buy Now and Pay Later function.  In an
appropriate place in your disclosure, please provide more details of this function.  For
example, who is providing this credit, who is processing the request for this credit service
and who is taking the related credit risk of default.  If this service is not available, please
clearly disclose that it is not available and if this also true for any other App functions
listed, please disclose that as well.
11.On page 65 you list some of your key business partnerships by category.  We also note
your discussion on page 73 of your strategic partners, with some of whom you have
contracts.  If you have material agreements with your key business partners or strategic
partners, please describe the material terms of those agreements and consider whether they
are a material contract that should be filed as an exhibit.  In this regard, please tell us if
you have their permission to use their corporate trademarks in your filing.
Competitive Outlook, page 73
12.We note your chart on page 73. Please disclose the source of the information that relates
to your competitors.
Intellectual Property Matters, page 73
13.We note your disclosure that "[i]t is not the intent of this prospectus to delineate each and
every trademarkable matter of ours owned through GEM." Please revise to describe all
material patents, trademarks, licenses, franchises, concessions, royalty agreements or
labor contracts, including duration. Refer to Item 101(h)(4)(vii) of Regulation S-K.

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Financial Statements
Notes to Consolidated Financial Statements
Note 1 - Nature of business and organization
Loyalty Program, page F-11
14.Please clarify for us if you are determined to be the accounting principal or agent when
customers make purchases through your loyalty program.  Please support your conclusion
with your analysis, citing the appropriate guidance where applicable.  Refer to ASC 606-
10-55-36 through 40.
Disaggregated information of revenues..., page F-13
15.Please tell us your consideration of disaggregating revenues between 'product revenue'
and 'loyalty program revenue.'  These revenue streams, in aggregate, account for greater
than 99% of your 2021 total revenue, and appear to reflect differing types of goods and/or
services.   Refer to ASC 606-10-50-5 and ASC 606-10-55-89 through 91.
General
16.Please provide us with supplemental copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, have presented or expect to present to potential investors in reliance on Section
5(d) of the Securities Act, whether or not you retained, or intend to retain, copies of
those communications. Please contact the staff member associated with the review of this
filing to discuss how to submit the materials, if any, to us for our review.
            You may contact Abe Friedman at 202-551-8298 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Scott Anderegg at 202-551-3342 or Jennifer López Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services