SecProbe.io

CORRESP
 1
 filename1.htm

 Craft Capital Management LLC

 377 Oak Street, Lower Concourse

 Garden City, NY 11530

 September 26, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Technology

 100 F Street NE

 Washington, D.C. 20549

 Re:
 Ultratrex Inc.

 Registration Statement on Form F-1, as amended
 File No. 333-290101

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the "Securities Act"), Craft Capital Management LLC hereby joins
Ultratrex Inc. in requesting that the Securities and Exchange Commission take appropriate action to accelerate the effective date of the
above-referenced registration statement on Form F-1, as amended, so as to become effective on September 30, 2025, at 4:00 PM Eastern Time,
or as soon thereafter as practicable.

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

 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.

 Very truly yours,

 Craft Capital Management LLC

 /s/ Stephen Kiront

 Stephen Kiront
 Chief Operating Officer

CORRESP
 1
 filename1.htm

 Ultratrex
Inc.

 220
Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

 September
26, 2025

 VIA
EDGAR

 Division
of Corporation Finance

 Office
of Technology

 U.S.
Securities and Exchange Commission

 100
F Street, NE

 Washington,
D.C., 20549

 Re:
 Ultratrex
 Inc.

 Registration
 Statement on Form F-1, as amended (File No. 333-290101)
 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, Ultratrex Inc.
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 September 30, 2025, 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,

 Ultratrex
 Inc.

 By:
 /s/
 Wong Kok Seng

 Name:
 Wong
 Kok Seng

 Title:
 Executive
 Director and Chief Executive Officer (Principal Executive Officer)

 cc:
 Yarona
 Yieh, Esq.

 Ortoli
 Rosenstadt LLP

CORRESP
 1
 filename1.htm

 September
17, 2025

 Via
Edgar Correspondence

 Division
of Corporation Finance

 Office
of Technology

 U.S.
Securities and Exchange Commission

 Washington,
DC 20549

 Attn:
Ms. Marion Graham

 Re:
 Ultratrex
 Inc.
 Registration
 Statement on Form F-1 (File No. 333-290101)

 Request
 for Waiver and Representation under Item 8.A.4 of Form 20-F

 Dear
Ms. Graham:

 The
undersigned, Ultratrex Inc., a foreign private issuer organized under the laws of the Cayman Islands (the "Company"), is
submitting this letter via EDGAR to the U.S. Securities and Exchange Commission (the "Commission") in connection with the
Company's registration statement on Form F-1 filed with the Commission on September 8, 2025 (the "Registration Statement"),
relating to the proposed initial public offering and listing of the Company's class A ordinary shares in the United States.

 The
Company has included in the Registration Statement its audited consolidated financial statements, prepared in accordance with the provisions
of the International Financial Reporting Standards ("IFRS") as issued by the International Accounting Standards Board ("IASB"),
as of June 30, 2023 and 2024 and for each of the two fiscal years ended June 30, 2023 and 2024.

 The
Company respectfully requests that the Commission waive the requirement of Item 8.A.4 of Form 20-F, which states that in the case of
a company's initial public offering, the registration statement on Form F-1 must contain audited financial statements of a date
not older than 12 months from the date of the offering (the "12-Month Requirement"). See also Division of Corporation
Finance, Financial Reporting Manual , Section 6220.3.

 The
Company is submitting this waiver request pursuant to Instruction 2 to Item 8.A.4 of Form 20-F, which provides that the Commission will
waive the 12-Month Requirement "in cases where the company is able to represent adequately to us that it is not required to comply
with this requirement in any other jurisdiction outside the United States and that complying with this requirement is impracticable or
involves undue hardship." See also the 2004 release entitled International Reporting and Disclosure Issues in the Division
of Corporation Finance (available on the Commission's website at http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm)
by the staff of the Division of Corporation Finance of the Commission at Section III.B.c, in which the staff noted that:

 "the
instruction indicates that the staff will waive the 12-month requirement where it is not applicable in the registrant's other filing
jurisdictions and is impracticable or involves undue hardship. As a result, we expect that the vast majority of IPOs will be subject
only to the 15-month rule. The only times that we anticipate audited financial statements will be filed under the 12-month rule are when
the registrant must comply with the rule in another jurisdiction, or when those audited financial statements are otherwise readily available."

 In
connection with this waiver request, the Company represents to the Commission that:

 1.
 The
 Company is not required by any jurisdiction outside the United States to prepare consolidated financial statements audited under
 any generally accepted auditing standards for any interim period.

 2.
 Full
 compliance with Item 8.A.4 of Form 20-F at present is impracticable and involves undue hardship for the Company.

 3.
 The
 Company does not anticipate that its audited financial statements for the fiscal year ended June 30, 2025 will be available until
 October 31, 2025.

 4.
 In
 no event will the Company seek effectiveness of the Registration Statement if its audited financial statements are older than 15
 months at the time of the Company's initial public offering.

 The
Company will file this letter as an exhibit to the Registration Statement pursuant to Instruction 2 to Item 8.A.4 of Form 20-F.

 Sincerely,

 /s/
 Wong Kok Seng

 Wong
 Kok Seng

 Executive
 Director and Chief Executive Officer
 (principal executive officer)

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 September 16, 2025

Wong Kok Seng
Chief Executive Officer
UltraTrex Inc.
220 Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

 Re: UltraTrex Inc.
 Registration Statement on Form F-1
 Filed September 8, 2025
 File No. 333-290101
Dear Wong Kok Seng:

 We have reviewed your registration statement and have the following
comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe our comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

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

Registration Statement on Form F-1
General

1. We note your filing includes audited financial statements that are older
than 12
 months. Please update your financial statements pursuant to Item 8.A.4
of Form 20-F
 or provide the appropriate representations in an exhibit. Refer to
Instruction 2 to Item
 8.A.4.
 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 Rule 461 regarding requests for acceleration. Please allow
adequate time for
us to review any amendment prior to the requested effective date of the
registration
 September 16, 2025
Page 2

statement.

 Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

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

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

Wong Kok Seng
Chief Executive Officer
UltraTrex Inc.
220 Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

 Re: UltraTrex Inc.
 Amendment No. 2 to Draft Registration Statement on Form F-1
 Submitted July 22, 2025
 CIK No. 0002046954
Dear Wong Kok Seng:

 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 June 18, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1

1. We note your response to prior comment 3. Please update your
organizational chart on
 page 7, and elsewhere as necessary, to include the voting control of
those parties prior
 to and after the offering to reflect the issuance of the Class B shares.
 August 4, 2025
Page 2
Management's Discussion and Analysis of Our Financial Condition and Results of
Operations
Organization and reorganization, page 35

2. We note in the disclosure regarding UMSB on page 36 you refer to the
"Concert
 Parties" however, in your response to prior comment 4 you did not refer
to an acting-
 in-concert agreement governing the control of UMSB. Please clarify your
disclosure
 and advise us. If an acting-in-concert agreement governing the control
of UMSB
 exists, disclose the details of this agreement including the date, the
parties involved,
 and the identity of the controlling person(s) on pages 36 and F-9. You
should also file
 this agreement as an exhibit.
3. We note after Mr. Halim transferred his 20% equity interest in UMSB on
December 6,
 2023, he held no equity in UMSB. Clarify in your disclosure your basis
for
 consolidating this entity with the other entities for which Mr. Halim
holds a
 controlling equity interest and advise us in detail.
4. Disclose on pages 37 and F-10 why the Group is considered to exercise
control over
 PT Ultratrex Indonesia and not Mr. Halim, and advise us. In light of his
98% equity
 interest it appears he controls.
5. Disclose on pages 37 and F-10 why the Group is considered to have
exercised control
 over Ultratrex Co. Ltd and not Mr. Halim, and advise us. In light of his
90% equity
 interest in Ultrator Co., Ltd, it appears he controlled it prior to the
November 29,
 2024 acquisition by Ultratrex Singapore.
Financial Statements
Note 1. General Information
Organization and reorganization, page F-8

6. Explain why in the table of page F-9 you indicate you held a 100% equity
interest
 in Ultratrex Asia Pacific Pte. Ltd. at June 30, 2024 and June 30, 2023,
prior to
 the July 3, 2024 date of incorporation. Similarly revise the disclosure
on page F-69
 and elsewhere, as applicable.

 Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 18, 2025

Wong Kok Seng
Chief Executive Officer
UltraTrex Inc.
220 Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

 Re: UltraTrex Inc.
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted June 3, 2025
 CIK No. 0002046954
Dear Wong Kok Seng:

 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 May 20, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1

1. We note your response to prior comment 5. Please explain why your
initial
 submission stated you had more than 70 customers and you now disclose
 your manufacturing and sales of amphibious heavy machinery business has
125
 customers. Additionally, please revise to provide an "as of" date for
this disclosure.
 We also note your statement on page 51 that you "have a wide customer
base in
 respect of our dredging solutions business, comprising more than 5
customers."
 Similarly revise to provide your number of customers for this line of
business as of
 June 18, 2025
Page 2

 the end of each period included in your filing and further explain why
you consider
 this to be a "wide customer base."
Risk Factors, page 10

2. On page F-53, you identify three "customers whom represent 10% or more
of the
 Group s total revenue;" however, it appears that only Customer A
accounted for 10%
 or more your revenue in 2024. Accordingly, please clarify the percentage
of revenue
 each of these customers accounted for in each period and revise your
disclosure as
 necessary. To the extent you rely on a limited number of customers,
please revise to
 include a risk factor discussing risks related to this dependence.
Additionally, to the
 extent these customers accounted for 10% or more of your revenues,
please revise to
 identify these customers.
Management's Discussion and Analysis of Our Financial Condition and Results of
Operations
Organization and reorganization, page 34

3. Please revise the organizational diagram to clearly indicate the voting
control of each
 of the beneficial owners that are a party to the Acting-in-Concert
Agreement and
 include the voting control of those parties prior to and after the
offering.
4. We note your response to prior comment 8 and reissue in part. Please
revise to clarify
 whether the concert party arrangement is still in effect and file the
Acting-in-Concert
 Agreement as an exhibit.
Liquidity and Capital Resources, page 44

5. We note your response to prior comment 13 and reissue in part. Please
revise to
 disclose an estimate of the amount of capital required to carry out your
business plan
 for the next 12 months.
Note 1. General Information
Organization and reorganization, page F-8

6. We note your response to prior comment 18. We also note that the report
of your
 independent registered public accounting firm included in the
registration statement
 has been issued for Ultratrex Inc., a Cayman Islands holding company,
and its
 consolidated subsidiaries, although the reorganization described in Note
1 is
 incomplete. Your disclosures indicate that Ultratrex Inc. has not
acquired Ultratrex
 Asia Pacific Pte. Ltd. as of the date of the audit report. Please tell
us why your public
 accounting firm included an unrestricted audit report rather than a
to be issued
 report due to the pending future event, namely the acquisition of
Ultratrex Asia
 Pacific Pte. Ltd.
7. We note your response to prior comment 20 and your disclosures of the
Acting-in-
 Concert Agreement signed on August 15, 2024. In order to better
understand the
 power held by Salim, Halim, Nursalim, and Taslim to collectively govern
the
 Company's financial and operating policies so as to obtain benefits from
its activities,
 please explain and expand your disclosures for the following:
 Clarify how the Concert Parties exercise their votes as shareholders
in
 concert. For example, explain in what manner contractually are they
required to
 June 18, 2025
Page 3

 make decisions together and coordinate their actions.
 Define all the matters that require the decisions of the
shareholders. For example,
 explain whether all the matters include electing directors,
approving acquisitions,
 and changing corporate bylaws.
 Tell us whether the Acting-in-Concert agreement remains in effect
after the
 completion of the reorganization and offering.
8. We note your response to prior comment 21. Please tell us why the board
of Ultratrex
 Machinery Sdn. Bhd. needed to legally mandate that Mr. Wong hold a 99%
equity
 interest in PT Ultratrex Machinery Indonesia ( PT UMI ) from October
22, 2022 until
 April 24, 2024, when PT UMI had been deemed capitalized by Ultratrex
Machinery
 Sdn. Bhd. Moreover, please clarify the "de facto" control held by the
Group
 collectively that provided the power to govern PT UMI's financial and
operating
 policies so as to obtain benefits from its activities. For instance,
explain any
 contractual arrangements giving power over PT UMI, exposure or rights to
variable
 returns from involvement with PT UMI, and the ability to use power to
affect those
 returns.
9. We note your response to prior comment 22. As part of the
reorganization, it appears
 Ultratrex Inc. will acquire Ultratrex Asia Pacific Pte. Ltd. under
common control due
 to the binding effect of the Acting-in-Concert Agreement. Please provide
the
 following about the parties before and after the transaction and the
offering:
 Clarify the ownership percentages of the Concert Parties in
Ultratrex Inc.
 and Ultratrex Asia Pacific. Ltd. upon the acquisition.
 Describe the transfer of ownership percentages from the Concert
Parties allowing
 Mr. Halim to exercise a controlling percentage of the total voting
power of your
 authorized and issued shares upon the completion of the offering.
 Explain the terms of any contractual arrangements of the transfer to
Mr. Halim
 upon completion of the offering and tell us why this transaction
does not result
 in a change of control from the Concert Parties collectively to Mr.
Halim.
10. We also note that the Ultratrex Asia Pacific Pte. Ltd. acquisition will
be accounted for
 as a business combination under common control in accordance with the
principles of
 IFRS 3. Please tell us your consideration of IFRS 3 paragraph 2(c) that
specifically
 scopes out transactions that are business combinations involving
entities or businesses
 under common control. Also tell us your consideration of IAS 8,
paragraphs 10 -12
 and revise your disclosures accordingly.
 June 18, 2025
Page 4

 Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 20, 2025

Wong Kok Seng
Chief Executive Officer
UltraTrex Inc.
220 Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

 Re: UltraTrex Inc.
 Draft Registration Statement on Form F-1
 Submitted April 22, 2025
 CIK No. 0002046954
Dear Wong Kok Seng:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1
Cover Page

1. We note that you intend to list your Class A shares on the Nasdaq
Capital Market and
 that you will be deemed a controlled company as defined by Nasdaq.
Please
 disclose here whether you intend to rely on any exemptions as a
"controlled company"
 and provide a cross-reference to a longer discussion of the effects of
your "controlled
 company" status.
2. Please revise your cover page to highlight the dual class structure of
your ordinary
 shares, including a discussion of the corresponding voting rights of
your Class A and
 Class B ordinary shares and the percentage of total voting power
controlled by Class
 A and Class B holders, respectively. Also include a risk factor that
discusses material
 May 20, 2025
Page 2

 risks resulting from your dual class capital structure, such as the
risks that your dual
 class structure may render your shares ineligible for inclusion in
certain stock market
 indices and thus adversely affect share price and liquidity.
Special Note Regarding Forward-Looking Statements, page iv

3. We note your disclosure that "[w]e undertake no obligation to update
publicly
 any forward-looking statements for any reason after the date of this
prospectus to
 conform these statements to actual results or to changes in our
expectations."
 Please revise to remove this statement disclaiming responsibility for
your disclosure.
Prospectus Summary, page 1

4. You state you are "one of the leading providers of environmental
 solutions" specializing in the manufacturing of amphibious machinery,
aquatic weed
 harvesters and dredgers. Please provide support for this and other
similar claims.
5. You state that you have a wide customer base consisting of more than 70
customers.
 In order to provide more context for this statement, please revise to
disclose your
 number of current customers as of the end of each financial period
included in your
 filing.
Risk Factors, page 10

6. Here you disclose that three customers accounted for 46.6% and 50.1% of
the
 company's trade receivable as of June 30, 2024 and June 30, 2023,
respectively. On
 page 45, you disclose these percentages as 47.5% and 52.8%. On page
F-53, you state
 "approximately 57% and 42% of the [company's] trade receivables arose
from four
 and two group of customers respectively, as of June 30, 2023 and 2024."
Please revise
 to reconcile any inconsistencies or advise.
7. We note that state owned enterprises and government organizations in
Indonesia
 accounted for 50.3% of your total trading revenue for the fiscal year
ended June 30,
 2024. Please consider adding a risk factor discussing any material risks
resulting from
 this concentration of revenue from state owned enterprises and
government
 organizations. For example, consider adding a risk factor if this type
of customer is
 able to terminate purchase agreements without penalty.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Organization and Reorganization, page 35

8. You disclose here that Salim Podiono, Halim Podiono, Nursalim Podiono,
and Taslim
 Podiono exercise their votes as actors in concert, and act in concert in
relation to all
 matters that require the decisions of the shareholders of the Company.
Please revise to
 clarify whether the concert party arrangement is still in effect,
whether there is a
 related written agreement and, if so, revise to disclose the material
terms of this
 agreement and file it as an exhibit. To the extent this arrangement is
no longer in
 effect, please revise to clarify whether there is currently another
voting agreement or
 similar arrangement in place.
 May 20, 2025
Page 3
Results of Operations, page 39

9. We note the increase in revenue was mainly due to the increase in
sales of
 amphibious machineries. Please disclose how unit volumes and/or
changes in selling
 prices contributed to the increase. Separately quantify the effects of
volume and
 pricing changes on your results of operations, for example, from sales
of the more
 popular models of your amphibious machinery, including mainly the
smaller scale
 amphibious excavators. Refer to Item 303(b)(2)(iii) of Regulation S-K.
10. We note the material increase in your gross profit margin in 2024 was
"mainly due to
 increase in sale of spare parts." As required by Item 5.D. of Form 20-F,
please more
 clearly identify recent material trends in production, inventory, and
selling prices and
 costs that had a material effect on operating results. Discuss any known
trends,
 uncertainties, demands, commitments or events that are reasonably likely
to have a
 material effect on your sales, profitability and income from continuing
operations, or
 that would cause reported financial information not necessarily to be
indicative of
 future operating results.
11. We also note you have identified multiple factors as impacting your
results of
 operations, but no quantification of the contribution of each factor to
the material
 changes in the various line items is provided. For instance, you
attribute an increase
 "in changes in inventories was mainly due to higher level of
inventories." This and
 other material factors are not quantified. Please revise to quantify
material changes in
 line items, including where material changes within a line items offset
one another.
 Refer to Item 303(b) of Regulation S-K.
Liquidity and Capital Resources, page 43

12. Your current disclosure of cash flows from operating activities appears
to repeat
 information presented in the statements of cash flows. Please provide a
more
 informative discussion and analysis of cash provided and used in working
capital
 accounts such as accounts receivable. Please explain the underlying
reasons and
 implications of material changes between periods to provide investors
with an
 understanding of trends and variability in cash flows. Refer to Item 5
of Form 20-F.
13. Please revise your disclosure to be more specific concerning the sources
of
 your liquidity for the next 12 months. Please revise to disclose an
estimate of the
 amount of capital required to carry out your business plan, how you
intend to raise
 this additional capital and when you intend to raise it. If you plan to
issue additional
 equity, you should disclose your plans to do so. If you plan to incur
debt obligations,
 you should disclose whether you have identified any potential lenders.
Business, page 55

14. We note your disclosure of leased property on pages 64-65. Please file
all material
 lease agreements. See Item 601(b)(10) of Regulation S-K.
Management, page 77

15. Please revise to ensure that you have disclosed the principal
occupations and
 employment over the last five years of each of your directors and
executive
 officers named here.
 May 20, 2025
Page 4

Related Party Transactions, page 83

16. We note here that you disclose that "[f]or the periods presented in this
prospectus, we
 have not engaged in any related-party transactions that would be
required to be
 disclosed under applicable SEC rules and regulations." On page F-50, you
disclose a
 number of significant related party transactions in the notes to your
financial
 statements. Please tell us what consideration you gave to disclosing
these related party
 transactions in response to 7.B of Form 20-F.
Tail Financing, page 103

17. We note your disclosure that the Representatives are entitled to a cash
fee equal to
 seven percent of the gross proceeds received by you from the sale of any
equity, debt
 and/or equity derivative instruments to any investors actually
introduced by the
 Underwriters to you under certain circumstances. Please revise to
clarify the term of
 this tail financing right and whether any additional fees paid to the
Representatives
 will impact your net proceeds from this offering.
Consolidated Financial Statements
Note 1. General Information
Organization and reorganization, page F-8

18. It appears your financial statements reflect the reorganization, an
event that does not
 appear to have been completed. In addition, the report of your
independent registered
 public accounting firm appears to opine on the financial statements of
Ultratrex Inc.,
 an entity that was only established on August 15, 2024. Please disclose
and tell us
 your basis of such presentation when the reorganization has not been
completed, and
 post-reorganization financial statements have not been included.
19. Please clarify on page F-9 and elsewhere, your statement that "[t]he
Concert Party
 entitled to one (1) vote, regardless of their respective shareholdings
in the Company."
20. Please expand your disclosures regarding the Concert Party on page F-9
and
 elsewhere, where applicable, to:
 indicate if there was a contemporaneous written agreement among each
of the
 identified shareholders to vote their shares in concert;
 if so, disclose the date of this agreement among the shareholders;
 describe how in an event of a tie differences are resolved and who
decides; and
 quantify any consideration exchanged among the shareholders in
connection to
 the formation of the Concert Party.
21. We note you refer to Mr. Salim, Mr. Halim, Mr. Nursalim, and Mr. Taslim
as
 collectively the "Concert Party." Please clarify your disclosure and
explain to us the
 basis for your conclusion in the last paragraph on page F-9 that the
Group is common
 controlling PT Ultratrex Machinery Indonesia with a deemed 99% equity
interest
 when apparently, this interest was held by Mr. Wong. Also, tell us why
 the disclosed subsequent transaction was not accounted for as a business
combination
 on April 1, 2024. Provide us the terms of any contractual arrangements
and
 reference the supporting accounting literature.
 May 20, 2025
Page 5

22. We note upon the completion of the offering, you will be a controlled
company as
 your Executive Director, Mr. Halim will hold [ ]% of your total issued
and
 outstanding Class A Shares and 100% of our total issued and outstanding
Class B
 Shares and will be able to exercise [ ]% of the total voting power of
your authorized
 and issued shares. Tell us how you will account for Ultratrex Inc.'s
acquisition of a
 100% equity interest in Ultratrex Asia Pacific Pte. Ltd, an entity
previously held by
 Mr. Salim, Mr. Halim, Mr. Nursalim, Mr. Taslim and Mr. Wong with 20% of
equity
 interest each, and explain the basis for your accounting. Also, explain
to us why this
 transaction does not result in a change of control from the Concert Party
collectively
 to Mr. Halim.
General

23. Please revise the registration statement cover page to include the
information required
 by Form F-1 for your agent for service.
24. Please supplementally provide us with copies of all written
communications, as
 defined in Rule405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.
 Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Yarona Yieh
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