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 WELLCHANG HOLDINGS COMPANY LIMITED

 December 2, 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:
 Wellchange Holdings Company Limited

 Registration Statement on Form F-1

 File No. 333-291882

 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, WELLCHANG HOLDINGS COMPANY LIMITED hereby requests
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 4:30 p.m., Eastern Time, on December 3, 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,

 WELLCHANG HOLDINGS COMPANY LIMITED

 By:
 /s/ Shek Kin Pong

 Name:
 Shek Kin Pong

 Title:
 Chief Executive Officer

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January 13, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-1004

    Re:
    Wellchange Holdings Company Limited

    Registration Statement on Form F-1, as amended

    File No. 333-284034

Ladies and Gentlemen:

As the placement agent of
the proposed offering of Wellchange Holdings Company Limited (the “Company”), we hereby join the Company’s request for
acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m., Eastern Time, on January 14, 2025,
or as soon thereafter as is practicable.

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

    Very truly yours,

    Revere Securities LLC

    By:
    /s/ Bill Moreno

    Name:
    Bill Moreno

    Title:
    Chairman and CEO

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January 13, 2025

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4720

    Re:
    Wellchange Holdings Company Limited

    Registration Statement on Form F-1 (File No. 333-284034)

    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, Wellchange Holdings Company Limited, hereby requests acceleration of the effective
date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m., Eastern Time, on January 14, 2025,
or as soon thereafter as practicable.

    Very truly yours,

    Wellchange Holdings Company Limited

    By:
    /s/ Shek Kin Pong

    Name:
    Shek Kin Pong

    Title:
    Chief Executive Officer,

 Chairman of the Board (Principal Executive Officer)

December 19, 2024
Shek Kin Pong
Chief Executive Officer
Wellchange Holdings Company Limited
Unit E, 11/F, Billion Plaza II, 10 Cheung Yue Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Wellchange Holdings Company Limited
Draft Registration Statement on Form F-1
Submitted December 18, 2024
CIK No. 0001990251
Dear Shek Kin Pong:
            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 Rule 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 Jeff Kauten at 202-551-3447 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Yarona L. Yieh

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Wellchange Holdings Company Limited

Unit E, 11/F, Billion Plaza II, 10 Cheung Yue Street

Cheung Sha Wan, Kowloon, Hong Kong

September 26, 2024

VIA EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4720

Attn: Claire DeLabar

Robert Littlepage

Uwem Bassey

Matthew Crispino

    Re:
    Wellchange Holdings Company Limited

    Registration Statement on Form F-1, as amended (File No. 333-276946)

    Request for Acceleration of Effectiveness

Dear Mr. Bassey,

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Wellchange Holdings Company Limited hereby requests
that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended be accelerated to and that the Registration
Statement become effective at 4:00 p.m., Eastern Time, on September 30, 2024, or as soon thereafter as practicable.

    Very truly yours,

    Wellchange Holdings Company Limited

    By:
    /s/ Shek Kin Pong

    Name:
    Shek Kin Pong

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

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September 26, 2024

Dominari Securities LLC

725 Fifth Avenue, 23rd Floor

New York, NY 10022

as representatives of the several underwriters

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4720

 Attn: Claire DeLabar

Robert Littlepage

Uwem Bassey

Matthew Crispino

    Re:

    Wellchange Holdings Company Limited

    File No. 333-276946

    Registration Statement on Form F-1, as amended

Dear Mr. Bassey,

Pursuant to Rule 461 of the
General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Dominari Securities
LLC, as representative of the underwriters, hereby joins Wellchange Holdings Company Limited (the “Company”) in connection
with its request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 4:00 p.m., Eastern Time,
on September 30, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 under
the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated August 19, 2024,
to underwriters, dealers, institutions and others 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.

    Very truly yours,

    Dominari Securities LLC

    By:
    /s/ Eric Newman

    Name:
    Eric Newman

    Title:
    Head of Investment Banking

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June 10, 2024

Via EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Uwem Bassey

    Matthew Crispino

    Claire DeLabar

    Robert Littlepage

    Re:
    Wellchange Holdings Co Ltd

    Amendment No 1 to Registration Statement on Form F-1

    Filed March 27, 2024

    File No. 333-276946

Ladies and Gentlemen:

This letter is being submitted in response to
the letter dated April 10, 2024 from the U.S. Securities and Exchange Commission (the “Commission”) in which the staff
of the Commission (the “Staff”) commented on the above-referenced Amendment No.1 to the Registration Statement on Form
F-1 filed on March 27, 2024. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, an amended Registration Statement
on Form F-1 (“F-1/A”) for filing with the Commission, which has been revised to reflect the Staff’s comments
as well as certain other updates to the F-1/A.

For the Staff’s convenience, each Staff’s
comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references
below in the Company’s responses are to the page numbers in F-1/A. Capitalized terms used but not otherwise defined herein have
the meanings set forth in the F-1/A.

Form F-1/A filed March 27, 2024

Dilution, page 68

    1

    Please complete the disclosure under
    Dilution and provide any missing information elsewhere in your filing like under Use of Proceeds in a pre-effective amendment to
    your Form F-1.

Response: In response to the Staff’s
comment, we have completed the requested disclosure under the Dilution and Use of Proceed sections in the F-1/A.

Financial Statements, page F-1

    2.

    Please provide audited financial statements
for the year ended December 31, 2023 in an amended filing.

Response: In response to the Staff’s
comment, we have provided the audited financial statements for the year ended December 31, 2023 in the F-1/A as required.

In responding to your comments, we acknowledge
that:

 ● the
Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 ● Staff
comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to
the filing; and

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

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

    Very truly yours,

    /s/ Shek Kin Pong

    Shek Kin Pong, Chief Executive Officer

United States securities and exchange commission logo
April 10, 2024
Au Ho (Arthur) Chi
Chief Financial Officer
Wellchange Holdings Co Ltd
Unit E, 11/F, Billion Plaza 2, 10 Cheung Yue Street
Cheung ShaWan, Kowloon, Hong Kong
Re:Wellchange Holdings Co Ltd
Amendment No 1 to Registration Statement on Form F-1
Filed March 27, 2024
File No: 333-276946
Dear Au Ho (Arthur) Chi:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Form F-1/A filed March 27, 2024
Dilution, page 68
1.Please complete the disclosure under Dilution and provide any missing information
elsewhere in your filing like under Use of Proceeds in a pre-effective amendment to your
Form F-1.
Financial Statements, page F-1
2.Please provide audited financial statements for the year ended December 31, 2023 in an
amended filing.

 FirstName LastNameAu Ho (Arthur) Chi
 Comapany NameWellchange Holdings Co Ltd
 April 10, 2024 Page 2
 FirstName LastName
Au Ho (Arthur) Chi
Wellchange Holdings Co Ltd
April 10, 2024
Page 2
            Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Uwem Bassey at 202-551-3433 or Matthew Crispino at 202-551-3456 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yarona L. Yieh

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March 27, 2024

Via EDGAR

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Uwem Bassey

    Matthew Crispino

    Claire DeLabar

    Robert Littlepage

    Re:
    Wellchange Holdings Co Ltd

    Registration Statement on Form F-1

    Filed February 8, 2024

    File No. 333-276946

Ladies and Gentlemen:

This letter is being submitted in response to
the letter dated March 6, 2024 from the U.S. Securities and Exchange Commission (the “Commission”) in which the staff
of the Commission (the “Staff”) commented on the above-referenced Registration Statement on Form F-1 filed on February
8, 2024. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, an amended Registration Statement on Form F-1
(“F-1/A”) for filing with the Commission, which has been revised to reflect the Staff’s comments as well as certain
other updates to the F-1/A.

For the Staff’s convenience, each Staff’s
comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references
below in the Company’s responses are to the page numbers in F-1/A. Capitalized terms used but not otherwise defined herein have
the meanings set forth in the F-1/A.

Form F-1 filed February 8, 2024

Our Customers, page 111

    1
    You disclosed that you had two customers that accounted for 32% of the company’s total revenue for the six months ended June 30, 2023. Please disclose the material terms of any agreements with these customers, including the identity, term and termination provisions of any agreements.

Response: In response to the Staff’s
comment, we have disclosed that these two customers signed our standard software development agreement under the caption “customer
concentration risk” on page 92 of the F-1/A. The material teams of our standard software development agreement have been previously
disclosed (see page 91 of the F-1/A), and we have previously filed the agreement template as exhibit 10.5.

Financial Statements - June 30, 2023 and 2022

Note 12. Shareholders' Equity, page F-52

    2.
    We note on January 26, 2024 you implemented a 4,000-for-1 share split for ordinary shares and that all per share amounts and numbers of ordinary shares have been retrospectively adjusted. Please delete the reference to a "reverse" share split, as the 4,000- for-1 split is not a reverse share split but a regular share split. Please also correct the disclosure in Note 18 on page F-58 accordingly.

Response: In response to the Staff’s
comment, we have revised the disclosure on pages F-52 and F-59 of the F-1/A as required.

Note 18. Subsequent Events, page F-58

    3.
    We note that on February 7, 2024 you "proposed a 5-for-1 forward share split of ordinary shares which was approved by existing shareholders and board of directors, pursuant to which the Company is in the process of issuing additional shares." Please update your disclosures to reflect the issuance and retrospective adjustment of per share and share amounts in your next amendment, presuming that the issuance has occurred prior to your next amended filing or expand the disclosure to explain the delay in the issuance of shares.

Response: In response to the Staff’s
comment, the 5-for-1 forward split was completed on February 8, 2024, and we have revised our disclosure on page F-59 of the F-1/A
to reflect the issuance and retrospective adjustment of per share and share amounts.

Exhibit Index, page II-3

    4.
    Please file an exhibit that includes the representations required by Instruction 2 to Item 8.A.4 of Form 20-F if you intend to comply with the 15-month requirement rather than the 12-month requirement for updating financial statements.

Response: In response to the Staff’s
comment, we have filed our application for waiver and representation under Form 20-F, Instruction 2 to Item 8.A.4 as Exhibit 99.8 to the
F-1/A.

In responding to your comments, we acknowledge
that:

    ●
    the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

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

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

    Very truly yours,

    /s/ Shek Kin Pong

    Shek Kin Pong, Chief Executive Officer

United States securities and exchange commission logo
March 6, 2024
Au Ho (Arthur) Chi
Chief Financial Officer
Wellchange Holdings Co Ltd
Unit E, 11/F, Billion Plaza 2, 10 Cheung Yue Street
Cheung ShaWan, Kowloon, Hong Kong
Re:Wellchange Holdings Co Ltd
Registration Statement on Form F-1
Filed February 8, 2024
File No: 333-276946
Dear Au Ho (Arthur) Chi:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Form F-1 filed February 8, 2024
Our Customers, page 111
1.You disclosed that you had two customers that accounted for 32% of the company’s total
revenue for the six months ended June 30, 2023. Please disclose the material terms of any
agreements with these customers, including the identity, term and termination provisions
of any agreements.
Financial Statements - June 30, 2023 and 2022
Note 12. Shareholders' Equity, page F-52
2.We note on January 26, 2024 you implemented a 4,000-for-1 share split for ordinary
shares and that all per share amounts and numbers of ordinary shares have been
retrospectively adjusted. Please delete the reference to a "reverse" share split, as the 4,000-
for-1 split is not a reverse share split but a regular share split. Please also correct the
disclosure in Note 18 on page F-58 accordingly.

 FirstName LastNameAu Ho (Arthur) Chi
 Comapany NameWellchange Holdings Co Ltd
 March 6, 2024 Page 2
 FirstName LastName
Au Ho (Arthur) Chi
Wellchange Holdings Co Ltd
March 6, 2024
Page 2
Note 18. Subsequent Events, page F-58
3.We note that on February 7, 2024 you "proposed a 5-for-1 forward share split of ordinary
shares which was approved by existing shareholders and board of directors, pursuant to
which the Company is in the process of issuing additional shares." Please update your
disclosures to reflect the issuance and retrospective adjustment of per share and share
amounts in your next amendment, presuming that the issuance has occurred prior to your
next amended filing or expand the disclosure to explain the delay in the issuance of
shares.
Exhibit Index, page II-3
4.Please file an exhibit that includes the representations required by Instruction 2 to Item
8.A.4 of Form 20-F if you intend to comply with the 15-month requirement rather than the
12-month requirement for updating financial statements.
            Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Uwem Bassey at 202-551-3433 or Matthew Crispino at 202-551-3456 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yarona L. Yieh

United States securities and exchange commission logo
October 26, 2023
Au Ho (Arthur) Chi
Chief Financial Officer
Wellchange Holdings Co Ltd
Flat E, 11/F, Billion Plaza 2, Cheung Yue Street
Cheung ShaWan, Kowloon, Hong Kong
Re:Wellchange Holdings Co Ltd
Registration Statement on DRS Form F-1
Filed September 28, 2023
File No: 377-06900
Dear Au Ho (Arthur) Chi:
            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.
DRS Form F-1
Prospectus Summary
Overview, page 1
1.Please define "small- and medium- sized businesses" (SMBs) in the context of your
customer base. Clarify whether SMBs are measured in terms of revenue, employees,
and/or other criteria. Also, disclose here your number of customers for all periods
presented in your financial statements.
Our Competitive Strengths, page 2
2.Please balance the disclosure in this section by also discussing the decrease in your
subscription services revenue from fiscal 2021 to 2022.

 FirstName LastNameAu Ho (Arthur) Chi
 Comapany NameWellchange Holdings Co Ltd
 October 26, 2023 Page 2
 FirstName LastName
Au Ho (Arthur) Chi
Wellchange Holdings Co Ltd
October 26, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Factors Affecting Our Results of Operations, page 70
3.Please revise here to include a quantified discussion of the key performance indicators and
other metrics used in managing your business for each period presented. Also, ensure you
clearly define how each metric is calculated and include a discussion of any trends,
uncertainties and fluctuations in such measures from period to period. Refer to SEC
Release No. 33-10751.
Customer concentration risk, page 86
4.We note your disclosure that for the year ended December 31, 2022, two customers
accounted for 45.9% and 12.2% of your total revenues.  Please discuss the material terms
of your purchase or other agreements with such customers. Please also file any such
agreements as exhibits to the registration statement or tell us why you do not believe they
are required to be filed.
Business, page 94
5.Please disclose the principal markets in which you compete, including a breakdown of
total revenues by activity and geographic market for each of the periods included in your
financial statements.  Refer to Item 4.B.2 of Form 20-F.
Principal Shareholders, page 119
6.Please disclosed any significant change in the percentage ownership held by any major
shareholder during the past 3 years. Item 7.A.1(b) of Form 20-F.
Financial Statements
Consolidated Balances Sheets, page F-3
7.Please reclassify the stock subscription receivables due from shareholders to present it on
the balance sheet as a deduction from stockholders’ equity. We refer you to SAB Topic
4:E.
Note 2. Summary of Significant Accounting Policies and Practices
Intangible assets, net, page F-10
8.We note that you acquired the ERP software system from a third party and merged it with
your existing platform.  Please expand the disclosure to explain the basis for your belief
that an estimated useful life of 10 years is reasonable, including a description of your
accounting policy for determining the useful life of software intangible assets.
Revenue recognition, page F-13
9.We note that you have determined that the standalone price of technical service is
considered insignificant as you have minimal experience to perform the technical support

 FirstName LastNameAu Ho (Arthur) Chi
 Comapany NameWellchange Holdings Co Ltd
 October 26, 2023 Page 3
 FirstName LastName
Au Ho (Arthur) Chi
Wellchange Holdings Co Ltd
October 26, 2023
Page 3
services.  Please expand the accounting policy disclosure and revenue recognition critical
accounting policies in MD&A on pages 73 and 74 to clarify whether you mean that you
have not had to provide significant technical support services to date for your platform or
whether you have not had sufficient experience due to a limited experience in entering
into such arrangements.  If the latter applies, tell us how you determined that it was
appropriate to recognize revenue for customized and white-label software solutions prior
to the 90 day technical support service agreement period.
Note 16. Risks and Uncertainties
Liquidity risk, page F-28
10.We note that you state in Note 2 on pages F-18 and F-19 that your working capital deficit
raises substantial doubt about your ability to continue as a going concern.  Please expand
the disclosure of Liquidity risk on page F-28 and MD&A Basis of presentation on page 72
and Cash Flow Sufficiency on page 84 to integrate the going concern issue with your
disclosure that typically you ensure that you have sufficient cash on demand to meet
expected operational expenses for a period of twelve months.
Note 17. Commitments and Contingencies, page F-28
11.Please describe in the litigation disclosure on page F-29 the facts and circumstances
concerning the legal proceeding relating to the alleged misappropriation and/or retention
of confidential and property information disclosed on pages 35, or tell us the basis for
your belief that disclosure is not required.  Please also revise the Legal Proceedings
disclosure on page 107 accordingly, if necessary.
General
12.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Uwem Bassey at 202-551-3433 or Matthew Crispino at 202-551-3456 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology