February 10, 2025

Marilu Brassington
Interim Chief Accounting Officer
Scepter Holdings, Inc. NV
2278 Monitor St
Dallas, Texas 75207

       Re: Scepter Holdings, Inc. NV
           Amendment No. 3 to Registration Statement on Form 10
           Filed January 30, 2025
           File No. 000-53336
Dear Marilu Brassington:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Amendment No. 3 to Registration Statement on Form 10
Item 1. Business, page 5

1.     We note your revised disclosure in response to prior comment 6. Please
revise Item 1
       to state, as you do on page F-8, that the "Adapti platform is an AI
system that was
       designed to create a proprietary    data fingerprint    for client
products data and even the
       entire company by utilizing third party AI such as ChatGPT, OpenAI or
Google AI
       tools."
Statements of Changes in Stockholders' Deficit, page F-6

2.     We note your response to prior comment 12. Please further clarify why
the number of
       shares of common stock in 2023 did not change as a result of the
correction.
 February 10, 2025
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact Valeria Franks at 202-551-7705 or Theresa Brillant at
202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rucha Pandit at 202-551-6022 or Dietrich King at
202-551-8071 with
any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Steven Davis