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                              October 19, 2021

       Dennis Nguyen
       Chief Executive Officer
       Society Pass Incorporated
       701 S. Carson Street, Suite 200
       Carson City, NV 89701

                                                        Re: Society Pass
Incorporated
                                                            Amendment No. 5 to
Registration Statement on Form S-1
                                                            Filed October 13,
2021
                                                            File No. 333-258056

       Dear Mr. Nguyen:

             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
October 5, 2021 letter.

       Amendment No.5 to Registration Statement of Form S-1

       Capitalization, page 31

   1.                                                   We note the revisions
you made in response to comment 3. In order to present your
                                                        capitalization in a
manner consistent with your dilution presentation on page 32, please
                                                        show the impact of the
6,362,089 shares of our common stock that will be issued upon the
                                                        automatic conversion of
the Convertible Preferred Stock in the third column, and
                                                        present the sale of
2,888,889 shares issued in this offering under the fourth column.
       Shares Eligible for Future Sale, page 97

   2.                                                   Please include in this
section the shares underlying the representative warrants.
 Dennis Nguyen
Society Pass Incorporated
October 19, 2021
Page 2
Note 18 Commitments and Contingencies
Executive Service Agreements, page F-75

3.       We noted from exhibit A in your response to comment 4 that you
determined the value of
         the company at December 31, 2017 by taking an average revenue multiple
for Coffee
         shops using the 2021 Edition of the Business Reference Guide, 31st
Edition, published by
         the Business Brokerage Press. The value of your common stock was then
obtained by
         dividing the company value by the number of common stock outstanding
at December 31,
         2017. Please tell us how you considered the following:

                Address how you considered the comparability of the enterprises
that were utilized in
              the publication to your company and whether any adjustments were
made for factors,
              such as state of development, profitability, liquidity, location
of business, etc..
                Address whether you considered recent sales of equity
securities in arms length
              transactions when preparing your valuation.
                Address how your valuation method considered the change from
              operating restaurants in 2017 to operating e-commerce platforms
and mobile
              applications in 2018.
4.       You state in your response to comment 4 that your estimated common
stock fair value on
         December 31, 2017 was $0.04 and that it did not increase through
December 31, 2020.
         You further state that that market value of the common stock did not
materially increase in
         2021. This appears to be inconsistent with your representation that
the executive shares
         issued in September 2021 had a fair value of $7.65. Please tell us the
factors that
         contributed to the increase from $.04 to $7.65 during 2021, including
any intervening
         events within the company or changes in your valuation assumptions or
methodology.
5.       We note on page 2 in exhibit A in your response to comment 4 that you
issued 1,500,000
         common stock shares related to the bonus for the Leflair acquisition
and 125,000 common
         stock shares for 1/2 of the 2021 bonus. Please provide us with a
detailed discussion of
         how you determined the fair value of these shares issued in the 3rd
quarter of 2021 was
         $.04 when shares issued to other executives during the same time frame
had a fair value of
         $7.65.
6.     It appears per section 3(a) and (b) of exhibit 10.4 the Executive may
elect at any time to
       convert any unpaid Salary or bonus, in whole or in part, into common
stock. Considering
FirstName LastNameDennis Nguyen
       the holder has the right to convert to shares at any time, the
compensation appears to be
Comapany    NameSociety
       stock-based         Pass Incorporated
                    compensation.    Please provide us with a detailed
discussion of how you
Octoberconsidered  the guidance
         19, 2021 Page  2        in ASC 718.
FirstName LastName
 Dennis Nguyen
FirstName  LastNameDennis
Society Pass Incorporated Nguyen
Comapany
October 19,NameSociety
            2021         Pass Incorporated
October
Page 3 19, 2021 Page 3
FirstName LastName
Exhibit 5.1, page I-1

7.       Please have counsel revise the opinion to specify the number of shares
to be sold in the
         offering, which appears to be up to 3,322,223, assuming the exercise
of the over-allotment
         option, as well as the number of shares underlying the representative
warrants, which
         appears to be up to 144,445.
       You may contact Keira Nakada at 202-551-3659 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Dietrich King at 202-551-8071 with
any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services