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                             June 21, 2023

       Ivy Lee
       Chief Financial Officer
       SAG Holdings Ltd
       14 Ang Mo Kio Street 63
       Singapore 569116

                                                        Re: SAG Holdings Ltd
                                                            Amendment No. 5 to
Registration Statement on Form F-1
                                                            Filed June 14, 2023
                                                            File No. 333-267771

       Dear Ivy Lee:

             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 April
7, 2023 letter.

       Amendment No. 5 to Registration Statement on Form F-1

       Exhibit 23.1, page 1

   1.                                                   Please have your
auditor revise their consent to include reference to the financial
                                                        statements for the year
ended December 31, 2021 and correctly state the date of their audit
                                                        report with respect to
the financial statements for the year ended December 31, 2022.

       General

   2.                                                   We note recent
instances of extreme stock price run-ups followed by rapid price declines
                                                        and stock price
volatility seemingly unrelated to company performance following a
                                                        number of recent
initial public offerings, particularly among companies with relatively
 Ivy Lee
SAG Holdings Ltd
June 21, 2023
Page 2
         smaller public floats. Revise to include a separate risk factor
addressing the potential for
         rapid and substantial price volatility and discuss the risks to
investors when investing in
         stock where the price is changing rapidly. Clearly state that such
volatility, including any
         stock-run up, may be unrelated to your actual or expected operating
performance and
         financial condition or prospects, making it difficult for prospective
investors to assess the
         rapidly changing value of your stock.
       You may contact Suying Li at 202-551-3335 or Theresa Brillant at
202-551-3307 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any
other
questions.



FirstName LastNameIvy Lee                                       Sincerely,
Comapany NameSAG Holdings Ltd
                                                                Division of
Corporation Finance
June 21, 2023 Page 2                                            Office of Trade
& Services
FirstName LastName