August 20, 2024

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

       Re: SAG Holdings Ltd
           Amendment No. 18 to Registration Statement on Form F-1
           Filed August 7, 2024
           File No. 333-267771
Dear Ivy Lee:

     We have reviewed your amended registration statement and have the
following
comment(s).

       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.

Amendment No. 18 to Registration Statement on Form F-1
General

1.     Please refer to the registration statement cover page. Please check the
applicable check
       box on the cover page regarding the registration of securities pursuant
to Rule 415 of
       the Securities Act of 1933.
2.     Please refer to the Resale Prospectus Shareholders Plan of Distribution
section on page
       Alt-3. We note your disclosure that the Resale Prospectus Shareholders
may sell their
       Ordinary Shares through "purchases by a broker-dealer as principal and
resale by the
       broker-dealer for its account" and that "any broker-dealers or agents
that are involved in
       selling the Ordinary Shares may be deemed to be 'underwriters'". Please
confirm your
       understanding that the retention by a Resale Prospectus Shareholder of
an underwriter
       would constitute a material change to your plan of distribution
requiring a post-effective
       amendment. Refer to your undertaking provided pursuant to Item
512(a)(1)(iii) of
       Regulation S-K.
 August 20, 2024
Page 2

       Please 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 Donald Field at 202-551-3680 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services