SAG Holdings Limited

14 Ang Mo Kio Street 63

Singapore 569116

May 28, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attention: Scott Anderegg

Re:	SAG Holdings Limited
	Amendment No. 16 to Registration Statement on Form F-1
	File No. 333-267771

Ladies and Gentlemen:

SAG Holdings Limited (the “Company”) has submitted the Company’s Amendment No. 16 to Registration Statement on Form F-1 today to provide updated 2023 audited financials.

If you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com or Joilene Wood at 415-305-4651 or jwood@troygould.com.

Sincerely,
SAG Holdings Limited
	/s/ Jimmy Neo
By:	Jimmy Neo
	Chief Executive Officer & Executive Director

cc:	David L. Ficksman
	R. Joilene Wood