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                              January 26, 2024

       Shangzhao Hong
       Chief Executive Officer
       Creative Global Technology Holdings Ltd
       Unit 03, 22/F, Westin Centre
       26 Hung To Road, Kwun Tong
       Kowloon, Hong Kong

                                                        Re: Creative Global
Technology Holdings Ltd
                                                            Amendment No. 4 to
Registration Statement on Form F-1
                                                            Filed January 16,
2024
                                                            File No. 333-273329

       Dear Shangzhao Hong:

            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.
Unless we note otherwise,
       any references to prior comments are to comments in our October 31, 2023
letter.

       Amendment No. 4 to Registration Statement on Form F-1, Filed January 16,
2024

       Quantitative and Qualitative Disclosures about Market Risks
       Foreign Currency Exchange Risk, page 72

   1.                                                   We note your references
to American Depositary Shares. However, the rest of your
                                                        registration statement
discloses the registration of ordinary shares. Please amend your
                                                        registration statement
to clarify this discrepancy.
       Resale Prospectus Alternate Page
       Cover Page, page A-1

   2.                                                   We note that the Resale
Prospectus Summary contemplates the same offering price range
                                                        as the Prospectus Cover
Page. Please confirm the price range within which the selling
 Shangzhao Hong
Creative Global Technology Holdings Ltd
January 26, 2024
Page 2
      shareholder will offer its ordinary shares and revise the Resale
Prospectus Cover Page as
      applicable. Refer to Item 501(b)(3) of Regulation S-K. In the
alternative, please revise and
      confirm that the selling shareholder will not make any offers or sales
until the ordinary
      shares are listed on Nasdaq, and revise your Resale Prospectus Cover Page
to clarify that
      such selling shareholder will then sell its ordinary shares at market
prices once trading of
      your ordinary shares begins. Lastly, please revise the Resale Prospectus
Summary and
      Selling Shareholder Plan of Distribution sections to align with the
Resale Prospectus
      Cover Page which details that the offering is contingent on the company's
Nasdaq listing.
3.    We note that the disclosure describing the exemptions to the Nasdaq
corporate governance
      rules deviate between the Prospectus Cover Page and the Resale Prospectus
Cover Page.
      Please reconcile.
       Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680
with any other
questions.



                                                            Sincerely,
FirstName LastNameShangzhao Hong
                                                     Division of Corporation
Finance
Comapany NameCreative Global Technology Holdings Ltd
                                                     Office of Trade & Services
January 26, 2024 Page 2
cc:       Lan Lou
FirstName LastName