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                                April 3, 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. 8 to
Registration Statement on Form F-1
                                                            Filed March 22,
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 January 26, 2024
letter.

       Amendment No. 8 to Registration Statement on Form F-1 Filed March 22,
2024

       Resale Prospectus, page Alt-1

   1.                                                   We note the reduction
of the primary offering from 2,000,000 Ordinary Shares to
                                                        1,250,000 Ordinary
Shares. We also note that the Resale Prospectus accounts for
                                                        3,000,000 Ordinary
Shares. As a result, with respect to the resale offering:
                                                            Revise to delete
references to the primary and secondary offerings being conducted
                                                            "concurrently," as
it appears that the resale offering will begin only once your
                                                            Ordinary Shares are
listed and the initial public offering is complete.
                                                            Disclose any
natural persons that control the selling shareholder and any position,
                                                            office, or other
material relationship which the selling shareholder has had with the
                                                            registrant or any
of its predecessors or affiliates within three years prior to the filing
                                                            of the registration
statement. Refer to Item 507 of Regulation S-K.
 Shangzhao Hong
Creative Global Technology Holdings Ltd
April 3, 2024
Page 2
             Disclose in greater detail the circumstances under which the
selling shareholder
           received the shares covered by the resale offering, as well as how
long the selling
           shareholder has held such shares. Specifically, how long HSZ
Holdings Limited held
           the shares covered by the resale offering prior to transferring the
shares to CHSZ
           Holdings Limited.
             Advise why the resale offering is required to be registered at
this time.
             Advise how you determined the number of Ordinary Shares being
registered in
           connection with the resale offering.
             Advise how the selling shareholder was selected to participate in
this resale offering
           and why the selling shareholder who is a greater than 5% shareholder
has been
           excluded from the lock-up.
             Lastly, advise why the resale offering should not be deemed an
indirect primary
           being conducted by or on behalf of the issuer. Refer to Question
612.09 of the
           Securities Act Rules Compliance and Disclosure Interpretations.

       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
April 3, 2024 Page 2
cc:       Lan Lou
FirstName LastName