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                            September 8, 2023

       Kian Hwa Goh
       Chief Executive Officer
       Orangekloud Technology Inc.
       1 Yishun Industrial Street 1
       #04-27/28&34 Aposh Building Bizhub
       Singapore, 768160

                                                        Re: Orangekloud
Technology Inc.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted August
24, 2023
                                                            CIK No. 0001979407

       Dear Kian Hwa Goh:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       August 2, 2023 letter.

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

       Prospectus Summary, page 5

   1.                                                   We note your response
to prior comment 5. Please revise to include a chart depicting your
                                                        corporate structure
before the Reorganization and Offering.
 Kian Hwa Goh
FirstName LastNameKian   Hwa Goh
Orangekloud  Technology Inc.
Comapany 8,
September NameOrangekloud
             2023            Technology Inc.
September
Page 2    8, 2023 Page 2
FirstName LastName
Implications of Being an Emerging Growth Company and a Foreign Private Issuer,
page 7

2.       We note your response to prior comment 6. Please note that your
election to take
         advantage of the extended transition period for complying with new or
revised accounting
         standards is not irrevocable. Please revise accordingly. Refer to
Question 37 of the FAQ
         on Title 1 of the JOBS Act. In addition, as previously requested,
revise Note 2 to disclose
         that, as result of your election, your financial statements may not be
comparable to
         companies that comply with public company effective dates.
Use of Proceeds, page 28

3.       We note your response to prior comment 8. Please provide information
on the status of the
         company   s plans to pursue acquisition or strategic investment
opportunities. See Item
         3.C.3 of Part 1 of Form 20-F.
Dilution, page 31

4.       Based on your revisions to prior comment 9 it appears that there will
not be a forward
         split. Please also revise the dilution section to remove references to
the split. Also, the
         dilution calculations should be presented as of December 31, 2022, the
most recent
         balance sheet date included in the filing. Please revise accordingly.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Other Metrics, page 41

5.       We note your response to prior comment 14. Please revise to quantify
recurring revenue
         and revenue retention rate for each period presented. Also, explain
your basis for
         including third party license revenue in recurring revenue. In this
regard, it appears that
         this revenue is point in time revenue so it is unclear how it is
recurring.
Management, page 63

6.       In light of Mr. Goh   s other positions with other companies, please
revise to discuss any
         conflicts of interest.
Consolidated Financial Statements of Orangekloud Technology Inc.
Report of Independent Registered Public Accounting Firm, page F-2

7.       We note your response to prior comment 19. Please note your auditors
should include a
         signed and dated preface statement in a header to their    to be
issued    report stating the
         reason for such report and that they expect to be in a position to
issue the report in the
         form presented prior to effectiveness. Please revise.
 Kian Hwa Goh
FirstName LastNameKian   Hwa Goh
Orangekloud  Technology Inc.
Comapany 8,
September NameOrangekloud
             2023            Technology Inc.
September
Page 3    8, 2023 Page 3
FirstName LastName
Consolidated Statements of Operations and Comprehensive Income (Loss), page F-5

8.       Your response to prior comment 20 indicates that the remaining payroll
and
         employee benefits amounts is for management personnel and finance and
administrative
         staff. Tell us what consideration was given to labeling this line item
"general and
         administrative expense."
Notes to Consolidated Financial Statements
2. Summary of significant accounting policies
Revenue recognition, page F-12

9.       We note your revisions and response to prior comment 21. As previously
requested,
         please explain in your response how you determined that point in time
recognition was
         appropriate for third party hosting services. As part of your
response, tell us whether you
         have any obligations to the customer over the hosting service period.
Refer to ASC 606-
         10-25-30.
10.      We note the remaining performance obligation ("RPO") table added in
response to prior
         comment 24. Please tell us what the RPO amount for packaged software
solutions
         represents. In this regard, we note that revenues for these solutions
is recognized at a
         point in time so it is unclear what the unsatisfied performance
obligation relates to.
General

11.      We note your response to prior comment 26. Please revise your
disclosure to:
             State the purpose and effect of the Reorganization;
             Discuss the Shareholder   s Agreement relating to MSC Consulting,
which will be
            included as an exhibit;
             Tell us the exemption from Securities Act registration you will
rely on to conduct the
            exchanges contemplated by the Reorganization.

        You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or
Christine Dietz,
Senior Staff Accountant, at (202) 551-3408 if you have questions regarding
comments on the
financial statements and related matters. Please contact Alexandra Barone,
Staff Attorney, at
(202) 551-8816 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Lawrence Venick