United States securities and exchange commission logo





                             April 30, 2024

       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. 4 to
Registration Statement on Form F-1
                                                            Filed April 22,
2024
                                                            File No. 333-277162

       Dear Kian Hwa Goh:

            We have reviewed your amended registration statement and have the
following
       comments.

              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. 4 to Registration Statement on Form F-1

       Risk Factors
       Risks Related to Our Business
       We are dependent on our relationships with key suppliers., page 15

   1.                                                   We note that "Vendor A"
and "Vendor B" accounted for 19% and 6% of the of your total
                                                        purchases and 59% and
20% of your accounts payable in 2023, respectively. Please
                                                        describe the purchases,
identify the vendors, and disclose the material terms of your
                                                        agreements with these
vendors. Additionally, please file related agreements as exhibits to
                                                        the registration
statement or tell us why the information is not required. Refer to Item
                                                        4.B.6. of Form 20-F and
Item 601(b)(10) of Regulation S-K.
 Kian Hwa Goh
FirstName   LastNameKian  Hwa Goh
Orangekloud   Technology Inc.
Comapany
April       NameOrangekloud Technology Inc.
       30, 2024
April 230, 2024 Page 2
Page
FirstName LastName
Dilution, page 31

2.       Please revise your calculation of net tangible book value as of
December 31, 2023, to
         exclude deferred offering costs and contract assets.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results from Operations
Revenue, page 35

3.       We note your disclosure that you had a 14.9% reduction in revenue from
2022 to 2023
         due to a prolonged grant application process on your customer's end.
Please revise to
         provide a more detailed discussion regarding the grant application
process and identify
         any known trends or uncertainties that will result in or that are
reasonably likely to result
         in a material impact on your revenue. In addition, revise to provide
risk factor disclosure
         as appropriate.
Other Metrics
Recurring revenue growth, page 40

4.       We note that in the current year recurring revenue declined by 16% yet
the "revenue
         growth rate" was 84%. Such presentation may be confusing to an
investor as the table
         appears to indicate that revenue grew by 84% in 2023 when revenue
actually
         declined. Please consider renaming this metric so that it is not
confused with actual
         revenue growth. In this regard, consider renaming the metric
"recurring retention rate" or
         something similar.
Selling Shareholders, page A-11

5.       Please provide a materially complete discussion of how the selling
shareholders acquired
         the securities that you are registering on their behalf for resale.
The background of the
         issuances to the selling shareholders and the nature of the
arrangements, agreements, and
         relationships with the company should include, for each selling
shareholder, a discussion
         of the date of the transaction in which the securities were sold, the
amount of securities
         sold, the agreement(s) that evidence the sale and the instrument(s)
that define the rights of
         the security holders. Refer to item 507 of Regulation S-K.
 Kian Hwa Goh
FirstName   LastNameKian  Hwa Goh
Orangekloud   Technology Inc.
Comapany
April       NameOrangekloud Technology Inc.
       30, 2024
April 330, 2024 Page 3
Page
FirstName LastName
       Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Kyle Wiley at 202-344-5791 or Matthew Derby at 202-551-3334 with any
other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Technology
cc:      Lawrence Venick