October 16, 2024

Joyce Lee Jue Hui
Chief Executive Officer
Fitness Champs Holdings Limited
7030 Ang Mo Kio
Avenue 5, #04-48
NorthStar@AMK
Singapore 569880

       Re: Fitness Champs Holdings Limited
           Amendment No. 1 to Registration Statement on Form F-1
           Filed October 3, 2024
           File No. 333-282016
Dear Joyce Lee Jue Hui:

     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.

Amendment No. 1 to Registration Statement on Form F-1
Capitalization
Indebtedness, page 35

1.     On your table of indebtedness, please tell us what the column labeled
"As adjusted"
       represents. The notes at the end of the table indicate that you intend
to repay the
       shareholder loans in full using proceeds from this offering, so it is
not clear what the
       as adjusted amounts represents. In addition, we note that your
capitalization table also
       reflects the full amount of shareholder loans in the "as adjusted"
column.
 October 16, 2024
Page 2

       Please contact Patrick Kuhn at 202-551-3308 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Taylor Beech at 202-551-4515 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   David Ficksman