IFRS & Foreign Private Issuers

Company response: In response to the Staff’s comments, we have revised our disclosures beginning on page F-24 of the Registration Statement to replace our current December 31, 2025 interim unaudited financial statement prepared under IFRS with financial statements prepared under U.S. GAAP and also revised other areas of the Registration Statement impacted by the change, including our capitalization table and Item 5. Operating and financial review and prospects. We appreciate the assistance the Staff has provided with its comments. response letter →

Company response: to the Staff’s comment, the Company will revise future filings, as applicable, to provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. To the extent the CBI Sample Letter requests disclosure on the prospectus cover page or in the prospectus summary, the Company will provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F; in addition, the Company will include a discussion of the transfer of cash within the Company in Item 5 of Form 20-F. response letter →

Company response: We respectfully advise the Staff that we have filed Amendment No. 1 to include an updated report from JWF Assurance PAC that addresses the above. response letter →

Company response: Updated disclosure has been added on pages 5 and 6 of the Amended Registration Statement to include the related party transaction involving Haoju Artificial Intelligence Technology Co., Ltd., as well as the other related party transactions for the period specified in Item 7 of Form 20-F. response letter →

Company response: We respectfully advise the staff as follows: The Company’s revenue for the years ended April 30, 2025 and 2024 were S$167,707 (approximately US$128,464) and S$1,882,803 (approximately US$1,380,848), respectively, representing a decrease of 91.1%. This reduction in revenue was primarily attributed to a reduction in sales orders from our largest customers due to a change in our business strategy in which we directly interact with our customers. As a result, the Company has expanded its sales channel from selling to our distributors to selling directly to customers, with the price of the products remaining largely unchanged, leading to a decline in revenue where sales to distributors have… response letter →

Company response: We have revised our disclosure in Item 15 of Part II to the Form 20-F. response letter →

Company response: We have revised our disclosure in Item 15 of Part II to the Form 20-F. response letter →

Company response: to the Staff’s comments, we revised our disclosure on page 99 of Amendment No. 2 to provide the required compensation information for the fiscal year ended September 30, 2025. Financial Statements Index to Financial Statements, page F-1 3. Pursuant to Item 8.A.4 of Form 20-F, please provide audited financial statements that are no more than twelve months old. Alternatively, to the extent you meet the 15-month criteria outlined in Instruction 2. to Item 8.A.4, file the necessary representations as an exhibit to the registration statement. In response to the Staff’s comments, we filed a request for waiver and representation under Item 8.A.4 of Form 20-F as Exhibit 99.2 to Amendment No. 2. We… response letter →