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                                                            June 6, 2025

Lim Say Wei
Chief Executive Officer
Magnitude International Ltd
27 Woodlands Industrial Park E1
#03-15 (Lobby B) Hiangkie Industrial Building
Singapore 757718

       Re: Magnitude International Ltd
           Registration Statement on Form F-1
           Filed May 28, 2025
           File No. 333-287609
Dear Lim Say Wei:

       We have reviewed your registration statement and have the following
comment.

        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.

Registration Statement on Form F-1 filed May 28, 2025
General

1.     Given the substantial portion of your shares being registered for resale
and the
       period those shares have been held since being initially sold to each of
the Resale
       Shareholders, please provide us with an analysis of your basis for
determining that it
       is appropriate to characterize the resale offering as a secondary
offering under
       Securities Act Rule 415(a)(1)(i), as opposed to an indirect primary
offering. For
       guidance, refer to Securities Act Rules Compliance and Disclosure
Interpretation
       612.09.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 June 6, 2025
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Howard Efron at 202-551-3439 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters.
Please contact Benjamin Holt at 202-551-6614 or Jeffrey Gabor at 202-551-2544
with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Kyle Leung
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