<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                            September 13, 2024

Ng Chen Lok
Chief Executive Officer
Sagtec Global Ltd
No 43-2, Jalan Besar Kepong,
Pekan Kepong, 52100 Kuala Lumpur

        Re: Sagtec Global Ltd
            Draft Registration Statement on Form F-1
            Submitted August 16, 2024
            CIK No. 0002029138
Dear Ng Chen Lok:

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

        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 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 the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional comments.

Draft Registration Statement on Form F-1 submitted August 16, 2024
Enforceability of civil liabilities, page 24

1.      We note your disclosure here that the majority of your operations and
current assets are
        located in Singapore, while on page F-33 you state that    [t]he Group
 s operations are
        located in Malaysia.     The geographical locations of the Group   s
non-current assets are
        mostly situated in Malaysia based on physical location of assets.
Please clarify the
        location of your operations and assets.
Results of Operations
Comparison of the Results for the Fiscal Years Ended December 31, 2022 and
2023, page 31

2.      Please revise the table to disclose the percentage of revenue from your
products and
        services.
 September 13, 2024
Page 2
Business
Our Customers, page 51

3.     We note that three customers accounted for 17.0%, 16.8% and 13.66% of
your revenue
       for the fiscal year ended December 31, 2023. Please disclose the
material terms of your
       agreements with each of these three customers, including the identity,
term, termination
       provisions and any minimum purchase requirements. Please file your
agreements with
       these customers or advise. See Item 601(b)(10) of Regulation S-K.
Our Suppliers, page 51

4.     We note that two of your suppliers accounted for 34.69% and 25.84% of
your cost of
       sales for the fiscal year ended December 31, 2023. Please revise to
identify these suppliers
       and provide a summary of the material terms of your agreements with
these suppliers,
       including the term, termination provisions and any minimum purchase
requirements. See
       Item 4.B.6 of Form 20-F. Additionally, please file these agreements as
exhibits. See Item
       601(b)(10) of Regulation S-K. Lastly, add a risk factor that discusses
risks resulting from
       your dependence on a limited number of suppliers. See Item 3.D. of Form
20-F.
Employees, page 55

5.     We note that as of the date of this prospectus, you had a total of 22
employees. Please
       expand your disclosure to provide either the number of employees at the
end of the period
       or the average for the period for each of the past three financial years
(and changes in such
       numbers, if material). Refer to Item 6.D of Form 20-F.
Description of authorized and issued shares, page 70

6.     We note you disclose that 13,144,059 Ordinary Shares are issued and
outstanding as of
       the date of this prospectus on pages 28 and 70. However, based on your
disclosures
       throughout the rest of your filing, it appears 11,294,059 Ordinary
Shares are issued and
       outstanding. Please explain the difference or revise.
Consolidated statements of financial position, page F-3

7.     We note the sale of food ordering kiosk machines and the sale of
power-bank charging
       stations contributed 28.57% and 48.73% of your revenue, respectively for
the years ended
       December 31, 2022, and December 31, 2023. We also note you did not
present a line
          Inventories    on the face of your Consolidated statements of
financial position as set forth
       in paragraph 54 of IAS1. In this regard, please explain to us how you
account and manage
       your inventories.
Consolidated Statements of Profit or Loss and Other Comprehensive Income, page
F-4

8.     We note your disclosures of cost of sales on page F-28, and it appears
staff costs and
       benefits were not allocated to cost of sales. We also note your
disclosure of staff costs
       and benefits in your expenses by nature, which it is approximately 68%
of total operating
       expenses. In this regard, please tell us whether any of these costs are
directly attributable
       to revenue and therefore are required to be included in costs and
expenses applicable to
       revenues (i.e., cost of revenue). We refer you to IAS 1 paragraphs 99 to
105.
 September 13, 2024
Page 3
9.     It appears your basic and diluted net income per share is calculated
using the net profit for
       the year instead of the amounts attributable to ordinary equity holders
of the parent entity.
       Refer to IAS 33 paragraph 12. Please revise or advise.
Consolidated Statements of Cash Flows, page F-6

10.    Please clarify whether the bank overdrafts are repayable on demand as
describe in IAS 7
       paragraph 8. If so, tell us your consideration of including the bank
overdraft as a
       component of cash and cash equivalents.
Notes to consolidated financial statements
Note 2. Material accounting policies
Convenience Translation, page F-9

11.    We note your statement that all translations from RM into USD for the
fiscal year ended
       December 31, 2023 were calculated at of USD1 = RM4.5892 or an average
rate of USD1
       = RM4.5679. Please clarify how the use of an average rate complies with
Rule 3-20(b) of
       Regulation S-X. Rule 3-20(b) of Regulation S-X specifies that the
translation should be
       presented using the exchange rate as of the most recent balance sheet
included in the
       filing, except that a rate as of the most recent practicable date shall
be used if materially
       different. In addition, please revise your MD&A to remove any reference
to U.S. dollar
       period over period changes so that your filing is presented on a
consistent basis. Lastly,
       please clarify your statement on page 15 that "[y]our reporting currency
is United States
       Dollars."
Revenue recognition, page F-12

12.    We note from your disclosure within your Business Overview that you
offer customizable
       software and application development for table ordering, QR ordering and
self-service
       kiosk ordering. You also sell food ordering kiosk machines designed to
improve the
       dining experience for both customers and businesses. You further provide
additional
       products and services through the sale of power-bank charging stations
through our
       majority owned subsidiary, CL Technologies. In these regards, please
expand your
       revenue recognition accounting policy disclosure to enable users to
understand the nature,
       amount, timing and uncertainty of revenue and cash flows arising from
your contracts
       with customers as set forth in paragraph 11 of IFRS 15 to address, but
not limited to, the
       following.
           Please disclose significant terms of these contracts with customers,
such as the
           duration of these contracts.
           Please describe nature of services and products that you provide to
your customers.
           Explain to us precisely what your performance obligation is (i.e.,
the service you
           provide) for each revenue stream and how you fulfil the performance
obligation.
           Disclose how to determine whether a customer obtains control of an
asset or service.
           For revenues are recognized over time, please clarify if recognized
on a straight-line
           basis or some other method.
           Please disclose how you account for Costs to obtain or fulfill a
contract, if applicable.
 September 13, 2024
Page 4

Note 7. Dispositions of Sagtec Group Sdn Bhd, page F-17

13.    We note you presented disposal gain in amount RM662,701 as a result of
the dispositions
       of Sagfood (Malaysia) Sdn Bhd as a line item to arrive at income from
operations before
       income tax on the face of the financial statements. In this regard,
please elaborate on why
       the disposal of Sagfood (Malaysia) Sdn Bhd should not be presented as
discontinued
       operations. Refer to IFRS 5.
Note 10. Trade receivables, page F-21

14.    It appears that amounts of your trade receivables presented on the face
of balance sheets
       are net of provision for expected credit loss. In this regard, please
revise the balance sheet
       caption    Trade receivable    to    Trade Receivables, net   .
Note 19. Expenses by nature, page F-28

15.    We note your total expenses by nature is not equal to your total selling
and administrative
       expenses on the face of consolidated statements of profit or loss and
other comprehensive
       income. In this regard, please revise or advise.
23. Operating segments, page F-33

16.    We refer to your tables which present summarized financial information
for your five
       reportable segments. In this regard, please reconciles herein the total
of the reportable
       segments    measures of profit or loss (business operating income) to
consolidated profit or
       loss before tax expense in accordance with paragraph 28 of IFRS 8 or
tell us why you
       believe the current reconciliation to Gross Profit complies with that
literature.
Exhibits

17.    We note that you or your subsidiaries have credit facilities. Please
file your credit facility
       agreements or advise. See Item 601(b)(10) of Regulation S-K.
General

18.    Please provide us with supplemental copies of all written
communications, as defined in
       Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your
       behalf, have presented or expect to present to potential investors in
reliance on Section
       5(d) of the Securities Act, whether or not you retained, or intend to
retain, copies of those
       communications.
       Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-551-3574
with any
other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
 September 13, 2024
Page 5
cc:   Yarona Yieh
</TEXT>
</DOCUMENT>
