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                                                            January 10, 2025

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

       Re: Sagtec Global Ltd
           Registration Statement on Form F-1
           Filed December 26, 2024
           File No. 333-284053
Dear Ng Chen Lok:

       We have reviewed your 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. Unless
we note
otherwise, any references to prior comments are to comments in our November 26,
2024
letter.

Registration Statement on Form F-1
Prospectus Summary
Recent Developments, page 6

1.     We note your statement that you or your auditor may identify    items
that would
       require [you] to make adjustments to the financial information.. and any
resulting
       changes could be material. Accordingly, undue reliance should not be
placed on these
       preliminary estimates.    If you choose to disclose preliminary results,
you should be
       able to assert that the actual results are not expected to differ
materially from that
       reflected in the preliminary results. Accordingly, please remove this
statement, as it
       implies that investors should not rely on the information presented.
2.     Please revise your estimates for the year ended December 31, 2024 to
include cost of
       sales expense in addition to the operating expenses.
 January 10, 2025
Page 2

Business
Our Customers, page 64

3.     We note your responses to prior comment 1 and comment 3 of our letter
dated
       September 13, 2024 and re-issue these comments. Please revise to
discloses the
       identities of these greater than 10% customers. In this regard, we view
this
       information to be material. To the extent you continue to believe this
information is
       not required, please provide a detailed legal analysis explaining why
you believe this
       information is not material.
Our Suppliers, page 68

4.     We note your responses to prior comment 2 and comment 4 of our letter
dated
       September 13, 2024 and re-issue these comments. Please revise to
disclose the
       identities of the suppliers that accounted for greater than 10% of your
cost of sales for
       the fiscal year ended December 31, 2023. In this regard, we view this
information to
       be material. To the extent you continue to believe this information is
not required,
       please provide a detailed legal analysis explaining why you believe this
information is
       not material.
Index to unaudited interim condensed consolidated financial statements, page
F-34

5.     We note that you have provided the unaudited interim condensed
consolidated
       financial statements as of and for the six months period ended June 30,
2024. In this
       regard, please revise to clearly label your interim financial statements
information as
       "unaudited" where appropriate throughout the filing, including, but not
limited to the
       following sections: summary financial data, capitalization, dilution,
management   s
       discussion and analysis of the financial condition and results of
operations.
        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.

       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 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
 January 10, 2025
Page 3
cc:   Yarona Yieh
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