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United States securities and exchange commission logo





                               May 24, 2024

       David Quek Yong Qi
       Chief Executive Officer
       Cuprina Holdings (Cayman) Limited
       Blk 1090 Lower Delta Road #06-08
       Singapore 169201

                                                        Re: Cuprina Holdings
(Cayman) Limited
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed May 16, 2024
                                                            File No. 333-277731

       Dear David Quek Yong Qi:

            We have reviewed your amended 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.

       Amendment No. 1 to Registration Statement on Form F-1

       Underwriting
       Lock-up Agreements, page 162

   1.                                                   Please revise to
specify the exceptions to the lock-up agreements.
       General

   2.                                                   Please revise the cover
pages of both the primary and resale prospectuses to clearly state,
                                                        if true, that the
selling shareholders may not commence their resale of shares until after
                                                        the IPO closes. Please
also revise to clarify, if true, that neither the primary offering nor
                                                        the resale offering
will proceed if your ordinary shares are not approved for listing on
                                                        Nasdaq.
   3.                                                   We refer to your
explanatory note regarding the two prospectuses for the primary and
                                                        secondary offering as
well as your registration statement cover page which appears to
 David Quek Yong Qi
Cuprina Holdings (Cayman) Limited
May 24, 2024
Page 2
      indicate that the resale offering will be made pursuant to Rule 415.
Please provide us an
      analysis explaining your basis for determining that the secondary
offering is eligible to be
      made under Rule 415(a)(1)(i). In responding, please consider the guidance
provided in
      Compliance Disclosure Interpretations, Securities Act Rules, Question
612.09. In your
      response, please tell us whether either of the selling shareholders have
business or familial
      relationships with employees or affiliates of your company.
4.    We note your disclosure on your resale prospectus cover page and page
ALT-2 that your
      selling shareholders may sell their securities through one or more
transactions that may
      take place in ordinary brokers    transactions, privately negotiated
transactions or through
      sales to one or more dealers for resale of such securities as principals.
Please confirm your
      understanding that the retention by a selling shareholder of a dealer or
underwriter would
      constitute a material change to your plan of distribution requiring a
post-effective
      amendment. Please also revise Item 9 to provide the undertakings required
by Item 512(a)
      of Regulation S-K.
5.    Please revise the cover page of the resale prospectus so that it does not
assume the prior
      consummation of your primary initial public offering and listing of your
Class A ordinary
      shares on Nasdaq.
       Please contact Christine Torney at 202-551-3652 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Doris Stacey Gama at 202-551-3188 or Alan Campbell at 202-551-4224 with
any other
questions.



                                                            Sincerely,
FirstName LastNameDavid Quek Yong Qi
                                                            Division of
Corporation Finance
Comapany NameCuprina Holdings (Cayman) Limited
                                                            Office of Life
Sciences
May 24, 2024 Page 2
cc:       Mathew Lewis, Esq.
FirstName LastName
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