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WRITER’S DIRECT LINE

+86.21.8022.8568

WRITER’S EMAIL

[email protected]

February 8, 2024

Confidential

Ms. Christine Torney

Ms. Angela Connell

Mr. Alan Campbell

Ms. Doris Stacey Gama

Division of Corporation Finance

Office of Life Sciences

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Dear Ms. Torney, Ms. Connell, Mr. Campbell, Ms. Gama:

On behalf of our client, Cuprina Holdings (Cayman) Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we submit to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated February 5, 2024 on the Company’s amendment No.3 to draft registration statement on Form F-1 confidentially submitted on January 26, 2024. Concurrently with the submission of this letter, the Company is submitting its revised draft registration statement on Form F-1 (the “Revised Draft Registration Statement”) and certain exhibits via EDGAR to the Commission for confidential review pursuant to the Jumpstart Our Business Startups Act.

The Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references in the Revised Draft Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Revised Draft Registration Statement.

Management

Compensation of Directors and Executive Officers, page 134

In response to the Staff’s comment, the Company has revised the disclosure on page 134 of the Revised Draft Registration Statement.

Notes to Consolidated Financial Statements

1 - Organization and business overview

Reorganization of the Company’s legal structure (the “Reorganization”), page F-7

In response to the Staff’s comment, the Company respectfully submits that all activities for the years ended December 31, 2021 and 2022 and the six months ended June 30, 2023, were carried out by Cuprina Pte. Ltd. As part of the Group’s internal reorganization for the purpose of listing, Cuprina Holdings (Cayman) Limited was incorporated in the Cayman Islands on September 22, 2023. Previous submissions to the Commission referred to Cuprina Holdings (Cayman) Limited as the reporting entity, even though the reorganization had not been completed before the end of January 2024. Following the completion of the reorganization in January 2024, there has been an official change of the reporting entity from Cuprina Pte. Ltd. to Cuprina Holdings (Cayman) Limited. This change occurred because the reorganization was accounted for as a recapitalization among entities under common control, as Cuprina Holding Pte. Ltd. was the controlling shareholder of all these entities both before and after the reorganization. In a transaction that is considered to be a transfer of net assets or exchange of equity interest between entities under common control, the receiving entity reflects the transfer as a change in the reporting entity on a retrospective basis. ASC 805-50-30-5 applies to transfers of net assets or exchange of equity interest between entities under common control and requires the receiving entity to reflect the transfer in a manner similar to a pooling of interests. Similarly, the changes in the issued and outstanding share capital of Cuprina Holdings (Cayman) Limited are a result of the change in the reporting entity mentioned above, as Cuprina Holdings (Cayman) Limited will be the entity going for the initial public offering in this case.

If you have any questions regarding the Revised Draft Registration Statement, please contact the undersigned by phone at +86.21.8022.8568 or via e-mail at [email protected].