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                           April 11, 2022

       Chong Chan Teo
       Chief Executive Officer
       Treasure Global Inc.
       276 5th Avenue, Suite 704 #739
       New York, New York 10001

                                                        Re: Treasure Global
Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted on March
23, 2022
                                                            CIK No. 0001905956

       Dear Mr. Teo:

              We have reviewed your amended draft registration statement and
have the following
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              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 our 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 our
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Capitalization, page 42

   1.                                                   We note your response
to comment 5. Please revise your capitalization table to only show
                                                        accounts related to
indebtedness and stockholders' deficit. In addition, revise the pro
                                                        forma column to include
the issuances of shares related to the conversions of debt and
                                                        anti-dilution
agreements.
 Chong Chan Teo
FirstName   LastNameChong Chan Teo
Treasure Global  Inc.
Comapany
April       NameTreasure Global Inc.
       11, 2022
April 211, 2022 Page 2
Page
FirstName LastName
       You may contact Abe Friedman at 202-551-8298 or Joel parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Jennifer L  pez Molina at
202-551-3792 with any
other questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services