September 23, 2024

Via EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

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

Filed September 5, 2024

File No. 333-281629 

Dear Ms. O’Shanick, Ms. Purnell, Mr. James, Mr. Eastman:

As counsel for Cre8 Enterprise Limited (the “Company”) and on its behalf, this letter is being submitted in response to the letter dated September 10, 2024 from the U.S. Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced Registration Statement on Form F-1 submitted on September 5, 2024. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, an amended Registration Statement on Form F-1 (“Form F-1”) for filing with the Commission, which has been revised to reflect the Staff’s comments as well as certain other updates to the Form F-1.

For the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references below in the Company’s responses are to the page numbers in Form F-1. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Form F-1.

Amendment No. 1 to Registration Statement on Form F-1 Part II - Information Not Required In the Prospectus

Item 8. Exhibits and Financial Statement Schedules Exhibit Index

Exhibit 99.7 Opinion of Guangdong Wesley Law Firm, PRC Counsel to the Registrant, regarding certain PRC law matters, page II-3

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully advise the Staff that we have provided a revised PRC legal opinion provided by Guangdong Wesley Law Firm, our PRC Counsel, which is filed as Exhibit 99.7 to the Form F-1 to clarify that no over-allotment shares were issued prior to the effectiveness of the registration statement.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully advise the Staff that we have provided a revised PRC legal opinion provided by Guangdong Wesley Law Firm, our PRC Counsel, which is filed as Exhibit 99.7 to the Form F-1, to clearly opine on each representation in the registration statement as attributed to our PRC counsel, by cross-referencing to the specific sections in the registration statement in the PRC Counsel’s opinion.

RESPONSE: We note the Staff’s comment, and in response hereto, respectfully advise the Staff that we have provided a revised PRC legal opinion provided by Guangdong Wesley Law Firm, our PRC Counsel, filed as Exhibit 99.7 to the Form F-1, which removed the aforesaid statement on the page 8 of the opinion.

We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.