September 16, 2025

Wong Kok Seng
Chief Executive Officer
UltraTrex Inc.
220 Orchard Road
Unit 05-02, Midpoint Orchard
Singapore 238852

       Re: UltraTrex Inc.
           Registration Statement on Form F-1
           Filed September 8, 2025
           File No. 333-290101
Dear Wong Kok Seng:

       We have reviewed your registration statement and have the following
comment.

        Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form F-1
General

1.     We note your filing includes audited financial statements that are older
than 12
       months. Please update your financial statements pursuant to Item 8.A.4
of Form 20-F
       or provide the appropriate representations in an exhibit. Refer to
Instruction 2 to Item
       8.A.4.
        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 Rule 461 regarding requests for acceleration. Please allow
adequate time for
us to review any amendment prior to the requested effective date of the
registration
 September 16, 2025
Page 2

statement.

        Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at
202-551-3574
with any other questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Technology
cc:   Yarona Yieh