March 12, 2020

Laurent Bernard Marie Junique
Chief Executive Officer
TDCX (KY) PTE LTD
750D Chai Chee Roa
#06-01/06 Viva Business Park
Singapore 469004

       Re: TDCX (KY) PTE LTD
           Draft Registration Statement on Form F-1
           Submitted February 14, 2020
           CIK No. 0001803112

Dear Mr. Junique:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, 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 comments apply 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 these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1 submitted February 14, 2020

Prospectus Summary, page 1

1.     You refer to your leading clients such as Facebook and Airbnb on page 3
of your
       prospectus summary. In light of the risk factor on page 19 and the
concentration of your
       business related to Facebook and Airbnb, please disclose here that 52.1%
of your revenue
       in fiscal year 2018 is derived from these two clients.
2.     On page 2, you reference that more than half of your employees are
"tertiary school
       graduates, including employees with master's degrees and/or doctorates."
Please clarify
       what you mean by tertiary school graduates, as that term may differ as
to region. For
       example, please clarify whether over half of your employees are graduate
school
 Laurent Bernard Marie Junique
TDCX (KY) PTE LTD
March 12, 2020
Page 2
         graduates with advanced college or university degrees. Further, please
clarify if the
         tertiary school graduates are concentrated in certain markets.
3.       You reference deepening your relationships with your existing clients
is part of your
         growth strategy and that as you expand your services throughout your
clients' businesses
         and processes, that it encourages client "stickiness" and discourages
clients from turning
         to other providers. We further note per page 19, however, that you are
not exclusive
         providers to your clients generally. Please explain how you measure
client retention and
         advise us whether such measures would be considered key performance
indicators.
4.       You reference fixed price contracts based on statements of work as
part of master service
         agreements with your clients. It appears that these agreements are
generally 12 month
         agreements that are renewable on a yearly basis. Please clarify
whether the prices paid for
         services are revised on a yearly basis to reflect changes in market
conditions for your
         respective labor markets.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-IFRS Financial Measurements, page 76

5.       Please revise the caption for the Debt/EBITDA ratio to indicate that
Debt includes only
         Bank Loans. Refer to Item 10(e)(ii)(E) of Regulation S-K.
6.       Please disclose here, and elsewhere as applicable, that EBITDA and
EBITDA margin may
         not be comparable to similarly titled measures since your calculation
of EBITDA includes
         depreciation on the right-of-use assets and finance costs on lease
liabilities following your
         early adoption of IFRS 16.
History and Corporate Structure, page 85

7.       You provide a chart of your expected corporate structure as the date
of the prospectus
         following your reorganization, which you have not yet completed.
Please briefly describe
         the current corporate structure of your future subsidiaries and
operations and the steps
         necessary to complete your reorganization.
Industry Overview, page 87

8.     Please clarify the relevance of the market and industry data to your
business, particularly
       as it relates to geographic regions. For example, you provide certain
market data based on
       delivery locations, but with the markets served including all major
global end markets.
       On the other hand, on page 71 you refer to the Southeast Asia, Global
English and Europe
       end-markets. In order to understand how the data relates to your
business, please clarify
       how market data on delivery markets relates to your end-markets. For
example, clarify
FirstName LastNameLaurent Bernard Marie Junique
       the extent to which your clients, their customers, and your employees
are located in
Comapany NameTDCX (KY) as Southeast Asia and the extent to which your revenues
are
       particular regions such PTE LTD
March attributable to those regions.
       12, 2020 Page 2
FirstName LastName
 Laurent Bernard Marie Junique
FirstName LastNameLaurent Bernard Marie Junique
TDCX (KY) PTE LTD
Comapany2020
March 12, NameTDCX (KY) PTE LTD
March 12, 2020 Page 3
Page 3
FirstName LastName

9.       We note that the Frost & Sullivan report that you commissioned
contains various CAGR
         projections through 2024. Please provide more details of how these
projections were
         determined, including any material assumptions.
EBITDA Margins, page 103

10.      Please tell us if you believe the EBITDA margins of your peers are
calculated on a
         comparable basis. In this regard, we note that your calculation of
EBITDA includes
         depreciation on right-of-use assets and finance costs on lease
liabilities following your
         early adoption of IFRS 16.
Business
Case Studies, page 118

11.      Your case studies provide examples of the services provided by a New
Economy Client
         and a Search Engine Client. In light of the fact that Facebook and
Airbnb represented
         52.1% of total revenue for 2018, please consider providing similar
descriptions of the
         solutions that you provided to your two largest clients.
Employees and Culture, page 122

12.      Please clarify if there are material differences between the employees
and services
         provided in each geographic market. We note, for example, that 27% of
your employees
         for the fiscal year ended 2018 were based in Thailand, but Thailand
only represented
         approximately 7.1% of your total revenues for 2018. It is unclear what
accounts for this
         disparity, such as whether lower margin services are provided by your
Thailand
         operations.
13.      You provide the number of employees by your geographic locations on
page 126 and, per
         page 71, you derive all of your revenue in these geographic locations.
Please provide
         more detail as to the location of the customers to your clients and
which of your locations
         provides services to these locations. For example, for North American
customers of your
         clients that you provide customer experience or support services,
please clarify which of
         your locations service these customers. Similarly, please clarify
whether any of your
         locations outside of China provide services and interactions with
customers of your clients
         based in China.
Regulatory Environment, page 132

14.      On pages 22 and 23, you briefly discuss being subject to labor laws
that involve
         retirement, minimum wage, and general employee welfare. In light of
your business
         model that is dependent upon providing outsourced services of your
labor force, please
         expand this section to provide a brief description of such laws that
materially affect your
         operations, particularly as it relates to compensation, termination,
benefits, or other
         worker protections.
 Laurent Bernard Marie Junique
TDCX (KY) PTE LTD
March 12, 2020
Page 4
Description of Certain Indebtedness, page 144

15.   Please advise us whether the OCBC China Facility and/or OCBC Facility are
material
      agreements upon which you are substantially dependent and should be filed
as an exhibit
      pursuant to Item 601(b)(10) of Regulation S-K.
Notes to the Consolidated Financial Statements, page F-13

16.   In a note to the financial statements, please disclose your accounting
policy for costs to
      obtain and fulfill a contract. Refer to paragraphs 91, 94 and 95 of IFRS
15.
Note 3. Summary of Significant Accounting Policies
Revenue Recognition, page F-20

17.   We note on pages 27 and 31 that you incur significant start-up costs
related to investments
      in infrastructure to provide your services, including costs of
establishing your delivery
      centers "in accordance with your clients' preferred specifications and
hiring and training of
      employees, with such expenses being historically incurred before revenue
is generated."
      Please advise us and disclose how you account for these costs and any
related revenues.
General

18.   We note references to third-party market data throughout the prospectus,
including
      references to the report you commissioned from Frost & Sullivan. Please
provide us with
      copies of the Frost & Sullivan report and any other materials that
support third-party
      statements, clearly cross-referencing each statement with the underlying
factual support.
19.   Please supplementally provide us with copies of all written
communications, as defined in
      Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
      present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
      not they retain copies of the communications.
       You may contact Kathryn Jacobson, Senior Staff Accountant, at (202)
551-3365 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions regarding
comments on the financial statements and related matters. Please contact Edwin
Kim, Attorney-
Advisor, at (202) 551-3297 or Kathleen Krebs, Special Counsel, at (202)
551-3450 with any
other questions.



                                                             Sincerely,
FirstName LastNameLaurent Bernard Marie Junique
                                                             Division of
Corporation Finance
Comapany NameTDCX (KY) PTE LTD
                                                             Office of
Technology
March 12, 2020 Page 4
cc:       Rajeev P. Duggal, Esq.
FirstName LastName