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January 29, 2021

Confidential
Ms. Kathryn Jacobsen
Mr. Edwin Kim
Mr. Robert Littlepage
Ms. Jan Woo
Division of Corporation Finance
Office of Technology
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re: TDCX (KY) PTE LTD
Response to the Staff   s Comments dated March 12, 2020 on the Draft
Registration Statement Submitted
February 14, 2020
CIK No. 0001803112

Dear Ms. Jacobsen, Mr. Edwin Kim, Mr. Littlepage and Ms. Woo:

      On behalf of our client, TDCX (KY) PTE LTD, a company 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 March 12, 2020 on the Company   s draft registration statement on Form
F-1 confidentially submitted on
February 14, 2020 (the    Draft Registration Statement   ).

      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    JOBS Act   ). The
Company confirms that it will include its audited financial statements for the
year ended December 31, 2020 in a
 subsequent filing. In addition to adding and revising disclosure in response
to the Staff   s comments, the Company
has updated the Revised Draft Registration Statement to remove its audited
consolidated financial statements for the
year ended December 31, 2017 and include its audited consolidated financial
statements for the year ended
December 31, 2019 and related financial information.
                                                          1

     To facilitate your review, we have separately delivered to you today four
courtesy copies of the Revised Draft
Registration Statement, marked to show changes to the Draft Registration
Statement, and four copies of the
submitted exhibits.

      The Staff   s comments are repeated below in italics 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.

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.
      In response to the Staff   s comment, the Company has revised the
disclosure on pages 3 and 118 of the Revised
      Draft Registration Statement.
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 graduates with advanced college or
university degrees. Further, please clarify
     if the tertiary school graduates are concentrated in certain markets.
      In response to the Staff   s comment, the Company has revised the
disclosure on pages 2, 117 and 133 of the
      Revised Draft Registration Statement. The Company further notes that, for
each of its offices, over half of our
      employees are college or university graduates (i.e. post high school),
including employees with master   s
      and/or doctorate degrees.
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.
      The Company respectfully submits that exclusive arrangements with clients
in its industry are not standard
      practice due to clients    own desires to mitigate their reliance on any
single third-party vendor. The Company
      believes, however, that as it expands and deepens its relationship,
service offerings and touch points with a
      client,    stickiness    with, and loyalty from, that client increases
because, among other things, the client will
      consider favorably the convenience and efficiency afforded by obtaining
the services from the Company,
      consider the benefits it derives from obtaining a wider range of services
from the Company, and have a deeper
      engagement with the Company, which allows the Company more opportunities
to demonstrate its value to
      them, even though the Company would not be an exclusive provider to the
client.
      The Company measures client retention on an annual basis based on
percentage of clients who remain active
      clients in any period compared to any previous period. The Company does
not believe that this measure is a
      key performance indicator because the Company has decided to focus on
attracting clients by providing
      solutions that attract a mix of new economy clients as well as
traditional clients undergoing digital
      transformation rather than focus solely on other traditional clients to
whom it historically provided services.
                                                          2

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.
      The Company respectfully submits that while the master service agreements
are generally for 12-month terms,
      the client may or may not, depending on the terms of the agreements, have
the right to extend the term and/or
      revise the pricing from the original 12-month term. Accordingly, prices
paid for services are not always
      revised on a yearly basis and, depending on the agreement, the Company
may not be able to re-
      negotiate pricing terms after any primary or renewal term.
      The Company has revised the disclosure on page 20 of the Revised Draft
Registration Statement accordingly.

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.
      The Company respectfully submits that Debt was defined as bank loans and
Debt/EBITDA ratio as bank loans
      divided by EBITDA on page 76 of the Draft Registration Statement and is
defined on pages 16, 66, 80 and
      121 of the Revised Draft Registration Statement.
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.

      In response to the Staff   s comment, the Company has revised the
disclosure on pages 16, 66, 80 and 121 of the
      Revised Draft Registration Statement.
                                                         3

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.
      The Company respectfully submits that the reorganization has been
completed on December 16, 2020 and that
      the corporate structure included on pages 7 and 90 of the Revised Draft
Registration Statement reflects the
      current corporate structure of the Company.

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
     the extent to which your clients, their customers, and your employees are
located in particular regions such as
     Southeast Asia and the extent to which your revenues are attributable to
those regions.
      The Company respectfully submits that many of the outsourced business
services providers, including the
      Company, have global operations with delivery locations around the world
and serve clients and our clients
      customers that are located both in the same country as the delivery
location (onshore) and in countries
      different from the delivery location (offshore). Therefore, market sizing
has been conducted by segmenting
       revenue based on the delivery location, which includes both onshore and
offshore data. For instance,
      Southeast Asia market revenue represents the service providers
earnings associated with customer
      interactions that are delivered from their delivery locations in
Southeast Asia, regardless of where the
      customers are physically located. Revenue includes fulfillment models
such as onshore, offshore, home-agent,
      automated and technology-enabled solutions. As a popular offshore
destination, Southeast Asia delivery
      centers cater to offshore North American, European and Australian markets
as well as onshore domestic
      markets.
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.
      In response to the Staff   s comment, the Company has attached the
requested material in Exhibit A.

                                                          4

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.
      The Company respectfully advises the Staff that it has implemented an
early adoption of IFRS 16 and
      presented its financial statements consistently for each of the fiscal
years 2018 and 2019.
      Based on the Company   s review of the financial disclosure of its peers
that report under IFRS and as
      summarized below, the Company is not aware of any of its peers similarly
implementing an early adoption of
      IFRS 16 prior to fiscal year 2019. As such, EBITDA margins of its peers
reporting under IFRS may not be
      calculated on a comparable basis for 2018. However, the Company
respectfully submits that it believes that
      EBITDA margins for the majority of its peers that report under IFRS 16
have included depreciation on right-
      of-use assets and finance costs on lease liabilities and are calculated
on a comparable basis for 2019.
      Additionally, as it relates to the Company   s peers that report under US
GAAP, the Company respectfully
      advises the Staff that it has considered the joint meeting held between
the Centre for Audit Quality (CAQ)
      SEC Regulations Committee and the Staff on March 20, 2019 where committee
members observed an
      EBITDA measure presented after the adoption of ASC 842 under U.S. GAAP
may no longer be comparable to
      the same measure presented by an IFRS filer after the adoption of IFRS
16. Specifically, the Company
      understands that under ASC 842, the reduction in the right of use asset
relating to operating leases is recorded
      as part of lease expense rather than depreciation. As a result, EBITDA
margins of the Company   s peers
      adopting Topic 842 may also not be calculated on a comparable basis.
      As noted in our response to the Staff   s comment No. 6, the Company has
revised the disclosure on pages 16,
      66, 80 and 121 of the Revised Draft Registration Statement to clarify the
foregoing.
      The table below provides summary information on the Company and its
peers, each   s accounting standard and
      whether they have adopted the relevant new lease accounting standard.

                                                                     New Lease
Accounting Standard

Adopted?

                  Accounting
         Peers                                                FY2018    FY2019
      FY2020       Standard
         TDCX                                                 IFRS16
IFRS16                     IFRS
         Teleperformance
IFRS16                     IFRS
         Genpact                                                          Topic
842                   GAAP
         Concentrix
                        GAAP
         TTEC                                                             Topic
842                   GAAP
         EXLService                                                       Topic
842                   GAAP
         WNS
           IFRS16        IFRS
         Accenture
         Topic 842      GAAP
         Cognizant                                                        Topic
842                   GAAP
          Capgemini
IFRS16                     IFRS
         EPAM
Topic 842                   GAAP
         Globant
IFRS16                     IFRS
         Endava
IFRS16       IFRS16        IFRS
      In addition, the Company also respectfully advises the Staff that the
charts used for comparison analyses of
      (i) its EBITDA margins and (ii) its EBITDA per average employee compared
with those of its peers have been
      updated with 2019 information, as reflected on pages 112 and 113 in the
Revised Draft Registration
      Statement. Additionally, the Company has included footnote references
that EBITDA margin and EBITDA
      per employee, respectively, are non-IFRS measures which should not be
considered in isolation or as a
      substitute for financial results reported under IFRS and that similarly
titled non-IFRS measures may be
      calculated differently by or for different companies.
                                                          5

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.
      The Company respectfully submits that the New Economy Client and Search
Engine Client case studies have
      been provided to illustrate to investors the services and capabilities of
the Company generally rather than for a
      specific client. Descriptions of services the Company provides to Airbnb
is on page 123 of the Revised Draft
      Registration Statement and descriptions of services provided to Facebook
are included on pages 116 and 124
      of the Revised Draft Registration Statement (as services provided to
social media clients). As a result, the
      Company believes that the Revised Draft Registration Statement provides
investors with a description of the
      services and capabilities provided to both its largest clients and to its
other 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.
      The Company respectfully submits that the Draft Registration Statement
stated that Thailand had 831
      employees out of 5,712 total employees (14.5% and not 27%) for the fiscal
year ended December 31, 2018 on
      page 122 of the Draft Registration Statement, which has been updated to
848 employees out of 5,731 total
      employees (14.8%) reflected on page 137 of the Revised Draft Registration
Statement. This notwithstanding,
      there is a discrepancy between percentage of total employees contributed
by and percentage of total revenue
      generated from the Thailand office due to the impact of campaigns in
Thailand that began in the third quarter
      of 2018. The total number of employees in Thailand as of December 31,
2018 reflects the increased headcount
      required for the new campaigns, but the Company did not receive full year
revenues for those campaigns in
      2018. As reflected on page 137 of the Revised Draft Registration
Statement, the Thailand office had 12.8% of
      total employees as of December 31, 2019 and generated 12.5% of total
revenue in 2019. The Company notes
      that it allocates revenue based on the geography of the office that
delivers the service, not the location of the
      client engaging the Company   s services or the location of the customer
that the Company is interacting with.
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.
       The Company respectfully submits that the percentage of revenue by
geographic location (presented in the
      table on page 71 of the Draft Registration Statement as referred to in
the Staff   s comment, which is now on
      page 74 of the Revised Draft Registration Statement) is based on the
geography of the office that delivers the
      service, not the location of the client engaging the Company   s services
or the location of the customer that the
      Company is interacting with. In order to clarify this, the Company has
revised the disclosure on page 74 of the
      Revised Draft Registration Statement.
      The Company respectfully submits that it often does not receive
comprehensive data from its clients regarding
      the originating location of their end-customers, nor is such data always
necessary for the Company to provide
      its services.
      The delivery center location out of which the Company provides services
does not correlate consistently to the
      location of the customers of the Company   s clients. For
      example, a particular Company delivery center location may provide
services to client A   s customers in North
      America, while a different Company delivery center location may provide
services to client B   s customers in
      North America, as these determinations vary based on client choices,
relevant skills, particular campaigns and
      other considerations. Delivery center locations out of which the Company
provides services to a particular
      geography may also vary from period to period, client to client and
service to service. Moreover, customers of
      the Company   s clients may access the Company   s services from varying
geographies and not just the location
      of their residence.
      At present, in general based on information available to the Company
about customers of its clients (and as
      presented in footnotes 2 and 3 to the table on page 71 as referred to in
the Staff   s comment, which table is now
      on page 74 of the Revised Draft Registration Statement), the Company   s
locations in the Philippines provide
      services to North America based customers of the Company   s clients, and
the Company   s locations in
      Singapore, Malaysia and Thailand provide services to China based
customers of the Company   s clients,
      though the Company cannot be completely certain as to the location of its
clients    customers due to the lack of
      accurate and/or comprehensive information noted above.
                                                           6

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.
      In response to the Staff   s comment, the Company has revised the
disclosure for each jurisdiction in the
         Regulatory Environment    section of the disclosure on pages 143 to
149 of the Revised Draft Registration
      Statement.

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.
      The Company respectfully submits that neither the OCBC China Facility nor
the OCBC Facility are material
      agreements upon which the Company is substantially dependent and
therefore neither of such agreements will
      be filed as exhibits 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.
       In response to the Staff   s comment, the Company respectfully advises
the Staff that it has considered the
      guidance under paragraphs 91, 94 and 95 of IFRS 15 and concluded that the
accounting policy for costs to
      obtain and fulfill a contract is not applicable to the Company and its
subsidiaries. Specifically, the Company
      respectfully advises the Staff that in arriving at this conclusion, the
Company has considered that the costs
      incurred by the Company which are incidental to its revenue contracts
mainly include (1) personnel and travel
      costs, (2) hiring and training employees and (3) capital expenditures
incurred for infrastructure, renovation
      and leases of office space.
      Personnel and incidental costs would be incurred in the process of
bidding and pitching for contracts
      regardless of whether the contracts were successfully obtained by the
Company   s personnel and, as such, are
      recorded as expenses when incurred in accordance with paragraph 91 of
IFRS 15 as the Company does not
      expect to recover those expenses. Costs related to hiring and training
employees are also recorded as expenses
      when incurred as the Company has concluded that those costs do not
generate or enhance resources of the
      entity and, therefore, do not meet the criteria in paragraph 95 of IFRS
15. The Company believes the above is
      consistent with the Basis of Conclusion 308 of IFRS 15 where the IASB
explained that the standard only
      results in the capitalization of costs that meet the definition of an
asset and precludes an entity from deferring
      costs merely to normalize profit margins throughout a contract (by
allocating revenue and costs evenly over
      the contract term). In cases where the start-up costs to fulfil a
contract include capital expenditures in
      infrastructure, renovation and leases of offices space, the Company
respectfully advises the Staff that those
      costs are recorded based on the guidance included in IAS 16 Property
Plant and Equipment and IFRS 16,
      Leases which is consistent with paragraph 95 of IFRS 15.
      Based on the above, the Company does not believe that it incurs such
costs to obtain and fulfill a contract that
      meet the recognition criteria included in Paragraphs 91, 94 and 95 of
IFRS 15.
      In response to the Staff   s comment, the Company has supplemented its
revenue recognition policy on page 86
      of its Revised Draft Registration Statement and pages 17 to 18 of its
F-pages to clarify the above.

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.
      The Company respectfully advises the Staff that the nature and accounting
of start-up costs related to
      investments in infrastructure, including those to establish its delivery
centers, are described in the preceding
      response. The Company further advises the Staff that no revenue is
recorded in relation to these costs as they
      are incurred prior to provision of services to customers. In response to
the Staff   s comment, the Company has
      revised its revenue recognition policy included on page 86 of the Revised
Draft Registration Statement and
      pages 17 and 18 of its F-pages.
                                                           7

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.
      In response to the Staff   s comment, the Company has attached the
requested material in Exhibit B.
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.
      In response to the Staff   s comment, the Company has attached the
requested material in Exhibit C.
                                                  *     *      *

                                                        8

     If you have any questions regarding the Revised Draft Registration
Statement, please contact the undersigned
by phone at +65 6434-2980 or via e-mail at rajeev.duggal@skadden.com.

                                                                    Very truly
yours,
                                                                    /s/ Rajeev
Duggal
                                                                    Rajeev
Duggal
                                                        9