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 December 15, 2025

Raymond Fu
Chief Executive Officer
Kuber Resources Corp
1113, Lippo Centre Tower 2, 89 Queensway
Admiralty, Hong Kong

 Re: Kuber Resources Corp
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 10-Q for the Quarterly Period Ended September 30, 2025
 File No. 000-26119
Dear Raymond Fu:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Note 2 - Summary of significant accounting policies
Segment Reporting, page F-11

1. Please revise to disclose the segment measure of profitability used by
the CODM and
 how the CODM uses such measure in allocating resources and assessing
performance.
 Note that for a single reportable segment entity we would generally
expect that net
 income is the required measure. In addition, disclose the significant
expense
 categories that are regularly provided to the CODM and included in the
reported
 segment profit or loss, and any other segment items. Refer to ASC
280-10-50-22, 50-
 26A,50-26B and 50-29(f) (and the example in ASC 280-10-55-54(c)).
 December 15, 2025
Page 2
Note 14 - Concentrations, Risks, and Uncertainties
(c) Unissued VAT invoices, page F-18

2. Please revise to disclose your accounting policy for VAT and which
financial
 statement line items are impacted by VAT. Also, you disclose that
$3,452,729 of sales
 VAT invoices were unissued as of December 31, 2024. Please revise to
clarify
 whether this represents the amount of sales that were not invoiced or
the amount of
 sales for which VAT invoices were not issued. In this regard, it is
unclear whether the
 VAT process impacts the amount of revenue recognized on the Consolidated
 Statement of Income. Lastly, you disclose that the VAT rules are imposed
by local
 authorities on newly established companies. Please explain why you
qualify as a
 newly established company.
General

3. Please revise to provide the disclosures in the Division of Corporation
Finance s
 Sample Letter to China-Based Companies issued by the Staff in December
2021. To
 the extent that the letter requests disclosure on the prospectus cover
page or in the
 prospectus summary, please provide these disclosures in the forepart of
your Form 10-
 K.
Form 10-Q for the Quarterly Period Ended September 30, 2025
Condensed Consolidated Financial Statements
Condensed Consolidated Balance Sheets, page 5

4. Please revise to disclose what the "Advances to suppliers" line item
represents.
Note 1 - Organization and Nature of Business, page 9

5. We note your disclosure on page 23 that the Gongfa Materials (Guangdong)
New
 Materials Technology Co., Limited ("Gongfa") transaction was structured
under a
 VIE framework, with common control established through the power and
economic
 interests of Mr. Li Jiyong. Revise to disclose the terms of the
contractual agreements
 that give the company power and economics over the VIE.
6. Disclose qualitative information about involvement with the VIE,
including the
 nature, purpose, size, and activities of the VIE. Also include a
description of the
 recognized and unrecognized revenue-producing assets that are held by
the VIE.
 These assets may include licenses, trademarks, other intellectual
property, facilities or
 assembled workforce. Refer to ASC 810-10-50-5A.d.
7. Disclose quantitative information for the VIE including revenue; net
income;
 operating, investing, and financing cash flows; and the carrying amount
and
 classification of the VIE s assets and liabilities, including
intercompany payables.
 Material related party transactions of the VIE should be presented
separately. Refer to
 paragraphs 5A.d., 2AA.d., and 3.bb of ASC 810-10-50.
 December 15, 2025
Page 3
Note 11 - Acquisition of Business under Common Control, page 21

8. You disclose that the acquisition of Gongfa was accounted for as a
business
 combination of entities under common control. Please describe, in
detail, the
 relationship between and ownership in the entities involved in the
transaction prior to
 and after the acquisition of Gongfa that supports the common control
determination
 for accounting purposes. Refer to ASC 805-50-15-6. In addition, you
disclose that
 "the transaction was structured under a VIE framework, with common
control
 established through the power and economic interests of Mr. Li Jiyong."
Please
 provide us with an analysis explaining which entities are VIEs and how
you
 concluded that the acquisition of the VIE met the criteria for a common
control
 transaction. Refer to the specific authoritative guidance you considered
in your
 accounting for these transactions.

 In closing, 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.

 Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Timothy Lam
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