SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 29, 2026

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 reviewed your January 22, 2026 response to our comment letter
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. Unless
we note otherwise, any references to prior comments are to comments in our
December 15, 2025
letter.

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. We note the proposed disclosure provided in your response to prior
comment 1. Please
 further revise to discuss how the CODM uses the segment measure of
profitability in
 assessing segment performance and deciding how to allocate resources.
Refer to ASC
 280-10-50-29(f) and the example in ASC 280-10-55-54(c).
 January 29, 2026
Page 2
Note 14 - Concentrations, Risks, and Uncertainties
(c) Unissued VAT invoices, page F-18

2. We note your response to prior comment 2 indicates that Kuber Guangdong
was
 incorporated in October 2023 and you disclose that during the nine
months ended
 September 30, 2025, the Company issued VAT invoices for total sales of
approximately
 $28.8 million. Please reconcile this amount to the revenues reported in
your statement of
 income. In this regard, we note that total revenue for the two year
period ended
 December 31, 2024 plus the nine-months ended September 30, 2025 was only
 approximately $16.4 million.
General

3. We note your response to prior comment 3 does not address each of the
comments in the
 Division of Corporation Finance s Sample Letter to China-Based
Companies issued
 December 2021 and July 2023. Please confirm that your revised disclosure
will address
 all of the applicable disclosures in each of the 15 comments in the
letter. In this regard,
 we understand that you do not have a VIE structure so those disclosures
will not apply.
Form 10-Q for the Quarterly Period Ended September 30, 2025
Condensed Consolidated Financial Statements
Note 11 - Acquisition of Business under Common Control, page 21

4. We note your response to prior comment 8. As previously requested,
please describe, in
 detail, the relationship between and ownership in the entities involved
in the transaction
 before and after the acquisition of Gongfa that supports the common
control
 determination for accounting purposes. Refer to ASC 805-50-15-6. Also,
your
 disclosures and response indicate that the company is still evaluating
the transaction and
 its accounting. As this transaction was completed more than a year ago,
please explain to
 us how you have not yet determined the appropriate accounting.

 Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Timothy Lam
</TEXT>
</DOCUMENT>