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 Kuber Resources Corp.

 1113, Tower 2, Lippo Centre

 89 Queensway, Admiralty, Hong Kong

 January 22, 2026

 Securities and Exchange Commission

 Division of Corporation Finance,

 Office of Technology

 Attn: Chen Chen or Christine Dietz

 100 F Street N.E.

 Washington, D.C. 20549

 Re:
 Kuber Resources Corp.

 Form 10-K for the year ended December 31, 2024, and
 Form 10-Q for the Quarterly Period Ended September 30, 2025,
 File No. 000-26119

 Dear Ms. Chen or Ms. Dietz,

 Kuber Resources Corp., a Nevada corporation (the
"Company"), has received and reviewed your letter dated December 15, 2025 ("Staff's Letter"), pertaining
to the Company's Form 10-K for the fiscal year ended December 31, 2024 as filed with the Securities & Exchange Commission (the
"Commission") on April 15, 2025 (the "10-K") and Form 10-Q for the quarterly period ended September 30, 2025 filed
with the Commission on November 19, 2025 (the "10-Q").

 We understand from the Staff that the Company
should not file any amendments until the Staff has reviewed the Company's proposed revisions. Accordingly, this response letter
describes the changes the Company proposes to make to its disclosures in response to the Staff's comments.

 For clarity and consistency across the Company's
filings, we reiterate that on January 14, 2025, the Company, through Kuber Resources (Guangdong) Co., Ltd. ("Kuber Guangdong"),
completed the acquisition of Gongfa Materials (Guangdong) New Materials Technology Co., Limited ("Gongfa"), a PRC-based manufacturer
of engineered wood products. As a result of the transaction, Gongfa became a wholly owned subsidiary of Kuber Guangdong. Under the terms
of the Acquisition Agreement, Kuber Guangdong acquired 100% of the issued and outstanding equity interests of Gongfa in exchange for the
issuance of 24,994,381 shares of the Company's common stock, valued at approximately US$130 million based on an agreed price of
US$4.80 per share, representing approximately 20% of the Company's total outstanding shares as of December 31, 2024.

 For convenience of reference, each comment contained
in the Staff's Letter is reprinted below, numbered to correspond with the paragraph numbers assigned in the Staff's Letter,
and is followed by the corresponding response of the Company.

 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)).

 Response.

 The Company proposes to revise Footnote 2 (Segment
Reporting) in future filings to include the following disclosure:

 Segment Reporting

 ASC 280, Segment Reporting, establishes
standards for reporting information about operating segments based on the manner in which management organizes the business and evaluates
financial performance. Operating segments are components of an enterprise for which discrete financial information is available and regularly
reviewed by the chief operating decision maker ("CODM") to allocate resources and assess performance.

 The Company has identified its Chief
Executive Officer as the CODM. The CODM reviews the Company's results only on a consolidated basis and uses net income as the segment
measure of profit or loss in evaluating performance and making decisions regarding the allocation of resources. As the Company operates
as a single reportable segment, net income represents the reported segment profit or loss.

 In addition to net income, the CODM
is regularly provided with consolidated revenue and the following significant expense categories, all of which are included in the determination
of net income: cost of revenue, research and development, sales and marketing, and general and administrative expenses. Other items included
in the segment measure that are reviewed by the CODM include depreciation and amortization, interest income and expense, and income tax
expense.

 The CODM does not receive or review
discrete financial information by product line, service offering, or geographic region, and such information is not used in assessing
performance or allocating resources. Accordingly, the Company has one operating segment, which is also its single reportable segment.

 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.

 Response.
The Company proposes to revise Footnote 14(c) in future filings and add a VAT policy disclosure to Footnote 2 in future filings as follows:

 Unissued VAT Invoices

 Sales of the Company's products in
the People's Republic of China ("PRC") are subject to value-added tax ("VAT") at a rate of 6% of the gross sales price
or at a rate approved by local tax authorities. The Company accounts for VAT on a net basis, and amounts collected on behalf of tax authorities
are excluded from revenue. Output VAT may be offset by VAT paid on purchase of raw materials included in the cost of producing the finished
goods sold. VAT payable is recorded in accrued liabilities, and VAT recoverable on qualifying purchases is recorded in other current assets.

 Revenue is recognized upon the transfer
of control of goods to customers in accordance with ASC 606 and is not contingent upon the issuance of VAT invoices. Accordingly, the
VAT invoicing process does not impact the timing or amount of revenue recognized in the Consolidated Statements of Income.

 The Company's subsidiary "Kuber
Guangdong" was incorporated on October 17, 2023 and is therefore considered a newly established company under PRC tax regulations.
As a result, local tax authorities impose limitations on the amount of VAT invoices that may be issued during a specified period. Due
to these limitations, the Company was unable to issue VAT invoices for all sales during the year ended December 31, 2024.

 As of December 31, 2024, the Company
had issued VAT invoices for gross sales totaling $375,582. The remaining $3,452,729 represents gross sales amounts, excluding VAT, for
which VAT invoices had not yet been issued. The Company has submitted an application to the local tax authorities to increase its allowable
VAT invoice issuance limit and is awaiting approval. Upon approval, the Company expects to issue the outstanding VAT invoices.

 Failure to issue VAT invoices within
the prescribed timeframe may subject the Company to administrative requirements, including additional filings, payments, or monetary penalties
imposed by local tax authorities. As of December 31, 2024, the Company has not received any notices, penalties, or enforcement actions
related to this matter.

 Value-Added Tax

 Sales of the Company's products
in the PRC are subject to VAT at rates prescribed by PRC tax laws and regulations or as approved by local tax authorities. The Company
accounts for VAT on a net basis. Accordingly, amounts collected from customers on behalf of tax authorities are excluded from revenue.

 Input VAT incurred on the purchase
of raw materials and other qualifying goods and services used in the production of finished goods is recoverable and may be offset against
output VAT. VAT payable is recorded in accrued liabilities, while recoverable VAT is recorded in other current assets in the consolidated
balance sheets.

 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.

 Response.
The Company proposes to add, in the forepart of future filings, tailored disclosures responsive to the Division of Corporation Finance's
Sample Letter to China-Based Companies (December 2021), including as applicable to the Company:

 1. A statement in the forepart disclosing clearly that the Company is not a Chinese or Hong Kong operating
company but a U.S. holding company incorporated in the State of Nevada as a holding company with no material operations of its own; and
that the Company conducts a substantial majority of its operations through its wholly owned operating entities established in the PRC
and in Hong Kong, and not through a VIE structure.

 We will include risks to our operations,
investors and shareholders, including, but not limited to the impact any necessary PRC permissions that our PRC based wholly owned subsidiaries
may need to operate their business.

 2. We will include a prominent disclosure about the legal and operational risks associated with having the
majority of the Company's operations in the PRC and Hong Kong, including the significant regulatory, liquidity, and enforcement
risks faced by our Company and our operating subsidiaries. We will disclose and discuss risks arising from the legal system in the PRC,
including risks and uncertainties regarding the enforcement of laws, and that rules and regulations in the PRC can change quickly with
little advance notice; and the risk that the Chinese government may intervene or influence our wholly owned subsidiaries operations at
any time, which could result in a material change in their operations and in the value of our securities.

 We will include the following risk factors
specifically:

 " All of the risk factors disclosed
below that apply to our Company because the majority of our operations are based in the PRC, also apply to our subsidiary operating in
Hong Kong. "

 " We conduct part of our business
through wholly owned subsidiaries based in mainland China and Hong Kong. Our operations in China are governed by PRC laws and regulations.
Our PRC subsidiaries are generally subject to laws and regulations applicable to foreign investment in China and, in particular, laws
applicable to wholly foreign-owned enterprises. The PRC government has significant oversight over the conduct of the business, and may
intervene or influence in the operations of our subsidiaries based in mainland China and Hong Kong at any time, which could result in
a material adverse change in their operations and/or the value of our shares ."

 " Uncertainties with respect
to the legal system in the PRC could adversely affect us and our Hong Kong based subsidiaries . Risks and uncertainties arising
from the PRC legal system, including risks and uncertainties regarding the enforcement of laws and the fact that rules and regulations
in the PRC can change quickly with no or little advance notice, could result in a material adverse change in the operations of our wholly
owned subsidiaries based in the PRC and Hong Kong and in the value of our shares .

 For example, China enacted its amended
Company Law, which came into effect on July 1, 2024. The new regulations have profound implications for companies incorporated in China,
such as the five-year capital contribution timeframe for shareholders of limited liability companies to make their capital contributions
in full. In response to these changes, we may need to devote significant efforts and resources to adapt and conform our PRC corporate
practices to the new regulatory framework. Moreover, because these laws, regulations, and standards are subject to interpretations, their
application in practice may evolve over time as new guidance becomes available. This evolution may result in continued uncertainty regarding
compliance matters and additional costs incurred by ongoing revisions to our disclosure and governance practices. If we fail to address
and comply with these regulations and any subsequent changes, we may be subject to penalties and our businesses in the PRC may be harmed ."

 3. We have disclosed in our Form 10-K for the Fiscal Year Ended December 31, 2024, page 14 under the Section
titled "Licenses, Permits and Government Regulations" the permissions or approvals that our subsidiaries operating in the
PRC and Hong Kong are required to obtain from Chinese authorities to conduct their businesses as currently being conducted. We will review
and asses if additional disclosures on requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration
of China (CAC) or any other governmental agency are required. We will also include a disclosure about the implications to our investors
and shareholders of our PRC and Hong Kong based operating subsidiaries (i) not receiving or maintaining such permissions or approvals,
(ii) inadvertently concluding that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change which may require our operating subsidiaries in the PRC and Hong Kong to obtain such permissions or approvals in the future.

 4. We will add a description of our flow of funds or cash management policy, including a description of cash
transfers, dividends, and distributions made by the Company or any of our subsidiaries and any limitations on such transfers, dividends,
and distributions under the laws of the PRC and Hong Kong affecting transfers, dividends, and distributions paid by our wholly owned subsidiaries
to our Company, and related risk factors.

 We will include the
following risk factor following the description of our flow of funds or cash management policy.

 " Restrictions
on currency exchange may limit our ability to receive and use our revenues effectively.

 Because our revenues are denominated
in RMB, any restrictions on currency exchange may limit our ability to use RMB-denominated revenues to make dividend payments in U.S.
dollars. The principal PRC regulation governing foreign currency exchange is the Regulations on Administration of Foreign Exchange, as
amended. Under these regulations, RMB is freely convertible for trade- and service-related foreign exchange transactions, but not for
direct investment, loan or investment in securities outside China unless prior approval of the State Administration of Foreign Exchange
is obtained. Although the PRC regulations now allow greater convertibility of RMB for current account transactions, restrictions and limitations
remain. We cannot be certain that the PRC regulatory authorities will not impose more stringent restrictions on the convertibility of
RMB, especially with respect to foreign exchange transactions. The PRC government may also, at its discretion, restrict access in the
future to foreign currencies for current account transactions. If further restrictions prevent us from obtaining sufficient foreign currencies
to satisfy our foreign currency demands, we may not be able to pay dividends in foreign currencies to our shareholders. As a result, the
funds in our PRC subsidiaries may not be available to fund operations or for other uses outside of China due to i