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September 21, 2023
Min Jiang
Chief Executive Officer
SIPP International Industries, Inc.
69 Waterfall Blvd, The Ponds
Sydney, NSW 2769, Australia
Re:SIPP International Industries, Inc.
Amendment No. 4 to Registration Statement on Form S-1
Filed September 6, 2023
File No. 333-271830
Dear Min Jiang:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 28, 2023 letter.
Amendment No. 4 to Registration Statement on Form S-1 filed September 6, 2023
Cover Page
1.We note the disclosure throughout your prospectus about the Trial Measures and Articles
and that you indicate that you are not required to obtain approval or clearance from the
CSRC.  Please revise your disclosure to clarify whether you are relying on an opinion of
counsel in determining that you are not required to obtain approval or clearance from the
CSRC and, if so, identify counsel and file its consent.  Please make similar revisions
elsewhere that you discuss approval by the CSRC, such as your risk factors and cover
page.
2.We note the disclosure throughout your prospectus that "The Company is of the belief that
the expenses of engaging PRC counsel would be unduly burdensome on the Company,

 FirstName LastNameMin Jiang
 Comapany NameSIPP International Industries, Inc.
 September 21, 2023 Page 2
 FirstName LastName
Min Jiang
SIPP International Industries, Inc.
September 21, 2023
Page 2
and thus, the Company has not sought to engage PRC counsel to obtain an additional
opinion pertaining to the Company’s understanding of all required approvals and
permission to operate [y]our business."  If true, please revise to disclose that your
determination not to obtain the advice of counsel is based on a risk-based analysis and
include a related risk factor disclosure. Please revise to explicitly address the
consequences to your investors specifically if you do not receive or maintain the necessary
permissions or approvals, inadvertently conclude that such permissions or approvals are
not required or applicable laws, regulations or interpretations change and you are required
to obtain such permissions in the future.
Exhibits
3.We note your response to prior comment 6 and reissue the comment. In this regard, we
note that Exhibit 3.3 is still not a single complete copy of your articles.  As required by
Item 601(b)(3) of Regulation S-K, please file a complete copy of your Articles and
Incorporation and bylaws as amended to date.

General
4.It appears that you revised the disclosure in the fifth paragraph on page 58 in response to
the last bullet point of prior comment 7. However, the disclosure in the sixth paragraph on
page 24 about material weaknesses is still not consistent with the disclosure in the fourth
paragraph on page 58 about material weaknesses.  Please advise or revise accordingly.
            You may contact Eiko Yaoita Pyles at 202-551-3587 or Ernest Greene at 202-551-3733 if
you have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Geoff Kruczek at 202-551-3641 with any other
questions.

Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Matthew McMurdo