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    SIPP
    International Industries, Inc.
    50
West Liberty Street

                                                                                          Suite 880

    Reno,
    NV 89501

August 17,
2023

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

 Attention: Eiko
Yaoita Pyles

Ernest
Greene

Thomas
Jones

Geoff
Kruczek

 Re: SIPP
International Industries, Inc.

Amendment
No. 2 to Registration Statement on Form S-1

Filed
July 19, 2023

File
No. 333-271830

Dear
Sir or Madam:

SIPP
International Industries, Inc. (the “Company”) is filing amendment number 3 (the “Amendment”) to the Registration
Statement on Form S-1/A (the “Registration Statement”) in response to your recent review letter addressed to Min Jiang, Chief
Executive Officer of the Company, dated August 7, 2023 (the “SEC Letter”). This response letter, along with the amended
Offering Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in
the SEC Letter.

Amendment
No. 2 to Registration Statement on Form S-1 filed July 19, 2023

Cover
Page

1.
We note the repetitive new disclosures on the cover page, such as the disclosure about: (1) “it is uncertain when the Administration
Provision and the Measures will take effect or if they will take effect as currently drafted;” and (2) the “translated copy
of the current and effective regulations.” Please avoid the repetition of such disclosure on the cover page and clarify the status
and effect of the “currently drafted” Administration Provision and Measures.

We
have removed repetitive disclosure where appropriate.

2.
We note the disclosure on the cover page and elsewhere in your prospectus about your beliefs concerning authorizations and approvals,
such as “[t]he Company does not believe that it is required to seek authorizations from Chinese authorities” and that “[w]e
believe that we are not currently required to obtain approval from Chinese authorities” and the disclosure on page 14 that “[t]he
Material PRC Company has obtained all material Governmental authorizations necessary for its business as described in the Prospectus.”
Please reconcile such disclosure with the disclosure in the: (1) penultimate paragraph on page 29 that “[b]ased on our understanding
of the Chinese laws and regulations in effect at the time of this prospectus, we may be required to submit an application to the CSRC
for its approval of this offering;” (2) first paragraph on page 30 that “[a]s such, we will likely be required to file with the
CSRC within a reasonable time and before the consummation of this offering; and (3) last sentence on page 31 that “[p]ursuant to
... if the registration statement with respect to the Common stock to be sold in this offering does not become effective on a date, as
the Securities and Exchange Commission may determine, prior to the effectuation of the Trial Administrative Measures, or we fail to complete
this offering and listing on the Nasdaq Capital Market before September 30, 2023, we will have to file with the CSRC in accordance
with the Trial Administrative Measures with respect to this offering.” As requested in comment 8 of our June 6, 2023 letter,
disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business
and to offer the securities being registered to foreign investors. State whether you or your subsidiaries are covered by permissions
requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental
agency that is required to approve your or your subsidiaries’ operations, and state affirmatively whether you have received all
requisite permissions or approvals and whether any permissions or approvals have been denied. If you relied on the advice of counsel
in making these determinations, please identify counsel and file their consent. If you did not consult counsel in making these determinations,
please explain why you did not obtain the advice of counsel. Please also describe the consequences to you and your investors if you or
your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or
approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions
or approvals in the future.

We
have added disclosure about CAC and CSRC approval, as well as the reasons for not relying on local counsel’s opinion.

    2

3.
If you continue to disclose on the cover page and on page 6 about the translated copy of the current and effective regulations promulgated
by the CSRC, the disclosure that the company “does not believe that this offering is contingent upon receipt of approval from the
CSRC” and the company “does not believe that it is required to seek authorizations from Chinese authorities,” then
expand the disclosure about your beliefs to specifically address whether you considered that the WFOE is an operating subsidiary in China.
If you relied on the advice of counsel, revise to identify counsel. If you did not rely on advice of counsel, explain why you did not
rely on advice of counsel.

We
have added disclosure regarding the need for CSRC approval and why we did not rely on the advice of counsel.

4.
If you continue to include disclosure in your amendment that now appears on page 14 and elsewhere that, “[b]ased on our understanding
of the explicit provisions under PRC Laws:” (1) elaborate upon your “understanding” and the basis for your conclusions;
and (2) clarify whether your understanding is limited to the “explicit” provisions under PRC Laws, and if so, why it is appropriate
to limit your basis to your understanding of such “explicit” provisions.

We
have removed the applicable disclosure from the Amendment.

5.
We note your disclosure on page 14 and elsewhere that “[s]ubject to any applicable administrative procedures required by PRC Laws,
and provided that all required Governmental Authorizations have been duly obtained, the due application of the net proceeds to be received
by the Company from the issue Common Shares as disclosed in the Prospectus under the caption “Use of Proceeds” does not and
immediately after the Offering will not contravene any applicable PRC Laws, the articles of association or the business licenses of the
Material PRC Company, except for such contravention or default which would not be reasonably expected to have a Material Adverse Effect.”
Please delete these qualifications and exceptions.

We
have deleted all qualifications and exceptions.

6.
We note your disclosure that “[t]he WFOE structure is not as stable as some have imagined,” that “[t]he senior
management and the shareholders of the domestic company play a very important role in the WFOE structure,” and that
“[o]nce there are changes to such positions involving interests, potential risks of the WFOE structure will appear.”
Elaborate upon what you mean by “as some have imagined” or alternatively remove such disclosure and provide more
detailed and clear disclosure regarding the risks facing the company as a result of your holding company structure. In addition,
clarify what types of changes may cause certain risks to appear, and include a more detailed discussion of such “potential
risks.” In the alternative, to the extent that the risks related to your holding company structure are already discussed,
remove such disclosure regarding “changes to such positions involving interests . . . .”

We
have removed the applicable disclosure.

    3

7.
We note your response to prior comment 5 with respect to your disclosure regarding risks related to doing business in China. Please continue
to ensure that your disclosure does not suggest there are mitigating factors regarding the nature of your relationship with the Chinese
government, the manner in which you are regulated, or the degree to which your operations could be affected by economic, industrial,
or other policies in China. For example, we note you continue to disclose: (1) on the cover page that “[t]here are specific risks
related to having operations in China that the Company has been organized to avoid;” (2) on the cover page that “[t]he overall
effect has been to significantly enhance the protections afforded to various forms of foreign investments in China;” and (3) on
the pages 3, 5, and 13 that “based on our current structure, these risks remain immaterial, regardless of the recent statements
and regulatory actions by China’s government.”

We
have removed all mitigating language from the Amendment.

Certain
Risks and Limitations Related to Doing Business in China, page 7

8.
We note your response to prior comment 6 and the Certain Risks and Limitations Related to Doing Business in China section beginning on
page 7. Please revise the prospectus summary to include a summary of risk factors that discloses the risks that your corporate structure
and being based in or having the majority of the company’s operations poses to investors. For each of the risks discussed in the
bullet points in the summary of risk factors, include specific cross-references for each risk to the more detailed discussion of each
of these risks in the prospectus. Also, include in the summary of risk factors the risk concerning your auditor is among those listed
by the PCAOB Mainland China Determination. In this regard, we note the disclosure in the risk factor on pages 40-41.

We
have included additional risk factor summaries and cross references to the cover page and summary, including that our auditor is among
those listed by the PCAOB Mainland China Determination.

Risk
Factors, page 16

9.
Please include risk factors to highlight the following:

 ● the
risks concerning the offering is being conducted on a best-efforts, no minimum basis with no arrangements for funds to be placed in an
escrow, trust or similar account. For example, disclose that you may complete the offering even if only a small portion of the total
offering is raised and that amount may be substantially less than the total maximum offering amount. Also, disclose what may happen to
investor funds not placed in escrow pending closing with respect to that investor if you are voluntarily or involuntarily placed into
bankruptcy or receivership prior to that closing;

    4

 ● the
difference between the price per share of the shares of common stock offered in this offering compared to the price per share incurred
by Min Jiang to acquire the shares disclosed in the table on page 70. In this regard, we note the disclosure on page 48 that “[w]e
are offering our common stock at a price per share that is significantly more than the price per share paid by our current stockholders
for our common stock;”

 ● that
there is substantial doubt about the company’s ability to continue as a going concern. In this regard, we note the disclosure on
page 53 and in the financial statements, such as on page F-2; and

 ● the
anti-takeover effects that may be caused by your disparate voting rights. In this regard, we note the disclosure on page 72 about the
voting rights of the Series A Preferred Stock.

We
have added the applicable Risk Factors.

Directors
and Executive Officers, page 66

10.
We note your response to prior comment 14. Please tell us the size of the operations that you disclose your directors and officers supervise,
if the disclosed entity does not file periodic reports with the Commission. In this regard, it remains unclear whether additional disclosure
is required in your amendment to comply with the last sentence of Item 401(e) of Regulation S-K.

The
applicable officer and director has resigned.

Certain
Relationships and Related Transactions, page 71

11.
We note your response to prior comment 15. Please disclose the principle followed in determining to issue 100 million shares of common
stock of the company to acquire the assets of CIHL, disclose the identity of the persons making the determination and their relationship
with the company. If the assets were acquired by CIHL within two years prior to their transfer to the company, also state the cost thereof
to CIHL.

We
have added disclosure regarding the decision to issue 100M shares to acquire CHIL and the decision maker. As stated in the Amendment,
the assets acquired were recorded based on their historical cost, and the excess paid over the parent’s basis of the net assets
acquired was recorded to equity.

Plan
of Distribution, page 75

    5

12.
We note the disclosure in this section that the company “will sell the shares in this offering exclusively through [y]our officers
and directors, Min Jiang and Zonghan Wu. Tell us, with specificity, the steps that you have taken to determine that your officers and
directors have not participated in selling and offering securities for any issuer more than once every 12 months. In this regard, we
note the disclosure about best-efforts offerings by SSHT S&T Group Ltd. and Alpine Auto Brokers, Inc. in their recent filings with
the SEC. Also tell us, with a view to disclosure, why the disclosure in this section does not mention the assumption disclosed on page
5 and elsewhere in your prospectus about “Assuming no offer, issuance or sale of the Common Shares has been or will be made directly
or indirectly within the PRC.” In addition, revise the disclosure on the cover page and in this section and elsewhere, as appropriate,
to clarify that you are not offering, issuing or selling common shares within the PRC, if true, as opposed to assuming that you are not
offering, issuing or selling common shares in the PRC.

As
noted in the Amendment, Zonghan Wu has resigned as an officer and director and will not be involved in the offering. He will merely act
as an advisor and translator. The assumption has been removed from the Amendment. The Amendment clarifies that no offer, issuance or
sale of shares will be made in the PRC.

Exhibits

13.
We reissue prior comment 21. Exhibit 3.3 is still not a single complete copy of your articles. Instead, it appears to still be a collection
of multiple documents.

We
have added a single, updated copy of the amended and restated articles.

General

14.
We note your response to prior comment 23. Please continue to ensure that the disclosure throughout your filing is consistent and applicable
to you. For example, we note that you: (1) continue to refer on page 46 to proceeds of $1,350,000, but you refer on page 48 to proceeds
of $1,150,000; and (2) continue to disclose on page 47 that your “offering price of $0.01 per share was arbitrarily determined
based upon a discount to the current market price.” However, you disclose on page 48 that “[w]e are offering our common stock
at a price per share that is significantly more than ... the current market price of our common stock;” As further examples, we
note the following:

 ● the
disclosure on the cover page about “intends to rely on dividends” and “has made no such distributions to date”
is not consistent with disclosure elsewhere in the prospectus, such as the disclosure in the last paragraph on page 14 and the disclosure
in the first risk factor on page 22 that “[w]e rely primarily on dividends paid by WFOE for our cash needs.” In this regard,
it is unclear how you rely primarily on dividends and distributions despite having made no such distributions to date.

    6

 ● the
disclosure in the last paragraph on page 7 about “our officers or directors, many of whom are not residents in the United States”
is not consistent with the disclosure in the last paragraph on page 54 that you currently have two officers and directors;

 ● the
disclosure in the second paragraph in the last risk factor on page 22 about material weaknesses is not consisten