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CHINA TELETCH HOLDING, INC.

16th Floor, North Tower

528 Pudong South Road

Shanghai 200120

China

October 16, 2024

Mr. Uwem Bassey

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    China Teletech Holding, Inc.

    Registration Statement on Form 10-12G

    Filed August 27, 2024

    File No. 000-56680

Dear Mr.Bassey:

Set forth below are the responses of China Teletech
Holding, Inc., a Florida corporation (“CNCT” “we,” “us,”
“our” or the “Company”), to the comments received from you, the Division of Corporation
Finance of the U.S. Securities and Exchange Commission (the “SEC”) by emailed letter, dated September 24,
2024, with respect to (i) our Registration Statement on Form 10-12G filed on August 27, 2024. The responses provided below
are numbered to correspond to your comments, which have been reproduced and emboldened herein for ease of reference.

Registration Statement on Form 10-12G

Cover Page

1. We
note that you have a dual class capital structure whereby Series A Preferred Share has the voting power of 1,000 common shares and it
appears Mr. Yang, Kung-Fu will have majority voting control of the company through his control of World Capital Holding, Ltd. Please
revise your cover page to discuss the dual class nature of your capital structure and quantify the voting control that Messrs. Yan Ping
Shen and Yang, Kung-Fu have. In addition, revise your disclosure here and throughout the filing, including the cover page, to detail
the dilutive effect of the Series A Preferred Shares and the controlling impact of the Series A Preferred Shares. In addition, explain
in greater detail your capital structure, and the nature of the disparate voting rights.

Response:

The following language was inserted on the Cover Page and Risks
Related to Our Shareholders and Shares of Common Stock:

Our directors and executive officers are among our largest stockholders,
they can exert significant control over our business and affairs and have actual or potential interests that may depart from those of
investors.

Our sole executive officer and director, Yan Ping, Sheng, along with
Yang, Kung Fu own a significant percentage of shares of our outstanding capital stock through their company, World Capital Holding, Ltd.
As of the date of this prospectus, our executive officer and director and their respective affiliates beneficially own 100% of the outstanding
voting stock for our Preferred A shares and, converted into Common shares, the affiliates own approximately 95% of the outstanding voting
stock.

As a result, our sole office and director,
and controlling shareholder, can determine the outcome of any actions taken by us that require stockholder approval. For example, she
will be able to elect all our directors, control the policies and practices of the Company and control the outcome of any proposed business
combination.

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This concentration of ownership may have the effect of impeding a merger,
consolidation, takeover or other business consolidation, or discouraging a potential acquirer from making a tender offer for our common
stock, which in turn could reduce the price of the shares of our common stock price or prevent our stockholders from realizing a premium
over the price of our common stock. Investing in our stock is risky and investors could lose their entire investment.

Ownership is set forth in section entitled “Security
Ownership of Certain Beneficial Owners and Management” starting on page 17.

Common Stock

All outstanding shares of Common Stock are of the same class and have
equal rights and attributes. The holders of Common Stock are entitled to one vote per share on all matter submitted to a vote of stockholders
of the Company. All stockholders are entitled to share equally dividends, if any, as may be declared from time to time by the Board of
Directors out of funds legally available. In the event of liquidation, the holders of Common Stock are entitled to share ratably in all
assets remaining after payment of all liabilities. The stockholders do not have cumulative or preemptive rights.

Preferred Stock

Each share of Convertible Series A Preferred Stock shall be convertible,
at the option of the holder, into 1,000 fully paid and non-assessable shares of the Company’s Common Stock. In addition, holders
of the Convertible Series A Preferred Stock shall be entitled to vote on any, and all, matters considered and voted upon by the Company’s
Common Stock. The holder is entitled to 1,000 Common Share votes for every 1 share of Convertible Series A Preferred Stock. Detailed risk
factors discussing the disparate voting rights of the Preferred Shares and Common Shares and the associated risks to investors are set
forth in section entitled “Risk Factors” on page 6 and “Description
of Capital Stock” on page 13.

Our Preferred A shareholder has over 95% of the
voting shares and will carry the necessary votes to determine the outcome for all the above-mentioned actions. In addition, conversion
of the Convertible Series A Preferred Stock will result in dilution of the value of the common shares and decrease in ownership for current
shareholders of the class of Common stock. As a result, the Company’s shareholders are at risk of losing a significant amount of
their investment value.

Liquidity and Capital Resources, page 15

2. Please
disclose the amount of capital resources needed to fund your planned operations for the next twelve months. To the extent you do not
currently have sufficient capital, please describe the level of operations that you will be able to perform with your existing capital
resources and liquidity.

Response:

The following language was inserted:

Burn Rate

The amount of capital resources needed to fund our planned operations
for the next twelve months will be a minimum of $25,000 to maintain websites, email campaigns, marketing materials, and general administration
expenses. Our monthly burn rate is approximately $2,000.  Currently we do not have sufficient capital to fund our operations and
will need to obtain additional funding. At this time, our majority shareholder, World Capital Holding, Ltd will fund our operations.

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Security Ownership of Certain Beneficial Owners and Management,
page 17

3. Please
revise your beneficial ownership table to add a column that includes the aggregate voting power held by each person or entity identified.

Response:

The following language was inserted:

    Name and Address of Beneficial Owner
    Amount and

 Nature of

 Beneficial Ownership

    Percentage

 of Class

    Aggregate Voting Power

    World Capital Holding, Ltd. (1)(2)

 16th Floor, North Tower

 528 Pudong South Road

 Shanghai, China 200120

    1,500,000 Preferred A Shares
200,000,000
    100%
47%
    95.09%

    Li Yankuan
Room A1/F, Yue Fat Building
87/91 Tai Po Road
Kowloon, HK
    21,419,394
    5%
    .01%

Directors and Executives Officers, page 18

4. We
note the CEO is involved as the CEO of three other companies – World Financial Holding Group (USA), Shanghai Capital Holding Co.,
Ltd and Shanghai Qifan Enterprise Management Co., Ltd. Please revise to discuss any potential conflicts of interest and how much time
per week the CEO is involved in the management of China Teletech Holding, Inc.

Response:

The following language was inserted:

Mr. Sheng is involved with several companies.
There is potential conflict when managing multiple companies:

    ·
    Finding a suitable merger candidate or developing a business;

    ·
    Continuing to fund these companies by paying transfer agent fees, audit and accounting fees, and attorney fees;

    ·
    Time management;

    ·
    Maintaining regulatory compliance that segregate the companies;

    ·
     World Capital Holding Ltd. is majority shareholder and the potential for engaging in biased business practices increases;

    Clearly defined roles and responsibilities.

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Report of Independent Registered Public Accounting Firm, page
F-11

5. We
note that your audit firm identified material weaknesses in internal control over financial reporting that are communicated as critical
audit matters. Please provide us with the basis for the audit firm’s determination that the material weaknesses meet the definition
of critical audit matters. That is, explain how the matters relate to accounts or disclosures that are material to the financial statements
and whether auditing those affected account balances and disclosures involved especially challenging, subjective, or complex auditor
judgment. Refer to PCAOB AS 3101. In addition, please revise to include an audit opinion that complies with the guidance in paragraph
14 of PCAOB AS 3101 regarding the communication of critical audit matters.

Response:

The revised audit opinion was inserted in the Form 10 with the following
language that replaced the former:

No matters identified in the audit were considered
to be critical audit matters.

General

6. You
appear to be a shell company as that term is defined in Securities Act Rule 405 of Regulation C. In this regard, we note that you have
nominal operations and no or nominal assets to date. Please disclose prominently in the Business section that you are a shell company
and add disclosure highlighting the consequences of your shell company status. Discuss the prohibition on the use of Form S-8 by shell
companies, enhanced reporting requirements imposed on shell companies, and the conditions that must be satisfied before restricted and
control securities may be resold in reliance on Rule 144. Revise throughout as appropriate for consistency. In addition, we note your
disclosure that your stated business purpose "includes a merger [with] a target company in the food industry business" but
also note your disclosure indicating you do not believe you are a blank check company. Please disclose that you are a "blank check"
company under paragraph (a)(2) of Rule 419 of the Securities Act, and provide disclosure regarding your status as a blank check company
and in an appropriate place in your filing, provide details regarding compliance with Rule 419 in connection with any offering of your
securities. In the alternative, provide us with a detailed analysis regarding why you do not believe you are a "blank check"
company pursuant to paragraph (a)(2) of Rule 419 of the Securities Act.

Response:

We revised the language throughout our filing to disclose that we are
a blank check company.

The following language was inserted into the Business section and
Risk Factors:

Shell Companies

CNCT is a shell company under the Securities Act Rule 405 of Regulation
C

The term shell company means
a registrant, other than an asset-backed issuer as defined in Item 1101(b) of Regulation AB (§ 229.1101(b) that has:

 (1) No or nominal operations; and

 (2) Either:

 (i) No or nominal assets;

 (ii) Assets consisting solely of cash and cash equivalents; or

 (iii) Assets consisting of any amount of cash and cash equivalents and nominal other assets.

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Prohibition of the Use of S-8 and Reporting
Requirements for Shell Companies

The rules and rule amendments prohibit the use
of Form S-8 under the Securities Act of 1933 by shell companies. In addition, they require a shell company that is reporting an event
that causes it to cease being a shell company to disclose the same type of information that it would be required to provide in registering
a class of securities under the Securities Exchange Act of 1934.

Rule 145 under the Securities Act of 1933 provides
that any direct or indirect business combination of a reporting shell company (that is not a business combination related shell company)
involving another entity that is not a shell company is deemed to involve a sale of securities to the reporting shell company’s
shareholders. Where Rule 145a applies, that sale will need to be registered under the Securities Act, unless there is an applicable exemption.

In addition, new Rule 15-01 of Regulation S-X
provides for new financial statement requirements applicable to acquisitions involving shell companies (other than business combination
related shell companies). The Commission also adopted several amendments to existing Regulation S-X provisions. This rule aligns the age
requirements for financial statements for each business involved in a business combination with a shell company

Resale of Securities Under Rule 144

Rule 144(i) explicitly states that a shell company,
including a SPAC, cannot use Rule 144 to resell restricted securities until it has fully transitioned away from its shell status and filed
the required information with the SEC. To comply, the former shell company must file information equivalent to a Form 10, which details
its operations and financial status as a non-shell entity. After ceasing to be a shell company, there is typically a one-year waiting
period before restricted securities can be sold under Rule 144. Even after the one-year period, the company must continue to comply with
SEC reporting requirements to maintain eligibility for Rule 144.

Offering securities pursuant to a registration
statement under the Rule 419 of the Securities Act of 1933

In the event that we offer securities pursuant
to a registration statement under the Securities Act, such offering will be subject to the provisions of Rule 419 of the Securities Act
of 1933. Rule 419 applies to blank check companies and requires that the net offering proceeds, and all securities to be issued (and those
sold by a selling shareholder upon their sale) be promptly deposited by the company into an escrow or trust account pending the execution
of an agreement for an acquisition or merger.

In addition, the registrant is required to file
a post-effective amendment to the registration statement containing the same information as found in a Form 10 registration statement,
upon the execution of an agreement for such acquisition or merger. The rule provides procedures for the release of the offering funds
in conjunction with the post effective acquisition or merger. The obligation to file post-effective amendments are in addition to the
obligation to file Forms 8-K to report both the entry into a material non-ordinary course agreement and the completion of the transaction.

Under Rule 419, the funds and securities will
be released by the to the company and to investors, respectively, only after the company has met the following three conditions: first,
the company must execute an agreement for an acquisition; second, the Company must successfully complete a reconfirmation offering which
is reconfirmed by sufficient investors so that the remaining funds are adequate to allow the acquisition to be consummated; and third,
the acquisition meeting the above criteria must be consummated.

If a consummated acquisition meeting the requirements
of this section has not occurred by a date 18 months after the effective date of the initial registration statement, funds held in the
escrow or trust account shall be returned by first class mail or equally prompt means to the purchaser within five business days following
that date.

As of this draft, we plan to issue preferred shares
in an acquisition or merger and plan to rely on an exemption from Rule 419. Section 4(a)(2) of the Securities Act of 1933 exempts from
registration "transactions by an issuer not involving any public offering." It is section 4(a)(2) that permits an issuer to
sell securities in a "private placement" without registration under the Act of ’33.

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As a blank check company, our shareholders
may face significant restrictions on the resale of our Common Stock due to state "blue sky" laws and due to the applicability
of Rule 419 adopted by the Securities and Exchange Commission

The resale of Common Stock must meet the blue-sky
resale requirements in