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CORRESP
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VIA EDGAR

August 31, 2023

Securities and Exchange Commission

Division of Corporation Finance

Disclosure Review Program

100 F Street, NE

Washington, D.C. 20549

    Re:
    Plastec Technologies,
    Ltd.

    Amendment No. 1 to Form
    20-F for the Fiscal Year Ended December 31, 2022

    File
    No. 000-53826

Ladies and Gentlemen:

Plastec Technologies, Ltd. (the “Company,”
 “we,” “our” or “us”) hereby responds as follows to the comment letter from the staff of the Securities
and Exchange Commission (the “SEC”) dated August 22, 2023, relating to the above-referenced Annual Report on Form 20-F, as
amended (“Form 20-F”). Capitalized terms used but not defined herein have the meanings ascribed to them in the Form 20-F.

Amendment No. 1 to Form 20-F
for the Fiscal Year Ended December 31, 2022

Item 16I. Disclosure Regarding
Foreign Jurisdictions that Prevent Inspections, page 46

 1. We note your statement that you reviewed your register of members and public filings made by your shareholders in connection
with your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and tell
us whether you relied upon any legal opinions or third-party certifications such as affidavits as the basis for your submission. In your
response, please provide a similarly detailed discussion of the materials reviewed and legal opinions or third-party certifications relied
upon in connection with the required disclosures under paragraphs (b)(2) and (3).

We have reviewed written affirmations from each
officer of the Company and each member of the Company’s board of directors and the boards of directors of its consolidated foreign
operating entities, certifying that such persons do not have any current or prior affiliation with the Chinese Communist Party, or the
government of the People’s Republic of China, the Cayman Islands, Hong Kong, the British Virgin Islands or any foreign jurisdiction
that the PCAOB has determined it is unable to inspect or investigate completely because of a position taken by an authority in such foreign
jurisdiction.

Based on an examination of the Company’s
audited financial statements, register of members and public filings made by its shareholders, these written affirmations collectively
represent holders of over 80% of the Company’s outstanding ordinary shares, including Kin Sun Sze-To, the Company’s Chairman
of the Board and Chief Executive Officer and Chief Operating Officer, who himself beneficially owns 78.3% of the Company’s outstanding
ordinary shares. No other person has a controlling financial interest in the Company.

Securities and Exchange Commission

August 31, 2023

Page 2

In addition to the foregoing, in determining whether
the Company should take any further steps to analyze the unaccounted for shareholder base, we took into account the fact that the Company
is a former special purpose acquisition company (SPAC) that completed its initial public offering in the U.S. and is now a non-operating
shell company. Except in connection with its business combination with Plastec, the Company has never sold shares in any jurisdiction
other than the United States. Based on the foregoing, the Company determined that no additional actions needed to be taken.

Accordingly, the Company respectfully submits that
the materials reviewed by it provide a sufficient basis for the Company’s disclosures as required under paragraphs (a) and (b)(2)
and (3).

 2. In order to clarify the scope of your review, please supplementally describe the steps you have taken to confirm that none of
the members of your board or the boards of your consolidated foreign operating entities are officials of the Chinese Communist Party.
For instance, please tell us how the board members’ current or prior memberships on, or affiliations with, committees of the Chinese
Communist Party factored into your determination. In addition, please tell us whether you have relied upon third party certifications
such as affidavits as the basis for your disclosure.

We spoke with each officer of the Company and each
member of the Company’s board of directors and the boards of directors of its consolidated foreign operating entities to confirm
that such persons do not have any current or prior affiliation with the Chinese Communist Party, the government of the People’s
Republic of China, the Cayman Islands, Hong Kong, the British Virgin Islands or any foreign jurisdiction that the PCAOB has determined
it is unable to inspect or investigate completely because of a position taken by an authority in such foreign jurisdiction. We thereafter
obtained written affirmations from such individuals confirming the foregoing information.

 3. We note that your disclosures pursuant to Item 16I(b) use terms such as “our” or “our company.” It is
unclear from the context of these disclosures whether these terms are meant to encompass you and all of your consolidated foreign operating
entities or whether in some instances these terms refer solely to Plastec Technologies, Ltd., a Cayman Islands exempted company. Please
note that Item 16I(b) requires that you provide each disclosure for yourself and your consolidated foreign operating entities, including
variable interest entities or similar structures. To clarify this matter, please provide the following information:

 · With respect to (b)(2), please supplementally clarify the jurisdictions in which your consolidated foreign operating entities
are organized or incorporated and provide the percentage of your shares or the shares of your consolidated operating entities owned by
governmental entities in each foreign jurisdiction in which you have consolidated operating entities in your supplemental response.

Securities and Exchange Commission

August 31, 2023

Page 3

 · With respect to (b)(3) and (b)(5), please provide the required information for you and all of your consolidated foreign operating
entities in your supplemental response.

With respect to the first bullet of the Staff’s
comment (relating to (b)(2)), the Company has four subsidiaries: (i) Viewmount Developments Limited, a British Virgin Islands company
(“Viewmount”); (ii) Sun Line Industrial Limited, a Hong Kong company (“Sun Line”); (iii) Sun Ngai Spraying and
Silk Print Co., Ltd., a British Virgin Islands company (“Sun Ngai”); and (iv) Sun Terrace Industries Limited, a British Virgin
Islands company (“Sun Terrace”). However, Viewmount is the only operating entity, while the other three are dormant non-operating
subsidiaries. The Company owns 100% of Viewmount, which owns 100% of each of Sun Line, Sun Ngai and Sun Terrace.

Based on our review of the Company’s audited
financial statements, register of members, public filings made by the Company’s shareholders and the written affirmations collectively
represent holders of over 80% of the Company’s outstanding ordinary shares that such persons do not have any current or prior affiliation
with the government of the People’s Republic of China, Cayman Islands, British Virgin Islands and Hong Kong, the Company does not
believe any of its outstanding ordinary shares or the shares of the Company’s consolidated operating entities are owned by governmental
entities in each foreign jurisdiction in which the Company has consolidated operating entities.

With respect to the second bullet of the Staff’s
comment (relating to (b)(3)), we will file a second amendment to the Form 20-F in the form attached hereto as Exhibit A (the “Amendment”)
and therein clarify the disclosure to state that governmental entities in the foreign jurisdictions in which the Company and its consolidated
foreign operating entities are incorporated or otherwise organized do not have a controlling financial interest in the Company nor in
the Company’s consolidated foreign operating entities.

With respect to the second bullet of the Staff’s
comment (relating to (b)(5)), we will clarify the disclosure in the Amendment to state that none of the articles of incorporation (or
equivalent organizing document) of the Company or any of its consolidated foreign operating entities contains any charter of the Chinese
Communist Party, including the text of any such charter.

Securities and Exchange Commission

August 31, 2023

Page 4

 4. We note your submission pursuant to Item 16I(a) and your disclosure pursuant to Item 16I(b)(3) address ownership or control
by “governmental entities in China.” However, we note your definition of China on page 3 of your Form 20-F distinguishes between
mainland China and Hong Kong. Please supplementally tell us the ownership by governmental entities in Hong Kong as well as mainland China.

Based on an examination of the Company’s
register of members and public filings made by its shareholders, the Company has confirmed that it is not owned or controlled by any governmental
entities in both mainland China and Hong Kong.

 5. With respect to your disclosure pursuant to Item 16I(b)(5), we note that you have included language that such disclosure is
 “to our best knowledge.” Please supplementally confirm without qualification, if true, that your articles and the articles
of your consolidated foreign operating entities do not contain wording from any charter of the Chinese Communist Party.

We have confirmed that the Company’s articles
and those of its consolidated foreign operating entities do not contain wording from any charter of the Chinese Communist Party.

*************

We
thank the Staff for its review of the foregoing and the Form 20-F. If you have any further questions or comments, please feel free to
contact our counsel, Jeffrey M. Gallant at jgallant@graubard.com or by telephone at (212) 818-8638.

    Sincerely,

    /s/ Kin Sun Sze-To

    cc:
    Graubard Miller

    Attn: Jeffrey M. Gallant, Esq.

EXHIBIT A

UNITED STATES

SECURITIES AND EXCHANGE
COMMISSION

WASHINGTON, D.C. 20549

FORM 20-F/A

(Amendment No. 2)

(Mark One)

¨ REGISTRATION STATEMENT PURSUANT TO SECTION 12(B) OR
12(G) OF THE SECURITIES EXCHANGE ACT OF 1934

OR

x ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(D) OF
THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year
ended December 31, 2022

OR

¨ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(D) OF
THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from          to

OR

¨ SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(D) OF
THE SECURITIES EXCHANGE ACT OF 1934

Date of event requiring this shell
company report

    Commission file number:
    000-53826

PLASTEC TECHNOLOGIES, LTD.

(Exact Name of Registrant
as Specified in Its Charter)

N/A

(Translation of Registrant’s
Name Into English)

Cayman
Islands

(Jurisdiction of Incorporation
or Organization)

 c/o
Unit 01, 21/F, Aitken Vanson Centre, 61 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong

(Address of Principal
Executive Offices)

Kin Sun Sze-To, Chief Executive Officer, Plastec Technologies, Ltd.
 c/o Unit 01, 21/F, Aitken Vanson Centre, 61 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong
 Tel.: 852-21917155, Fax: 852-27796001

(Name, Telephone, E-mail
and/or Facsimile Number and Address of Company Contact Person)

Securities registered or to be registered
pursuant to Section 12(b) of the Act:

    Title of Each Class

    Trading Symbol(s)

    Name of Each Exchange on Which Registered

    None

Securities registered or to be registered
pursuant to Section 12(g) of the Act:

Ordinary Share, par value U.S.$0.001 per share

(Title of Class)

Securities for which there is a reporting
obligation pursuant to Section 15(d) of the Act: None

Indicate the number of outstanding
shares of each of the Issuer’s classes of capital or common stock as of the close of the period covered by the annual
report: 12,938,128 Ordinary Shares, par value U.S.$0.001 per share, as of December 31, 2022

Indicate
by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.   Yes  ¨  No  x

If
this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13
or 15(d) of the Securities Exchange Act of 1934.    Yes  ¨  No  x

Indicate
by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities
Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports),
and (2) has been subject to such filing requirements for the past 90 days.    Yes  x  No  ¨

Indicate
by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405
of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant
was required to submit such files).    Yes  x  No  ¨

Indicate by check mark whether the registrant
is a large accelerated filer, an accelerated filer, a non-accelerated filer or an emerging growth company. See definition of “large
accelerated filer”, “accelerated filer” and “emerging growth company” in Rule 12b-2 of the Exchange
Act. (Check one):

    Large accelerated filer ¨
    Accelerated filer ¨
    Non-accelerated filer x

    Emerging growth company ¨

If an emerging
growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected
not to use the extended transition period for complying with any new or revised financial accounting standards† provided pursuant
to Section 13(a) of the Exchange Act. ¨

Indicate by
check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its
internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered
public accounting firm that prepared or issued its audit report. ¨

If securities
are registered pursuant Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant
included in the filing reflect the correction of an error to previously issued financial statements. ¨

Indicate by
check mark whether any of those error corrections are restatements that required a recovery analysis of incentive- based compensation
received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ¨

Indicate by check mark which basis of accounting
the registrant has used to prepare the financial statements included in this filing:

    U.S. GAAP  x
    International Financial Reporting Standards as issued
    Other  ¨

    by the International Accounting Standards Board  ¨

If
 “Other” has been checked in response to the previous question indicate by check mark which financial statement item the registrant
has elected to follow.   Item 17  ¨  Item 18  ¨

If
this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange
Act).   Yes  x   No  ¨

    Auditor Name
    Auditor Firm ID
    Auditor Location

    Centurion ZD CPA & Co.
    2769
    Hong Kong, China

EXPLANATORY NOTE

This
Amendment No. 2 to Form 20-F (the “Form 20-F/A”) amends our annual report on Form 20-F for the year ended
December 31, 2022, which was originally filed with the U.S. Securities and Exchange Commission on May 30, 2023, as amended by
Amendment No. 1 filed with the SEC on August 1, 2023 (as amended, the “Annual Report”). The purpose of this Form 20-F/A
is (i) to amend Item 16I of the Annual Report to provide the disclosures required under Item 16I(b) of Form 20-F and (ii) to
provide the documentation required by Item 16I(a) of Form 20-F in the form of an exhibit to this Form 20-F/A.

This
Form 20-F/A does not reflect events occurring after the filing of the Annual Report and does not modify or update the disclosure
therein in any way