SecProbe.io

CORRESP
 1
 filename1.htm

 April
30, 2026

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 100
F Street, NE

 Washington,
D.C. 20549

 Attn:
Matthew Crispino and Jan Woo

 Re: FiEE,
Inc.

 Draft
Registration Statement on Form S-3

 Submitted
March 13, 2026

 CIK
No. 0001467761

 Dear
Mr. Crispino and Ms. Woo:

 FiEE,
Inc., a Delaware corporation (the " Company "), hereby responds to the comment provided by the staff of the Division
of Corporation Finance (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ")
in its letter dated March 25, 2026 (the " Comment Letter "), regarding the above-referenced Draft Registration Statement
on Form S-3.

 Prior
to the submission of this letter, the Company filed with the Commission via EDGAR Amendment No. 1 to the Company's Annual
Report on Form 10-K for the year ended December 31, 2025 (the " Form 10-K/A "), which includes, among other things,
revisions made in response to the comment received from the Staff in the Comment Letter. Concurrently with the submission of this
letter, the Company is publicly filing with the Commission via EDGAR the Company's Registration Statement on Form S-3 (the
" Public Filing Form S-3 "), which includes revisions made in response to the comment received from the Staff in
the Comment Letter as well as certain additional changes to update the disclosure contained therein.

 Set
forth below in bold font is the comment of the Staff contained in the Comment Letter and immediately below the comment is the response
of the Company with respect thereto.

 Draft
Registration Statement on Form S-3

 General

 1. We
 note that beginning in March 2025, the Company has derived all its revenues from Hong Kong.
 Please revise your filing to provide specific and prominent disclosures about the legal and
 operational risks associated with having your business in this location, consistent with
 the guidance in our Sample Letter to Companies Regarding China-Specific Disclosures and our
 Sample Letter to China-Based Companies, which were posted to our website July 17, 2023, and
 on December 20, 2021.

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 April
30, 2026

 Page
2

 Response :
The Company acknowledges the Staff's comment and respectfully advises the Staff that the Company has revised the disclosure beginning
on page 1 of the Form 10-K/A and beginning on page 4 of the Public Filing Form S-3 to address the legal and operational risks
associated with having the Company's revenue generating business in Hong Kong. Additionally, the Company has revised the disclosure
beginning on page 13 of the Form 10-K/A to include risk factors related to doing business in Hong Kong. Please note that the Form 10-K/A
is incorporated by reference into the Public Filing Form S-3.

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 April
30, 2026

 Page
3

 If
you should have any questions concerning the enclosed matters, please feel free to contact our counsel, David A. Bartz of K&L Gates
LLP, at david.bartz@klgates.com or by telephone at (615) 780-6743.

 Sincerely,

 /s/
 Li Wai Chung

 Li
 Wai Chung

 Chief
 Executive Officer and President

 cc:
 David
 A. Bartz, Esq., K&L Gates LLP