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SEC Company Response from XMax (XMAX) — May 8, 2026

XMax Inc.
Date: May 8, 2026 · CIK: 0001473334 · Accession: 0001493152-26-021892

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File numbers found in text: 333-295406

Date
April 29, 2026
Author
Chief
Form
CORRESP
Company
XMax Inc.

Letter

Re: XMAX Inc.

XMAX INC.

May 8, 2026

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

F Street, N.E.

Washington, DC 20549

Registration Statement on Form S-3

Filed April 29, 2026

File No. 333-295406

Acceleration Request

Requested Date: May 12, 2026

Requested Time: 4:00 p.m. Eastern Time

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, XMax Inc. (the “Company”) hereby respectfully requests the Securities and Exchange Commission (the “Commission”) to accelerate the effective date of the above-referenced Registration Statement and declare such Registration Statement effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable.

In connection with the acceleration request, the Company hereby acknowledges that:

● should the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

● the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

● the Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any further comments, require any further information or if any questions should arise in connection with this submission, please call our counsel Mr. Jeffrey Li at (703) 618-2505 at FisherBroyles, LLP.

[Signature Page Follows]

Very
truly yours,
XMax
Inc.

Show Raw Text
CORRESP
1
filename1.htm

XMAX
INC.

May
8, 2026

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
DC 20549

    Re:
    XMAX
                                            Inc.

    Registration
    Statement on Form S-3

    Filed April 29, 2026

    File No. 333-295406

Acceleration
Request

    Requested Date:
    May 12, 2026

    Requested Time:
    4:00 p.m. Eastern Time

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, XMax Inc. (the “Company”)
hereby respectfully requests the Securities and Exchange Commission (the “Commission”) to accelerate the effective
date of the above-referenced Registration Statement and declare such Registration Statement effective at the “Requested Date”
and “Requested Time” set forth above or as soon thereafter as practicable.

In
connection with the acceleration request, the Company hereby acknowledges that:

    ●
    should
                                                                     the Commission or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not
                                                                     foreclose the Commission from taking any action with respect to the filing;

    ●
    the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
Company may not assert the staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

If
you have any further comments, require any further information or if any questions should arise in connection with this submission, please
call our counsel Mr. Jeffrey Li at (703) 618-2505 at FisherBroyles, LLP.

[Signature
Page Follows]

    Very
                                            truly yours,

    XMax
    Inc.

    /s/
    Xiaohua Lu

    Xiaohua
Lu

    Chief
Executive Officer

    cc:
    Jeffrey
                                            Li, FisherBroyles, LLP