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 April 22, 2025

Zhang Guowei
Chief Executive Officer
Jingbo Technology, Inc.
Floor 1 to 6, No. 1 to 10 Chuangyi Road
Yinhu Village, Shoujiang Town
Fuyang District, China 310000

 Re: Jingbo Technology, Inc.
 Form 10-K/A for the Fiscal Year Ended February 29, 2024
 Form 10-K for the Fiscal Year Ended February 29, 2024
 Response dated April 8, 2025
 File No. 000-56570
Dear Zhang Guowei:

 We have reviewed your April 8, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March
25, 2025 letter.

Amendment 3 to Form 10-K/A for the Fiscal Year Ended February 29, 2024
Financial Information Related to the Consolidated VIE, Trusts and Partnerships,
page 9

1. We note your revised disclosures in response to prior comment 2. Please
revise the
 table to include a column for the Huixin WFOE and present your equity
investment
 interest in, and your share of Huixin WFOE's net income or losses.
Explain why your
 schedules of Selected Condensed Consolidated Balance Sheets Information
do not
 include a separate line item and eliminating adjustments for the
Parent's investment in
 Huixin WFOE. In addition, the table should present Huixin WFOE's
economic
 interest in the VIE s business operations through contractual
agreements between the
 VIEs and Huixin WFOE. That is, Huixin WFOE should present the service
fee
 income and related receivable due from the VIE to the WFOE from the date
the
 April 22, 2025
Page 2

 Exclusive Business Corporation Agreement was signed (i.e., WOFE's share
of VIEs'
 income or losses). Lastly, refer to all schedules, including the header,
as condensed
 "consolidating" financial data. Consider reordering the table to start
with the parent,
 then the WOFE and the VIEs accordingly. Supplementally provide us with
revised
 tables.
Item 1A. Risk Factors
"We do not have direct ownership of some of our operating entities in Chinese
Mainland, but
exercise control over...", page 19

2. We note your revised disclosures in response to prior comment 4 that
state "As a
 result, through such contractual arrangements with the VIE and its
shareholders, we
 are the primary beneficiary of the VIE, and, therefore, consolidate the
financial results
 of the VIE in our consolidated financial statements in accordance with
all of our
 current revenue is derived from our VIE in Chinese Mainland." Your
disclosures
 appear to infer ownership over the VIEs (e.g., our VIE ). Please
refrain from using
 terms such as we or our when describing activities or
functions of a VIE.
Item 9. Changes in and Disagreements with Accountants on Accounting and
Financial
Disclosure
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedure,, page 72

3. We note your revised disclosures in response to prior comment 5 state
"Based on this
 evaluation of our disclosure controls and procedures as of February 28,
2024, our
 management concluded that our disclosure controls and procedures as of
such date are
 effective at the reasonable assurance level." We also note from your
disclosures that
 there are material weaknesses and management concluded that your
internal controls
 over financial reporting were not effective as of February 29, 2024.
Please help us
 better understand how you were able to conclude that your disclosure
controls and
 procedures are effective when there are material weaknesses in your
internal controls
 over financial reporting.
 Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at
202-
551-3488 if you have questions regarding comments on the financial statements
and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
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