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CORRESP
 1
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 Lawrence
 Venick
 Partner

 2206-19
 Jardine House
 1
 Connaught Place Central
 Hong
 Kong, SAR

 Direct +852.3923.1188
 Main
 +852.3923.1111
 Fax +852.3923.1100
 lvenick@loeb.com

 Via
Edgar

 April
8, 2025

 Morgan
Youngwood and Stephen Krikorian

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 Washington,
D.C. 20549

 Re:
 Jingbo
 Technology, Inc. (the " Company ")
 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 March 14, 2025
 File
 No. 000-56570

 Dear
Messrs. Youngwood and Krikorian,

 As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated March 25, 2025 from the Securities
and Exchange Commission (the " Commission ") in which the staff of the Commission (the " Staff ") commented
on the above-referenced Form 10-K/A (the " Form 10-K/A ") for the Fiscal Year Ended February 29, 2024 and Form 10-K
for the Fiscal Year Ended February 29, 2024 (the " Form 10-K ").

 For
the Staff's convenience, the Staff's comment has been stated below in its entirety, with the Company's response set
out immediately underneath such comment. The Company has filed an amendment to the Form 10-K (the " Amendment ") in
response to the Staff's comments.

 Form
10-K/A for the Fiscal Year Ended February 29, 2024

 VIE
Structure and Risks Relating to Our Corporate Structure, page 3

 1.
 Disclose
 each permission or approval that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to operate your
 business and to offer the securities being registered to foreign investors. State whether you, your subsidiaries, or VIEs are covered
 by permissions requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any
 other governmental agency that is required to approve the VIE's operations, and state affirmatively whether you have received
 all requisite permissions or approvals and whether any permissions or approvals have been denied. Please also describe the consequences
 to you and your investors if you, your subsidiaries, or the VIEs: (i) do not receive or maintain such permissions or approvals, (ii)
 inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations
 change and you are required to obtain such permissions or approvals in the future.

 Response :
The Company has amended page 3 of the Amendment in response to the Staff's comments.

 Financial
Information Related to the Consolidated VIEs, Trusts and Partnerships, page 8

 2.
 We
 note that the consolidated VIEs constitute a material part of your consolidated financial statements. Please provide in tabular form
 a condensed consolidating schedule that disaggregates the operations and depicts the financial position, cash flows, and results of
 operations as of the same dates and for the same periods for which audited consolidated financial statements are required. The
 schedule should present major line items, such as revenue and cost of goods/services, and subtotals and disaggregated intercompany
 amounts, such as separate line items for intercompany receivables and investment in subsidiary. The schedule should also
 disaggregate the parent company, the VIEs and its consolidated subsidiaries, the WFOEs that are the primary beneficiary of the VIEs,
 and an aggregation of other entities that are consolidated. The objective of this disclosure is to allow an investor to evaluate the
 nature of assets held by, and the operations of, entities apart from the VIE, as well as the nature and amounts associated with
 intercompany transactions. Any intercompany amounts should be presented on a gross basis and when necessary, additional disclosure
 about such amounts should be included in order to make the information presented not misleading.

 Response :
The Company has amended pages 8-11 of the Amendment in response to the Staff's comments.

 Transfers
of Cash through Our Organizations, page 8

 3.
 Provide
 a clear description of how cash is transferred through your organization. Disclose your intentions
 to distribute earnings or settle amounts owed under the VIE agreements. Quantify any cash
 flows and transfers of other assets by type that have occurred between the holding company,
 its subsidiaries, and the consolidated VIEs, and direction of transfer. Quantify any dividends
 or distributions that a subsidiary or consolidated VIE have made to the holding company and
 which entity made such transfer, and their tax consequences. Similarly quantify dividends
 or distributions made to U.S. investors, the source, and their tax consequences.
 Your disclosure should make clear if no transfers, dividends, or distributions have been
 made to date. Describe any restrictions on foreign exchange and your ability to transfer
 cash between entities, across borders, and to U.S. investors. Describe any restrictions and
 limitations on your ability to distribute earnings from the company, including your subsidiaries
 and/or the consolidated VIEs, to the parent company and U.S. investors as well as the ability
 to settle amounts owed under the VIE agreements.

 Response :
The Company has amended page 11 of the Amendment in response to the Staff's comments.

 Item
1A. Risk Factors

 "We
do not have direct ownership of some of our operating entities in Chinese Mainland, but

 exercise
control over...", page 16

 4.
 You
 disclose that 31% of [Y]our current revenue is derived from our VIEs in Chinese Mainland. Your disclosures appear to infer ownership
 over the VIEs (e.g., "our VIEs"). Please refrain from using terms such as "we" or "our" when
 describing activities or functions of a VIE.

 Response :
The Company has amended the Risk Factors section in response to the Staff's comments.

 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 69

 5.
 We
 note your response to prior comment 3 and reissue our comment. We note that you did not disclose management's conclusion regarding
 the effectiveness of your disclosure controls and procedures as of February 29, 2024. Please revise to disclose management's
 conclusion of the effectiveness of your disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e) under the
 Securities
 Exchange
 Act of 1934. We refer you to Item 307 of Regulation S-K. Please note that Item 9 of the Form 10-K requires that you furnish information
 required by Item 307 and 308 of Regulation S-K.

 Response :
 The Company has amended page 72 of the Amendment in response to the Staff's
 comments.

 6.
 We
 note that your most recent amendment no longer includes the following statement "Based on this assessment, management concluded
 that our internal controls over financial reporting were not effective as of February 29, 2024." Please revise to disclose
 management's conclusion of the effectiveness of your internal controls over financial reporting as defined in Rule 13a-15(f)
 under the Securities Exchange Act of 1934. We refer you to Item 308 of Regulation S-K. Please note that Item 9 of the Form 10-K requires
 that you furnish information required by Item 307 and 308 of Regulation S-K. In this respect, you are required to disclose managements'
 conclusion of the effectiveness of both disclosure controls and procedures and internal controls over financial reporting.

 Response :
The Company has amended page 72 of the Amendment in response to the Staff's comments.

 *
* *

 Please
contact the undersigned at +1 310 7285129 if you have any questions with respect to the response contained in this letter.

 Sincerely,

 /s/
 Lawrence S. Venick

 Lawrence
 Venick

 Partner

 cc:
Zhang Guowei