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September 27, 2023
Sun Xiuzhi
Chief Executive Officer and Chief Financial Officer
Cambell International Holding Corp.
1-17-1 Zhaojia Road
Xinglongtai District
Panjin City, Liaoning Province
People's Republic of China
Re:Cambell International Holding Corp. (formerly Bitmis Corp.)
Form 10-K for Fiscal Year Ended June 30, 2022
Filed July 19, 2022
Form 10-Q for the period ended March 31, 2023
Filed May 22, 2023
Form 8-K/A filed January 11, 2023
File No. 333-214469
Dear Sun Xiuzhi:
            We have reviewed your August 14, 2023 and September 18, 2023 response to our
comment letter and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
June 14, 2023 letter.
Form 10-K for the Fiscal Year Ended June 30, 2022
General
1.We note your proposed disclosure stating that the Company is the primary beneficiary of a
variable interest entity.  Please revise your proposed disclosure to provide a diagram of the
company’s corporate structure, identifying the person or entity that owns the equity in
each depicted entity.

 FirstName LastNameSun Xiuzhi
 Comapany NameCambell International Holding Corp.
 September 27, 2023 Page 2
 FirstName LastName
Sun Xiuzhi
Cambell International Holding Corp.
September 27, 2023
Page 2
2.We note your proposed disclosure that "[i]f the business environment in China
deteriorates from the perspective of domestic or international investment, or if relations
between China and the United States or other governments deteriorate, the Chinese
government may intervene with [y]our operations and [y]our business in China and in the
United States."  Please revise your proposed disclosure to note that the Chinese
government may intervene or influence your operations at any time.

3.Please revise your proposed disclosure to include each permission or approval that you,
the VIE, or your subsidiaries are require to obtain from Chinese authorities to operate your
business.
4.We note that the VIE constitutes 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 VIE, the WFOE, 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.
            You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at 202-551-3494 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Cindy Polynice at 202-551-8707 or Joshua Gorsky at 202-551-7836 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences