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SCHLUETER & ASSOCIATES, P.C.

5655 SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD VILLAGE, CO 80111

TELEPHONE: +1-303-292-3883

FACSIMILE: +1-303-648-5663

Email: hfs@schlueterintl.com

August 7, 2023

Via Email: parikhs@sec.gov

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attn: Sasha Parikh

    Re:
    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 Ms. Parikh:

We represent Cambell International
Holding Corp., formerly known as Bitmis Corp. (the “Company”), as U.S. counsel. The purpose of this letter is to respond to
the comment letter dated June 14, 2023, from the Division of Corporation Finance, Office of Life Sciences (the “Staff”) of
the U.S. Securities and Exchange Commission (the “Commission” or “SEC”) relating to filings referenced above.
For your convenience, the comments have been reproduced below, followed by the Company’s response.

Form 10-K for Fiscal year Ended June 30, 2022

General

1.  We
note that on December 30, 2022, you acquired all of the issued and outstanding capital stock of Cambell International Holding Limited,
which operates through its subsidiaries and interest in a variable interest entity in the People’s Republic of China. In light of this
development, please provide us with proposed disclosure to be included in future filings that provides more specific and prominent details
about the legal and operational risks associated with China-based companies. For additional guidance, please see the Division of Corporation
Finance’s Sample Letter to China-Based Companies issued by the Staff in December 2021.

Response:

In response to this comment,
the Company has provided Exhibit A, which is attached hereto. Exhibit A contains the proposed disclosures that will be included in the
Company’s annual report on Form 10-K for the fiscal year ended June 30, 2023, and in future filings as appropriate.

Form 8-K filed January 11, 2023

Risk Factors, page 23

2.  You
disclose on page 44 that “Our auditor, an independent registered public accounting firm that issues the audit report included elsewhere
in this Report, is headquartered in San Mateo, California and registered with the PCAOB.” You seem to be referring to WWC, P.C.,
the auditor that signed the opinion for Cambell International Holding Limited. Tell us how you considered the requirements of Item 4.01
of Form 8-K. Specifically, explain to us and clearly disclose the extent to which the registrant Bitmis Corp. has retained WWC, P.C. to
be its auditor and terminated its relationship with BF Borgers CPA PC. Tell us which independent accountant performed the review procedures
for the quarterly interim periods ended December 31, 2022 and March 31, 2023.

Response:

The Company will file a current
report on Form 8-K under Item 4.01 Changes in Registrant’s Certifying Accountant in response to this comment. Also, the Company
anticipates filing a letter from BF Borgers CPA PC (“Borgers”) containing the required disclosures about its dismissal and
the statements made in the Form 8-K as an exhibit to the Form 8-K.

Borgers performed the review
procedures for the financial information contained in the Form 10-Q for the quarter ended September 30, 2022. WWC, P.C. performed the
review procedures for the financial information contained in the Form 10-Q for the quarter ended December 31, 2022, and March 31, 2023.

Form 10-Q for the period ended March 31, 2023

Management’s Discussion and Analysis of Financial Condition
and Results of Operations

Results of Operations, page 22

3. You disclose on pages 22 and 23 that the
decrease in revenues between the periods presented is “mainly due to the explosion of COVID-19” during the three-month
and nine-month periods. Please provide us with proposed disclosure to be provided in your future filings that provide a robust
discussion of the impact of COVID-19 on your operations compared to prior periods. As part of your response, please address the
following: ● To the extent possible, provide quantification of the impact of COVID-19 on your revenues and other line items
for each of the periods presented. ● Specifically identify the nature of the impact on your operations, such as worker
absenteeism, lockdowns, plant closure, purchase of additional protective equipment or sanitizing supplies, changes in customer
habits, etc., providing quantification to the extent possible.

Response:

In response to this comment,
please find attached Exhibit B, which contains disclosures regarding the impact of Covid-19 on the Company’s revenues and gross
profit. These disclosures will be included in the next Form 10-K filed with the SEC as appropriate.

If you have any questions
relating to this letter or Exhibits A or B, please do not hesitate to contact both the Company and me. I may be reached via email at hfs@schlueterintl.com
or on my US mobile at 303-868-3382. Also, please copy any future correspondence to both Celia Velletri and me. Ms. Velletri’s email
is cv@schueterintl.com.

    Very truly yours,

    Schlueter &
Associates, P.C.

    By:
    /s/ Henry F. Schlueter

    Henry F. Schlueter

    C:
    Bitmis Corp., now known as Cambell International Holding Corp.

    WWC, PC.

    2

EXHIBIT A – RESPONSE TO SEC COMMENT
NO. 1

In addition to the disclosure in the
super 8-K filed with the Securities and Exchange Commission on January 11, 2023 (the “Current Report”), the Company will be
adding further disclosure as follows: :

ITEM 1. BUSINESS

Regulatory Overview – The VIE
- Legal and Operational Risks

Cambell International
Holding Corp. (the “Company”) is not a Chinese operating company but rather a Nevada holding company with operations in the
PRC conducted by its PRC wholly foreign owned entity and subsidiary (Baijiakang (Liaoning) Health Information Consulting Services Co.,
Ltd.) through contractual agreements with a variable interest entity (“VIE”) (Liaoning Kangbaier Biotechnology Development
Co. Ltd.) as discussed below in greater detail below.

The VIE structure
involves unique risks to shareholders and investors. During the past several years, China has shown an increasingly open attitude towards
foreign investment in its domestic market by promoting the development of numerous Chinese companies, their offshore capital fundraising
and facilitating overseas listing. This has lead China to achieve significant economic success in which foreign investment has played
a large role. Problems remained, however, for Chinese companies engaging in restricted or prohibited industries, which are not only banned
from raising overseas capital but also isolated from going public abroad, in order to avoid foreign ownership. Chinese companies were
encountering a dilemma that comprised two conflicting goals: raising overseas capital while complying with China’s regulation on
direct foreign investment. Therefore, the variable interest entity (the “VIE”) evolved to solve the two inconsistencies. The
VIE has been an integral and critical factor in China’s economic success involving foreign investment.

In light of
the ownership structure of a VIE, foreign shareholding in a Chinese operating entity involving a prohibited or restricted industry contravenes
China’s regulations on direct foreign investment. However, the VIE structure uses contractual controls or agreements to meet the
ownership structure benchmark thus enabling foreign investors to obtain a Chinese operating entity’s economic benefits and managerial
rights without changing its ownership structure. Since the operating entity is under the 100% of Chinese shareholding, the operating entity
should be recognized by Chinese regulators to permit market entry in prohibited restricted industries thereby achieving creative compliance.

The broad
adoption of the VIE structure appears to suggest that it has been legally recognized in China especially given that VIE usage in capital
markets is clearly known to Chinese authorities. However, the legality of the VIE structure has not been explicitly confirmed. See Shen
Wei, “Will the Door Open Wider in the Aftermath of Alibaba?–Placing (or Misplacing) Foreign Investment in A Chinese Public
Law Frame” (2012) 42 Hong Kong Law Journal 561, 565.

Implications of Being a Holding Company
- Transfers of Cash to and from Our Subsidiaries and VIE

As a holding
company, we will rely on dividends and other distributions on equity paid by our subsidiaries and VIE for our cash and financing requirements.
We do not maintain cash management policies or procedures. We are permitted under the laws of the State of Nevada and our articles of
incorporation (as amended from time to time) to provide funding to our VIE and subsidiaries incorporated in China and Hong Kong through
loans or capital contributions. Our VIE and subsidiaries are permitted under the respective laws of China and Hong Kong to provide funding
to us through dividends without restrictions on the amount of the funds, other than as limited by the amount of their distributable earnings.
However, to the extent that cash is in our PRC or Hong Kong subsidiaries or our VIE, there is a possibility that the funds may not be
available to fund our operations or for other uses outside of the PRC or Hong Kong due to interventions or the imposition of restrictions
and limitations by the PRC or the Hong Kong government on the ability to transfer cash. If any of our subsidiaries incur debt on
their own behalf in the future, the instruments governing such debt may restrict their ability to pay dividends to us.

    3

As of the date
of this Annual Report, our subsidiaries have not experienced any difficulties or limitations on their ability to transfer cash between
each other; nor do they maintain cash management policies or procedures dictating the amount of such funding or how funds are transferred.
None of our subsidiaries have paid any dividends, other distributions or transferred assets to our holding company as of the date of this
Annual Report. In the future, cash proceeds raised from overseas financing activities may be transferred by us to our PRC or Hong Kong
subsidiaries via capital contribution or shareholder loans, as the case may be. As of the date of this Annual Report, we have not made
any transfers, paid any dividends, or made any distributions to U.S. investors.

Contractual Arrangements among
Baijiakang Consulting, our WFOE, Liaoning Kangbaier and Liaoning Kangbaier’s Shareholders

While we do
not have any equity interest in our consolidated affiliated entities, we have been and are expected to continue to be dependent on them
to operate our business as long as there is limitation or prohibition in the interpretation and application by local governments of regulations
concerning foreign investments in companies such as our consolidated affiliated entities. We rely on our consolidated affiliated entities
to maintain or renew their respective qualifications, licenses or permits necessary for our business in China. We believe that under the
VIE Agreements, we have substantial control over our consolidated affiliated entities and their respective shareholders to renew, revise
or enter into new contractual arrangements prior to the expiration of the current arrangements on terms that would enable us to continue
to operate our business in China after the expiration of the current arrangements, or pursuant to certain amendments and changes of the
current applicable PRC laws, regulations and rules on terms that would enable us to continue to operate our business in China legally.
While we currently do not anticipate any changes to PRC laws in the near future that may impact our ability to carry out our business
in China, no assurances can be made in this regard. See “Risk Factors-Risks Related to Doing Business in China-Changes in China’s
economic, political or social conditions or government policies could have a material adverse effect on our business and operations.”
and “Risk Factors-Risks Related to Doing Business in China-Uncertainties with respect to the PRC legal system could adversely
affect us.” For a detailed description of the risks associated with our corporate structure and the contractual arrangements
that support our corporate structure, see “Risk Factors-Risks Related to Our Corporate Structure.”

The Company is
the primary beneficiary of a variable interest entity (“VIE’), Liaoning Kangbaier which, under U.S. GAAP, is required to consolidate
the assets and liabilities of our VIE on our consolidated financial statements. When we obtain a variable interest in another entity,
we assess at the inception of the relationship and upon occurrence of certain significant events whether the entity is a VIE and, if so,
whether we are the primary beneficiary of the VIE based on our power to direct the activities of the VIE that most significantly impact
the VIE’s economic performance and our obligation to absorb losses or the right to receive benefits from the VIE that could potentially
be significant to the VIE.

To determine
whether a variable interest that we hold could potentially be significant to the VIE, we consider both qualitative and quantitative factors
regarding the nature, size and form of our involvement with the VIE. To assess whether we have the power to direct the activities of a
VIE that most significantly impact the VIE’s economic performance, we consider all the facts and circumstances, including our role
in establishing the VIE and our ongoing rights and responsibilities. This assessment includes identifying the activities that most significantly
impact the VIE’s economic performance and identifying which party, if any, has power over those activities. In general, the parties
that make the most significant decisions affecting the VIE (management and representation on the Board of Directors) and have the right
to unilaterally remove those decision-makers are deemed to have the power to direct the activities of a VIE. To assess whether we have
the obligation to absorb losses of the VIE or the right to receive benefits from the VIE that could potentially be significant to the
VIE, we consider all of our economic interests that are deemed to be variable interests in the VIE. This assessment requires us to apply
judgment in determining whether these interests, in the aggregate, are considered potentially significant to the VIE.

    4

There are uncertainties associated with the VIE
structure as the PRC has not yet ruled on its legality as follows:

 (i) Our contractual arrangements may not be as effective in providing us with operational
control, and shareholders of the VIE may fail to perform their obligations under the contractual arrangements.

 (ii) We may incur substantial costs to enforce the terms of the arrangements with the VIE.

 (iii) The legality and enforceability of the contractual arrangements by and among our
PRC subsidiaries and the VIE have not been tested in a court of law in China.

 (iv) The equity holders, directors and executive officers of the VIE as well as our
employees who execute other strategic initiatives may have potential conflicts of interest with our company

 (v) There are substantial uncertainties regarding the interpretation and application
of current and future PRC laws, regulations and rules regarding the status of our Nevada holding company with respect to the contractual
arrangements with the VIE.

 (vi) It is uncertain whether any new PRC laws or regulations relating to VIE structures
will be adopted or, if adopted, what they would provide.

 (vii) If we or our VIE is found to be in violation of any existing or future PRC laws
or regulations, or fail to obtain or maintain any of the required licenses, permits,