SecProbe.io

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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

September 18, 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

    Response dated August 7, 2023 to SEC Comment Letter

    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
your comments from our conversation on Wednesday, September 13, 2023 relating to our response letter dated August 7, 2023 (the “Response
Letter”) and attached exhibits A and B (collectively, the “Exhibits”) in reference to the filings above.  In that conversation,
you pointed out that it appeared that language had been dropped in the Response Letter.

After a review of the Response Letter, we have identified the following:

1. We note that in Exhibit A, page
7, the second paragraph of the risk factor titled “Opinions on Severely Cracking Down on Illegal Securities Activities According
to Law” ended with “In addition….”. These words remained in error after the sentence was moved to the paragraph
below. Attached is Exhibit A as corrected.

2. We also note that Exhibit B
erroneously included the disclosure contained in Exhibit A. This has been corrected as Exhibit B is in reference to the proposed disclosure
on Covid-19 for future filings. Attached is Exhibit B as corrected. Please note that the Risk Factor regarding COVID-19 contained in Exhibit
B has also been added to Exhibit A under “Item 1.A – Risk Factors – Risks Related to Our Company” where it will
appear in future filings, as long as it is still relevant.

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

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.

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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.

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.

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    (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, registrations, or approvals, the relevant PRC regulatory authorities would have broad discretion to take action in dealing with such violations or failures.

    (viii)
    If the PRC government finds that the agreements that establish the VIE structure for operating our business do not comply with PRC laws and regulations, or if these regulations or their interpretations change in the future, we would be subject to severe penalties or be forced to relinquish our interest in those operations.

Cash Flows

Substantially all of our sales
are earned by our PRC subsidiary and its VIE. As a holding company, we will rely on dividends and other distributions on equity paid by
our Hong Kong and PRC subsidiary for our cash and financing requirements. Our Hong Kong and PRC subsidiary 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 Hong Kong or PRC subsidiaries, 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 incurs debt on its own behalf in the future, the instruments governing such debt may restrict their ability to pay
dividends to us.

After investors’ funds
enter the Company, the funds can be directly transferred to Cambell International Holding Limited (“Cambell International”)
in accordance with the laws of the State of Nevada, which will then directly transfer the funds to Win&win Industrial Development
Company Ltd. (“Win&Win”) in accordance with the laws of the British Virgin Islands. Win&Win will then directly transfer
the funds to BJK Holding Group Limited (“BJK Holding”) in accordance with the laws of the British Virgin Islands. BJK Holding
can then transfer the funds to Baijiakang (Consulting) in accordance with the laws of Hong Kong, which can subsequently transfer funds
to the VIE, Liaoning Kangbaier. If the Company intends to distribute dividends, Baijiakang (Consulting) will transfer the dividends to
BJK Holding in accordance with the laws and regulations of China. BJK Holding will then transfer the funds to Win&Win in accordance
with the laws of Hong Kong, Win&Win will then transfer the funds to Cambell International, and Cambell International with then transfer
the funds to us in accordance with the laws of the BVI, which we will then distribute the dividends to all of our shareholders respectively
in proportion to the shares they hold in accordance with the laws and regulations of the State of Nevada, regardless of whether the shareholders
are U.