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June 13, 2024
Silong Chen
Chief Executive Officer
Dogness (International) Corp
No. 16 N. Dongke Road
Tongsha Industrial Zone
Dongguan, Guangdong 523217
Re:Dogness (International) Corp
Registration Statement on Form F-3
Filed June 7, 2024
File No. 333-280051
Dear Silong Chen:
            We have conducted a limited review of your registration statement and have the
following comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form F-3 filed June 7, 2024
General
1.We note your disclosure appearing on the cover page, Summary, and Risk Factor sections
relating to legal and operations risks associated with operating in China and PRC
regulations has changed significantly from the disclosure included in your annual report
on Form 20-F, File No. 001-38304 filed October 12, 2023. It is unclear to us that there
have been changes in the regulatory environment warranting disclosure that mitigates the
challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to the risk that the PRC government may
intervene in or influence your operations at any time, or may exert control over operations
of your business, which could result in a material change in your operations and/or the
value of the securities you are registering for sale. We remind you that, pursuant to federal
securities rules, the term "control" (including the terms "controlling," "controlled by," and

 FirstName LastNameSilong Chen
 Comapany NameDogness (International) Corp
 June 13, 2024 Page 2
 FirstName LastName
Silong Chen
Dogness (International) Corp
June 13, 2024
Page 2
"under common control with") as defined in Securities Act Rule 405 means "the
possession, direct or indirect, of the power to direct or cause the direction of the
management and policies of a person, whether through the ownership of voting securities,
by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to
uncertainties regarding the enforcement of laws and that the rules and regulations in China
can change quickly with little advance notice. We do not believe that your disclosure
referencing the PRC government's intent to strengthen its regulatory oversight conveys the
same risk. Please revise.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Erin Donahue at 202-551-6063 or Bradley Ecker at 202-551-4985 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing