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HURLBERT PLC

September 20, 2024

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Re: Hitek Global Inc.

Registration Statement on Form F-3 (the “Registration Statement”)

Submitted August 22, 2024

File No. 333-281723

Ladies and Gentlemen:

This letter is in response to the letter dated
September 4, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Hitek Global Inc. (the “Company”, “we”, and “our”). For ease of
reference, we have recited the Commission’s comments in this response and numbered them accordingly.

Registration Statement on Form F-3

Selling Shareholders, page 8

1. Please disclose whether any of your selling
shareholders are broker-dealers or affiliates of broker-dealers. If a selling shareholder is a broker-dealer, please revise your
disclosure to indicate that such selling shareholder is an underwriter, unless such selling shareholder received its securities as
compensation for investment banking services. In addition, in connection with a selling shareholder who is an affiliate of a
broker-dealer, please disclose if true, that:

 ● the selling shareholder purchased the shares being registered
for resale in the ordinary course of business; and

 ● at the time of the purchase, the selling shareholder had
no agreements or understandings, directly or indirectly, with any person
to distribute the securities.

If you are unable to make these representations, please
disclose that the selling shareholder is an underwriter.

Response: The Company acknowledges the Staff’s
comment and notes that no selling shareholder is a broker-dealer or an affiliate of a broker-dealer.

General

2. Given the size and nature of the resale offering
relative to the outstanding shares of Class A ordinary shares held by non-affiliates, it appears that this transaction may be an
indirect primary offering by or on behalf of the company. Please provide us with your legal analysis as to why the transaction
covered by the registration statement should be regarded as a secondary offering that is eligible to be made on a delayed or
continuous basis under Rule 415(a)(1)(i) of the Securities Act. For guidance, please refer to Question 612.09 of the Securities Act
Rules Compliance and Disclosure Interpretations.

Response:

The Company acknowledges the Staff’s comment,
but for the reasons set forth below respectfully submits that the proposed offering of the Company’s Class A ordinary shares, $0.0001
par value per share, by the selling stockholders as contemplated by the Registration Statement is appropriately characterized as an offering
that is eligible to be made on a delayed or continuous basis under Rule 415(a)(1)(i).

Under Rule 415(a)(1)(i), an issuer may register
securities to be sold on a delayed or continuous basis by selling security holders in a secondary offering. The Company will not receive
any proceeds from the resale of the securities registered pursuant to the Registration Statement; all such proceeds will be received by
the selling stockholders. However, the Staff has noted in Securities Act Rules Compliance and Disclosure Interpretation (“CDI”)
612.09 that “[t]he question of whether an offering styled a secondary one is really on behalf of the issuer is a difficult factual
one, not merely a question of who receives the proceeds.” The Company respectfully submits that, upon a proper evaluation of the
totality of the factors and circumstances articulated in CDI 612.09, the proposed offering is a valid secondary offering as to which the
selling stockholders are not acting as underwriters or otherwise as a conduit for the Company, and consequently all of the securities
may be registered under Rule 415(a)(1)(i).

As indicated in the Registration Statement, the
Company will not receive any proceeds from the resale of securities pursuant to the Registration Statement. Instead, the selling stockholders
will receive all proceeds received from any resales by them. As CDI 612.09 indicates, the question is a “difficult factual one”
involving an analysis of various factors and “all the circumstances.” Specifically, CDI 612.09 states that consideration should
be given to the following factors:

 ● how long the selling shareholders have held the securities;

 ● the circumstances under which they received them;

 ● their relationship to the issuer;

 ● the amount of shares involved;

 ● whether the sellers are in the business of underwriting securities; and

 ● whether under all the circumstances it appears that the seller is acting as a conduit for the issuer.

    2

Each of the relevant factors listed in CDI 612.09
is discussed below in the context of the Registration Statement. In our view, based on a proper consideration of all of those factors,
the Staff should conclude that the proposed offering is “solely by or on behalf of a person or persons other than the registrant,
a subsidiary of the registrant or a person of which the registrant is a subsidiary” and, therefore, the registration of all of such
securities is permissible under Rule 415(a)(1)(i). In other words, we believe that the totality of the facts and circumstances in this
case clearly demonstrates that the registration of the securities relates to a valid secondary offering, and the selling stockholders
are not acting as underwriters or otherwise as a conduit for the Company with respect to the securities covered by the Registration Statement.

 1. The Period for which the Selling Stockholders have Held the Securities

As of July 29, 2024, the Company closed a private
placement (the “Private Placement”) of (a) 14,907,000 Class A ordinary shares, $0.0001 par value per share (the “Placement
Shares”), and (b) warrants (the “Warrants”) to purchase up to an aggregate of 14,907,000 Class A ordinary shares (the
“Warrant Shares”) pursuant to a Securities Purchase Agreement, dated July 29, 2024, by and between the Company and the eight
purchasers named therein (the “Securities Purchase Agreement”). As used herein, the Placement Shares and the Warrant Shares
are collectively referred to as the “Shares.” The Warrants are exercisable immediately upon issuance with a term of two years
at an exercise price of $0.55 per share. While such exercise price will be adjusted for stock splits, the Warrants do not contain any
provision that would otherwise adjust the exercise price during the term of the Warrants. The Warrants also contain a cashless exercise
provision. The Company issued the Placement Shares at a price of $0.55 per share and the Warrants for nominal consideration. In connection
with the Private Placement, the Company warranted that it would use its best efforts to promptly register the resale of the Placement
Shares and the Warrant Shares.

The 29,814,000 Shares being registered pursuant
to the Registration Statement consist of the (i) 14,907,000 Placement Shares and (ii) 14,907,000 Warrant Shares issued in the Private
Placement. The Private Placement was completed and the Placement Shares and the Warrants were issued as of July 29, 2024 pursuant to binding
obligations arising out of the Securities Purchase Agreement.

Presumably, the longer the time securities are
held, the less likely it is that selling shareholders are acting as a mere conduit for the Company. Here, the selling shareholders have
held their securities for approximately two months as of the date of this letter, and for the reasons discussed below, the selling shareholders
will likely be required to continue to hold their securities for a significant additional length of time. This holding period is longer
than the holding period required by the staff for valid “PIPE” transactions.

The Staff’s “PIPEs” interpretation
is set forth in Question 116.9 of the CDIs for the Securities Act Forms (the “PIPEs Interpretation”). The PIPEs Interpretation
provides in relevant part that:

“In a PIPE transaction, a company will be permitted
to register the resale of securities prior to their issuance if the company has completed a Section 4(2)-exempt sale of the securities
(or in the case of convertible securities, of the convertible security itself) to the investor, and the investor is at market risk at
the time of filing of the resale registration statement…. The closing of the private placement of the unissued securities must
occur within a short time after the effectiveness of the resale registration statement.”

    3

The PIPEs Interpretation contemplates that a valid
secondary offering could occur immediately following the closing of the placement. Since there is no mandatory holding period that
must be overcome for a PIPE transaction to be a valid secondary offering, the holding period of the selling stockholders here should be
more than sufficient for a valid secondary offering.

This concept is consistent with custom and practice
in the PIPEs marketplace. In many PIPE transactions, a registration statement is required to be filed shortly after closing and is required
to be declared effective shortly thereafter. In addition, in this case, the selling stockholders understood that an extended holding period
was possible, given the potential for a review of the Registration Statement by the Commission. The Securities Purchase Agreement entered
into between the selling stockholders and the Company on July 29, 2024 required the Company to use its commercially reasonable efforts
to have the Registration Statement declared effective as soon as practicable.

Further, as discussed in more detail below, the
selling stockholders made their investment decision to purchase the Placement Shares and the Warrants fully understanding that there would
be only limited trading activity in the Company’s Class A ordinary shares. It is clear that the Company and the selling stockholders
effectuated the private placement because of the Company’s need for cash, and in so doing, (a) enhanced the Company’s cash
position and cash flow in the near term, (b) preserved the Company’s operations, and (c) allowed the Company to pursue potential
acquisitions. The context of the Company’s financing needs, and the relative illiquidity of the market for the Company’s Class
A ordinary shares, support the conclusion that the selling stockholders participated in the financing as part of their respective long-term
commitments to help preserve and grow the Company, and not for the purpose of distributing securities on behalf of the Company.

The factors discussed above, including the length
of time that has elapsed since the securities were originally acquired by the selling stockholders and that will ultimately elapse prior
to the Shares first becoming saleable in the public market, and the fact that the selling stockholders were aware at the July 29, 2024
closing that, for various reasons, they would be unable to quickly exit their positions with respect to the Company’s Class A ordinary
shares, in the aggregate, support the conclusion that the offering pursuant to the Registration Statement is a secondary offering.

    4

2. The Circumstances under which the
Selling Stockholders Received the Shares

All of the Placement Shares and Warrants issued
to the selling stockholders were issued pursuant to a private placement transaction exempt from the registration requirements of the Securities
Act. Specifically, the securities were offered, sold and issued in reliance upon the exemption from registration provided by Regulation
S promulgated under the Securities Act. That being said, the exemptions from registration provided by Section 4(a)(2) of the Securities
Act and Regulation D promulgated thereunder could also apply. Accordingly, the securities held by the selling stockholders are, and at
all times have been, restricted securities that could not have been, and may not be, offered or sold in the United States absent registration
or an applicable exemption from the registration requirements of the Securities Act. Each of the selling stockholders made specific representations
to the Company pursuant to the Purchase Agreement that such selling stockholder was acquiring the securities in the ordinary course of
business for such selling stockholder’s own account and not with a view towards, or for resale in connection with, the public sale
or distribution thereof, except pursuant to sales registered under the Securities Act or under an exemption from such registration, and
that such selling stockholder does not have a present agreement or understanding, directly or indirectly, to effect any distribution of
the securities to or through any person or entity. The Company is not aware of any evidence that would indicate that these specific representations
were false or of any evidence that any selling stockholder has any plan to act in concert to effect a distribution of its securities.
Furthermore, the Company is not aware of any evidence that a distribution would occur if the Registration Statement were declared effective.

Under the Commission’s rules, a “distribution”
requires special selling efforts. Rule 100(b) of Regulation M defines a “distribution” as “an offering of securities,
whether or not subject to registration under the Securities Act, that is distinguished from ordinary trading transactions by the magnitude
of the offering and the presence of special selling efforts and selling methods.” There is nothing to suggest that any special selling
efforts or selling methods by or on behalf of the selling stockholders have or would take place if the Registration Statement is declared
effective. The Company also is not aware of any facts to suggest that the selling stockholders have taken any actions to condition or
prime the market for the potential resale of the shares. To do so would result in a breach of the Purchase Agreement by the respective
selling stockholders.

The Company understands that the Commission has
become concerned about the public resale of securities purchased in so-called “toxic” transactions, and accordingly monitored
the attempted resale of securities resulting from these types of transactions. Specifically, the Commission compared the number of shares
that an issuer attempted to register to the total number of shares outstanding held by non-affiliates. In screening for these types of
offerings, the Staff looked at situations where an offering involved more than approximately one-third of the public float and raised
the Staff’s concerns that a secondary offering might be a “disguised” primary offering for Rule 415 purposes. According
to the Office of the Chief Counsel, however, this test was intended as a mere screening process and was not intended to be a substitute
for a complete analysis of the factors cited in CDI 612.09. It has been reported that the Staff has recognized that the application of
this float screening test led to the unintended consequence of limiting the securities that could be registered on behalf of selling stockholders
in transactions that did not implicate the Staff’s concerns with respect to “toxic” PIPE transactions. As a result,
we understand that the Staff’s focus shifted in late 2006 to “Extreme Convertible” transactions to avoid disrupting
legitimate PIPE transactions. The Company notes that the resale of the shares covered by the Registration Statement does not raise any
of these “toxic” offering concerns which the Staff has focused on in the past.

    5

Additionally, the selling stockholders obtained
the shares offered in the Registration Statement through a privately negotiated transaction completed at arms’-length, after a process
involving months of rigorous review and evaluation by the Company prior to entry into the Securities Purchase Agreement.

The Private Placement is an investment transaction
that has characteristics more closely associated with a traditional investment transaction than with an underwritten offering. Specifically,
in a typica