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 Nocera, Inc.

 2030 Powers Ferry Road SE

 Suite No. 212

 Atlanta, Georgia 30339

 June 20, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, NE

 Washington, D.C. 20549

 Re:
 Nocera, Inc.

 Amendment No. 1 to Form 10-K/A for Fiscal Quarter
 Ended December 31, 2024
 Filed June 4, 2025
 Response dated June 9, 2025

 File No. 001-41434

 Dear Ms. Shafique and Mr. Pavot:

 On behalf of Nocera, Inc.
(the "Company," "Nocera," "we," "us," or "our"), this letter responds to comments
provided by the staff of the Division of Corporation Finance (the "Staff") of the Securities and Exchange Commission (the
"Commission") provided to the undersigned on June 9, 2025, regarding the Company's Amendment No. 1 to Form 10-K/A filed
on June 4, 2025 for the fiscal year ended December 31, 2024 (the "10-K/A").

 For your convenience, the
Staff's comments have been restated below and the Company's responses are set forth immediately under the restated comments.
Unless otherwise indicated, defined terms used herein have the meanings set forth in the 10-K/A. We have filed Amendment No. 2 to the
10-K/A (the "Amendment") with the Commission today.

 Form 10-K/A filed June 4, 2025

 Report of Independent Registered Public Accounting Firm, page F-2

 1.
 The opinion date does not appear to cover the subsequent revisions to your financial statement disclosures. Please revise pursuant to paragraph 18e of PCAOB Auditing Standard 3101 and Auditing Standard 3110.

 1

 Response: Please be advised that we have
amended the disclosures on F-2 of the 10-K/A per the Staff's comment as follows:

 Note 8. Prepaid Expenses and Other Assets, Net, page F-35

 2.
 It appears that the receivable from SY Media is required to be eliminated from your December 31, 2024 and March 31, 2025 consolidated financial statements. Based on your disclosures on pages F-11 and F-49, it appears that SY Media is a consolidated entity.

 Response: Please be advised that we have
amended the disclosures on page F-35 of the 10-K/A per the Staff's comment as follows:

 December 31, 2024
 December 31, 2023

 $
 $

 Prepaid Expenses
 43,158
 7,795

 Other receivables from third party
 600,011
 2,570

 Prepaid expenses and other assets, net
 643,169
 10,365

 Other receivables as of December 31, 2024 and
2023 were $643,169 and $10,365, respectively. Other receivables include e-commerce live stream receivables for goods and e-commerce sales
deposit.

 Other receivables from third parties primarily
include employee loans totaling $361,830, issued on December 31, 2023; March 1, 2024; June 1, 2024; September 1, 2024; and October 1,
2024. Additionally, the balance includes e-commerce livestream sales deposits of $6,530, recorded on December 31, 2023; June 1, 2024;
and August 1, 2024. A balance of $176,283 is due from third party of SY Media in connection with the Company's livestream events,
recorded on June 1, 2024. These receivables are expected to be collected in accordance with normal payment cycles and are considered part
of ongoing operations. A further $5,659 relates to prior-year receivables from GZ GSI for fish sales in China, originally recognized on
December 1, 2021.

 Note 25. Segment Reporting, page
F-49

 3.
 Please revise to reconcile the total of the aggregate reportable segments' measures of profit or loss to your consolidated income before income taxes, in accordance with ASC 280-10-50-30(b). Please also ensure the total of the reportable segments' revenues are consistent with your consolidated revenues, as noted that total revenues for FY2024 presented as part of segment disclosures do not agree with what is presented on the income statement for the same period. Note also that the segment disclosures are also required in your interim financial statements including your March 31, 2025 Form 10-Q, See ASC 280-10-50-32.

 Response: Please be advised that we have
amended the disclosures on page F-49 of the 10-K/A and page 28 of the 10-Q/A per the Staff's comment as follows:

 The Company's CODM is responsible for reviewing
the results of operations and allocating resources across the Company's reportable segments, including Fish Trading and Catering
Services. These operating segments reflect the manner in which the CODM allocates resources and evaluates performance.

 These segments align with how management evaluates
performance and allocates resources. Segment performance is evaluated based on segment revenue and operating profit, which includes direct
costs and segment-specific general and administrative expenses and tax, but excludes corporate overhead and interest.

 2

 The summary of key information by segments for
the years ended December 31, 2024 and 2023 was as follows:

 For year ended December 31, 2024

 Sales of Fish Trading
 Sales of
Catering
 E-Commerce
 Total

 Revenue
 $ 16,574,440
 $ 168,853
 $ 269,839
 $ 17,013,132

 Cost of revenue
 $ 16,486,310
 $ 114,453
 $ 78,108
 $ 16,678,871

 Gross profit
 $ 88,130
 $ 54,400
 $ 191,731
 $ 334,261

 General and administrative expenses
 $ (447,742 )
 $ (597,774 )
 $ (1,089,820 )
 $ (2,135,336 )

 Segment operating losses
 $ (359,612 )
 $ (543,374 )
 $ (898,089 )
 $ (1,801,075 )

 Income tax expenses
 $ (121,575 )
 $ (2,495 )
 $ –
 $ (124,070 )

 Segment losses
 $ (481,187 )
 $ (545,869 )
 $ (898,089 )
 $ (1,925,145 )

 For year ended December 31, 2023

 Sales of Fish Trading
 Sales of
Catering
 Total

 Revenue
 $ 23,713,516
 $ 202,410
 $ 23,915,926

 Cost of revenue
 $ 23,558,911
 $ 162,056
 $ 23,720,967

 Gross profit
 $ 154,605
 $ 40,354
 $ 194,959

 General and administrative expenses
 $ (1,052,507 )
 $ (1,293,816 )
 $ (2,346,323 )

 Segment operating losses
 $ (897,965 )
 $ (1,253,462 )
 $ (2,151,364 )

 Income tax expenses
 $ –
 $ –
 $ –

 Segment losses
 $ (897,965 )
 $ (1,253,462 )
 $ (2,151,364 )

 The following tables set forth a summary of single
customers who represent 10% or more of the Company's segments revenue, net:

 Fish Trading

 December 31, 2024
 December 31, 2023

 Percentage of fish trading revenue

 Customer A
 18.90%
 19.90%

 Customer B
 16.40%
 26.50%

 Customer C
 11.40%
 10.50%

 Customer D
 16.50%
 13.20%

 Customer E
 16.50%
 –

 Customer F
 –
 11.40%

 79.7%
 81.50%

 3

 Catering

 December 31, 2024
 December 31, 2023

 Percentage of catering revenue

 Customer G
 11.11%
 49.19%

 Customer H
 11.92%
 40.69%

 Customer I
 52.41%
 –

 75.44%
 89.89%

 E--commerce

 December 31, 2024
 December 31, 2023

 Percentage of e-commerce revenue

 Customer J
 26.36%
 –

 26.36%
 –

 Effective as of January 1, 2024, the Company adopted
ASU 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures. The Company's Chief Operating Decision
Maker ("CODM") is its Executive Director, Song-Yuan Teng, who is responsible for reviewing the results of operations and allocating
resources across the Company's reportable segments, including Fish Trading and Catering Services. These operating segments reflect
the manner in which the CODM allocates resources and evaluates performance.

 These segments align with how management evaluates
performance and allocates resources. Segment performance is evaluated based on segment revenue and operating profit, which includes direct
costs and segment-specific general and administrative expenses and tax, but excludes corporate overhead and interest.

 The summary of key information by segments for
the three months ended March 31, 2025 and 2024 was as follows:

 For three months ended March 31, 2025

 Sales of Fish Trading
 Sales of
Catering
 E-Commerce
 Total

 Revenue
 $ 4,474,206
 $ 2,089
 $ 57,833
 $ 4,534,128

 Cost of revenue
 $ 4,465,209
 $ 1,567
 $ 16,402
 $ 4,483,178

 Gross profit
 $ 8,997
 $ 522
 $ 41,431
 $ 50,950

 General and administrative expenses
 $ (60,323 )
 $ (195,407 )
 $ (78,641 )
 $ (334,371 )

 Segment operating losses
 $ (51,326 )
 $ (194,885 )
 $ (37,210 )
 $ (283,421 )

 Income tax expenses
 $ –
 $ –
 $ –
 $ –

 Segment losses
 $ (51,326 )
 $ (194,885 )
 $ (37,210 )
 $ (283,421 )

 4

 For three months ended March 31, 2024

 Sales of Fish Trading
 Sales of
Catering
 E-Commerce
 Total

 Revenue
 $ 4,764,517
 $ 86,373
 $ 48,990
 $ 4,899,880

 Cost of revenue
 $ 4,754,614
 $ 43,989
 $ 17,316
 $ 4,815,919

 Gross profit
 $ 9,903
 $ 42,384
 $ 31,674
 $ 83,961

 General and administrative expenses
 $ (27,955 )
 $ (166,429 )
 $ (257,080 )
 $ (451,464 )

 Segment operating losses
 $ (18,052 )
 $ (124,045 )
 $ (225,406 )
 $ (367,503 )

 Income tax expenses
 $ (124,146 )
 $ –
 $ –
 $ (124,146 )

 Segment losses
 $ (142,198 )
 $ (124,045 )
 $ (225,406 )
 $ (491,649 )

 The following tables set forth a summary of single
customers who represent 10% or more of the Company's segments revenue, net:

 Fish Trading

 March 31, 2025
 March 31, 2024

 Percentage of fish trading revenue

 Customer A
 21.47%
 37.45%

 Customer B
 24.25%
 –

 Customer C
 18.42%
 –

 Customer D
 20.50%
 10.01%

 Customer E
 –
 18.21%

 Customer F
 –
 15.35%

 84.65%
 81.01%

 Catering

 March 31, 2025
 March 31, 2024

 Percentage of catering revenue

 Customer G
 83.99%
 –

 83.99%
 –

 5

 4.
 Please disclose the amount of revenue from any single customer that exceeded 10% of consolidated revenue in 2024 and/or 2023. See ASC 280-10-50-42.

 Response: Please be advised that we have amended the disclosures
on page F-49 of the 10-K/A and page 28 of the 10-Q/A per the Staff's comment as follows:

 The Company's CODM is responsible for reviewing
the results of operations and allocating resources across the Company's reportable segments, including Fish Trading and Catering
Services. These operating segments reflect the manner in which the CODM allocates resources and evaluates performance.

 These segments align with how management evaluates
performance and allocates resources. Segment performance is evaluated based on segment revenue and operating profit, which includes direct
costs and segment-specific general and administrative expenses and tax, but excludes corporate overhead and interest.

 The summary of key information by segments for
the years ended December 31, 2024 and 2023 was as follows:

 For year ended December 31, 2024

 Sales of Fish Trading
 Sales of
Catering
 E-Commerce
 Total

 Revenue
 $ 16,574,440
 $ 168,853
 $ 269,839
 $ 17,013,132

 Cost of revenue
 $ 16,486,310
 $ 114,453
 $ 78,108
 $ 16,678,871

 Gross profit
 $ 88,130
 $ 54,400
 $ 191,731
 $ 334,261

 General and administrative expenses
 $ (447,742 )
 $ (597,774 )
 $ (1,089,820 )
 $ (2,135,336 )

 Segment operating losses
 $ (359,612 )
 $ (543,374 )
 $ (898,089 )
 $ (1,801,075 )

 Income tax expenses
 $ (121,575 )
 $ (2,495 )
 $ –
 $ (124,070 )

 Segment losses
 $ (481,187 )
 $ (545,869 )
 $ (898,089 )
 $ (1,925,145 )

 For year ended December 31, 2023

 Sales of Fish Trading
 Sales of
Catering
 Total

 Revenue
 $ 23,713,516
 $ 202,410
 $ 23,915,926

 Cost of revenue
 $ 23,558,911
 $ 162,056
 $ 23,720,967

 Gross profit
 $ 154,605
 $ 40,354
 $ 194,959

 General and administrative expenses
 $ (1,052,507 )
 $ (1,293,816 )
 $ (2,346,323 )

 Segment operating losses
 $ (897,965 )
 $ (1,253,462 )
 $ (2,151,364 )

 Income tax expenses
 $ –
 $ –
 $ –

 Segment losses
 $ (897,965 )
 $ (1,253,462 )
 $ (2,151,364 )

 6

 The following tables set forth a summary of single
customers who represent 10% or more of the Company's segments revenue, net:

 Fish Trading

 December 31, 2024
 December 31, 2023

 Percentage of fish trading revenue

 Customer A
 18.90%
 19.90%

 Customer B
 16.40%
 26.50%

 Customer C
 11.40%
 10.50%

 Customer D
 16.50%
 13.20%

 Customer E
 16.50%
 –

 Customer F
 –
 11.40%

 79.7%
 81.50%

 Catering

 December 31, 2024
 December 31, 2023

 Percentage of catering revenue

 Customer G
 11.11%
 49.19%

 Customer H
 11.92%
 40.69%

 Customer I
 52.41%
 –

 75.44%
 89.89%

 E--commerce

 December 31, 2024
 December 31, 2023

 Percentage of e-commerce revenue

 Customer J
 26.36%
 –

 26.36%
 –

 Effective as of January 1, 2024, the Company adopted
ASU 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures. The Company's Chief Operating Decision
Maker ("CODM") is its Executive Director, Song-Yuan Teng, who is responsible for reviewing the results of operations and allocating
resources across the Company's reportable segments, including Fish Trading and Catering Services. These operating segments reflect
the manner in which the CODM allocates resources and evaluates performance.

 These segments align with how management evaluates
performance and allocates resources. Segment performance is evaluated based on segment revenue and operating profit, which includes direct
costs and segment-specific general and administrative expenses and tax, but excludes corporate overhead and interest.

 7

 The summary of key information by segments for
the three months ended March 31, 2025 and 2024 was as follows:

 For three months ended March 31, 2025

 Sales of Fish Trading
 Sales of
Catering
 E-Commerce
 Total

 Revenue
 $ 4,474,206
 $ 2,089
 $ 57,833
 $ 4,534,128

 Cost of revenue
 $ 4,465,209
 $ 1,567
 $ 16,402
 $ 4,483,178

 Gross profit
 $ 8,997
 $ 522
 $ 41,431
 $ 50,950

 General and administrative expenses
 $ (60,323 )
 $ (195,407 )
 $ (78,641 )
 $ (334,371 )

 Segment operating losses
 $ (51,326 )
 $ (194,885 )
 $ (37,210 )
 $ (283,421 )

 Income tax expenses
 $ –
 $ –
 $ –
 $ –

 Segment losses
 $ (51,326 )
 $ (194,885 )
 $ (37,210 )
 $ (283,421 )

 For three months ended March 31, 2024

 Sales of Fish Trading
 Sales of
Catering
 E-Commerce
 Total

 Revenue
 $ 4,764,517
 $ 86,373
 $ 48,990
 $ 4,899,880

 Cost of revenue
 $ 4,754,614
 $ 43,989
 $ 17,316
 $ 4,815,919

 Gross profit
 $ 9,903
 $ 42,384
 $ 31,674
 $ 83,961

 General and administrative expenses
 $ (27,955 )
 $ (166,429 )
 $ (257,080 )
 $ (451,464 )

 Segment operating losses
 $ (18,052 )
 $ (124,045 )
 $ (225,406 )
 $ (367,503 )

 Income tax expenses
 $ (124,146 )
 $ –
 $ –
 $ (124,146 )

 Segment losses
 $ (142,198 )
 $ (124,045 )
 $ (225,406 )
 $ (491,649 )

 The following tables set forth a summary of single
customers who represent 10% or more of the Company's segments revenue, net:

 Fish Trading

 March 31, 2025
 March 31, 2024

 Percentage of fish trading revenue

 Customer A
 21.47%
 37.45%

 Customer B
 24.25%
 –

 Customer C
 18.42%
 –

 Customer D
 20.50%
 10.01%

 Customer E
 –
 18.21%

 Customer F
 –
 15.35%

 84.65%
 81.01%

 8

 Catering

 March 31, 2025
 March 31, 2024

 Percentage of catering revenue

 Customer G
 83.99%
 –

 83.99%
 –

 We appreciate the opportunity to respond to your
comments. If you have further comments or questions, we stand ready to respond as quickly as possible. If you wish to contact us directly
you can reach us via Ross D. Carmel, Esq. of Sichenzia Ross Ference Carmel LLP at 646-838-1310.

 Sincerely,

 Nocera, Inc.

 By:
 /s/ Andy Ching-An Jin

 Chief Executive Officer

 cc: Ross D. Carmel, Esq.

 Sichenzia Ross Ference Carmel LLP

 9