SecProbe.io

May 20, 2019
Wenshan Xie
Chief Executive Officer
E-Home Household Service Holdings Ltd
Floor 9, Building 14, HaixiBaiyue Town
No. 14 Duyuan Road, Luozhou Town
Cangshan District, Fuzhou City 350001
People’s Republic of China
Re:E-Home Household Service Holdings Ltd.
Amended Draft Registration Statement on Form F-1
Submitted May 10, 2019
CIK No. 0001769768
Dear Mr. Xie:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.  Our references to prior comments are to comments in our April 10, 2019 letter.
Form DRS/A filed May 10,2019
Prospectus Summary, page 1
1.In your response to our prior comment 2, you disclose that “[r]egistered members are
those customers who followed our WeChat official account and provided their profiles,
including their phone numbers or WeChat User IDs.”  Please revise to clarify why you
believe the number of registered members is a useful metric and how it relates to your
generation of revenues.  For example, disclose the number of registered users who were
paying customers and used your services in each period discussed.

 FirstName LastNameWenshan Xie
 Comapany NameE-Home Household Service Holdings Ltd
 May 20, 2019 Page 2
 FirstName LastName
Wenshan Xie
E-Home Household Service Holdings Ltd
May 20, 2019
Page 2
Use of Proceeds, page 32
2.We note your disclosure in response to our prior comment 4.  To provide context, please
quantify how much of your net offering proceeds would likely be available for investment
in your PRC operations. For example, quantify the current statutory limits on your ability
to loan or make capital contributions to your PRC subsidiary and to make loans to your
VIEs. Also disclose, if true, that you expect the IPO proceeds to be used in China in the
form of RMB and, therefore, your PRC subsidiary, VIEs and their subsidiaries will need
to convert any capital contributions or loans from U.S. dollars to RMB.

Financial Statments, page F-1
3.We note your response to comment 11 however, we continue to believe you should
provide condensed financial statements of the registrant required by 12-04 of Regulation
S-X.
Revenue Recognition, page F-12
4.We note in your response to comment 14, the Company is obligated to provide market
development and to provide customer information to the service outlet.  Please explain to
us the nature of the Company's performance obligations to the home appliance services
and housekeeping services end customers.  Tell us if the end customer believes they have
engaged the Company or the service outlet to perform the service.  In this regard, tell us if
the end customer contracts separately with the service outlet.  If not, explain how the end
customer and the service outlet reach an understanding with respect to the services that are
to be performed.  Also, explain how disputes concerning the quality of service
are resolved between the service outlet, the Company, and the end customer.
5.We note in your response to comment 14 the service outlet is responsible for
collection.  Tell us if the Company has an obligation to pay the service outlet in the event
they are unable to collect from the end customer.  Also, tell us if the service outlet is
obligated to pay the Company in the event they are unable to collect from the end
customer.
Note 3 - Accounts Receivable, Net, page F-16
6.We note in your response to comment 14 the service outlet is responsible for collection.
Please indicate in this footnote the amount of account receivable that is due from your
service outlets and the amount due from the end customer.  Also, with respect to the
amount of receivables due from your service outlet, please clarify if the
accounts receivable is stated net of the amount of any fee due to the service outlet, i.e.
stated in the amount of cash you anticipate will ultimately be collected.

 FirstName LastNameWenshan Xie
 Comapany NameE-Home Household Service Holdings Ltd
 May 20, 2019 Page 3
 FirstName LastName
Wenshan Xie
E-Home Household Service Holdings Ltd
May 20, 2019
Page 3
Consolidated Statements of Changes in Shareholders' Equity, page F-27
7.Please provide us a detailed reconciliation of the opening balance of retained earnings of
$1,369,024 as of June 30, 2016 and the June 30, 2016 year-end balance reported in the
Company's financial statements filed with the Shanghai Equity Exchange.
Consolidated Statements of Cash Flows, page F-28
8.Please provide us a detailed reconciliation of the amount of cash and cash equivalents at
beginning of fiscal year 2017 of $2,770,719 and the June 30, 2016 year-end balance
reported in the Company's financial statements filed with the Shanghai Equity Exchange.
General
9.In response to our prior comment 18, you provided supplemental materials that are in
Chinese with only portions translated to English.  Please provide us with fully translated
copies so that we may better evaluate the materials.
            You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Robert S.
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Greg Dundas, Staff
Attorney, at (202) 551-3436 or Kathleen Krebs, Special Counsel, at (202) 551-3350  with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Telecommunications