SecProbe.io

CORRESP
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filename1.htm

Meiwu Technology Company Limited

1602,
Building C, Shenye Century Industrial Center

No.
743 Zhoushi Road, Hangcheng Street,

Bao’an
District,

Shenzhen,
People’s Republic of China

November
18, 2024

VIA
EDGAR

Aliya
Ishmukhamedova

Jan
Woo

Division
of Corporation Finance

Office
of Technology

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:

    Meiwu
    Technology Company Limited

    Registration
    Statement on Form F-1

    Filed
    October 25, 2024

    File
    No. 333-282379

Ladies
and Gentlemen:

Meiwu
Technology Company Limited (“we” or the “Company”) is hereby providing responses to comments of the Staff (the
“Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) issued on November 7, 2024 regarding the
Company’s Amendment No. 1 to Registration Statement on Form F-1 that was filed with the Commission on October 25, 2024 (the “Staff’s
Letter”).

Amendment
No. 1 to Registration Statement on Form F-1

Cover
Page

    1.
    Please
    revise the cover page and the Plan of Distribution to indicate the price at which Changbin Xia, the Chairman of the company, will
    offer the 30 million ordinary shares for resale. We note your disclosure that Mr. Xia will sell the ordinary shares on behalf of
    the company as well as himself. Clarify whether Mr. Xia will simultaneously offer and sell the shares by the company and the shares
    he holds in his personal capacity. If so, disclose any conflicts of interest.

RESPONSE:
In response to the Staff’s comment, we respectfully revised on the cover page and the Plan of Distribution to disclose that
the Chairman may sell his shares at prevailing market prices or privately negotiated prices, at prevailing market prices at the time
of the sale, at varying prices determined at the time of sale or at negotiated prices. In addition, Mr. Xia will enter into a certain
lock-up agreement with the Company on the effective date of the registration statement, pursuant to which, he will not sell his shares
for a period of 180 days following the effective date. Therefore, Mr. Xia will not simultaneously offer and sell the shares by the Company
and the shares he holds in his personal capacity. He will begin selling his shares after the closing of the Company’s primary offering.
As a result, we believe there will not be a conflict of interest. We revised on the Cover Page and the Plan of Distribution accordingly
to disclose this.

********

If
you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing please don’t hesitate
to contact us.

    Sincerely,

    Meiwu
    Technology Company Limited

    By:

    /s/
    Changbin Xia

    Name:
    Changbin
    Xia

    Title:

    Chairman