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April 10, 2023
Wei Li
Chief Executive Officer
DongFang City Holding Group Company Limited
Level 15, Tower 2
Etiqa Twins Tower, No. 11
Jalan Pinang , Kuala Lumpur
50450
Re:DongFang City Holding Group Company Limited
Form 10-K for the Fiscal Year Ended October 31, 2021
Response dated March 16, 2023
File No. 000-56120
Dear Wei Li:
            We have reviewed your March 16, 2023 response to our comment letter 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
March 2, 2023 letter.
Response dated March 16, 2023
Item 1. Business, page 1
1.We note your response to comment 2.  Please expand your disclosure to to address the
legal and operational risks associated with Mr. Wei Li’s significant ties with China, even
if he is not based there.  Additionally, please revise to disclose whether and how the
Holding Foreign Companies Accountable Act, as amended by the Consolidated
Appropriations Act, 2023, and related regulations will affect your company.
2.We note your response to comment 3.  Please expand your disclosure in the forepart of the
business section to discuss the risks that Mr. Wei Li having significant ties with China

 FirstName LastNameWei Li
 Comapany NameDongFang City Holding Group Company Limited
 April 10, 2023 Page 2
 FirstName LastName
Wei Li
DongFang City Holding Group Company Limited
April 10, 2023
Page 2
poses to investors.  Additionally, please expand your risk factor disclosure in response to
comment 3 to discuss, if applicable, the risk that the Chinese government may intervene
or influence your operations at any time.
3.We note your response to comment 5.  Please revise your disclosure to include in the
forepart of the business section a separate section on enforcement of liabilities addressing
the ability of shareholders to enforce their legal rights under United States securities laws.
Please clearly identify those officers and directors who are located outside of the United
States, and address the ability of shareholders to enforce their legal rights under United
States securities laws against these officers and directors.  For example, revise to discuss
more specifically the limitations on investors being able to effect service of process and
enforce civil liabilities in Malaysia, lack of reciprocity and treaties, and cost and time
constraints.
General
4.We note from your response to prior comment 11 that you dismissed your independent
registered public accounting firm, YCM CPA Inc.  Please tell us your consideration for
filing Item 4.01 in Form 8-K to report this event that addresses all of the disclosure
requirements under that Item including providing the information required by Item 304 of
Regulation S-K.
            You may contact Isaac Esquivel at (202) 551-3395 or Shannon Menjivar at (202) 551-
3856 if you have questions regarding comments on the financial statements and related
matters.  Please contact Benjamin Holt at (202) 551-6614 or Jeffrey Gabor at (202) 551-2544
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction