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February 14, 2023
Jianjun Zhong
President and Chief Executive Officer
Kenongwo Group US, Inc.
Yangjia Group, Xiaobu Town
Yuanzhou District, Yichun City
Jiangxi Province, China 336000
Re:Kenongwo Group US, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Response dated February 2, 2023
File No. 333-239929
Dear Jianjun Zhong:
            We have reviewed your February 2, 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
December 9, 2022 letter.
Correspondence filed January 13, 2023
Item 1. Business, page 1
1.We note your response to our prior comment 1 and reissue. At the onset of Part I, please
disclose prominently that you are not a Chinese operating company but a Nevada holding
company with operations conducted by your subsidiary in China.

 FirstName LastNameJianjun Zhong
 Comapany NameKenongwo Group US, Inc.
 February 14, 2023 Page 2
 FirstName LastName
Jianjun Zhong
Kenongwo Group US, Inc.
February 14, 2023
Page 2
2.We note your response to our prior comment 2 and reissue it in part. Provide prominent
disclosure about the legal and operational risks associated with being based in or having
the majority of the company’s operations in China. We also note your statements in your
response to comment 2 that “[y]our research direction is beneficial to Chinese agriculture
and even the world’s agriculture” and that “[y]our company’s products are not only
welcomed by [y]our customers, but also supported and helped by the local government in
China.” Please explain the basis of each of these claims. Furthermore, please clarify how
your research is “beneficial to Chinese agriculture” as well as how your products are
“supported and helped by the local government in China.”
3.We note your response to our prior comment 3 and reissue. Please prominently disclose
whether your auditor is subject to the determinations announced by the PCAOB on
December 16, 2021 and whether and how the Holding Foreign Companies Accountable
Act and related regulations will affect your company.
4.We note your response to our prior comment 4 and resissue in part. Please provide a clear
description in Item 1 of how cash is transferred through your organization. Quantify any
cash flows and transfers of other assets by type that have occurred between the holding
company and its subsidiary, and direction of transfer. Quantify any dividends or
distributions that the subsidiary have made to the holding company, and its tax
consequences. Your disclosure should make clear if no transfers, dividends, or
distributions have been made to date. Describe any restrictions on foreign exchange and
your ability to transfer cash between entities and across borders. Describe any restrictions
and limitations on your ability to distribute earnings from the company, including your
subsidiary, to the parent company.
5.We note your response to our prior comment 5 and reissue. Disclose each permission or
approval that you or your subsidiary are required to obtain from Chinese authorities to
operate your business and to offer securities to foreign investors. State whether you or
your subsidiary are covered by permissions requirements from the China Securities
Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) in
particular, or any other governmental agency that is required to approve your operations,
and state affirmatively whether you have received all requisite permissions or approvals
and whether any permissions or approvals have been denied.  If you or your subsidiary are
not required to obtain any permissions or approvals from Chinese authorities to operate
your business and to offer securities to foreign investors, then please revise to state this
explicitly. If you are not required to obtain permissions requirements or approvals from
the CSRC and CAC or any other governmental agency please revise to state this
explicitly. Please also describe the consequences to you and your investors if you or your
subsidiary: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such permissions or approvals are not required, or (iii) applicable laws,
regulations, or interpretations change and you are required to obtain such permissions or
approvals in the future. Please note that (ii) and (iii) must be disclosed regardless of
whether or not you currently hold permissions or approvals.

 FirstName LastNameJianjun Zhong
 Comapany NameKenongwo Group US, Inc.
 February 14, 2023 Page 3
 FirstName LastName
Jianjun Zhong
Kenongwo Group US, Inc.
February 14, 2023
Page 3
Item 1A. Risk Factors, page 11
6.We note your response to our prior comment 6 and reissue. In your summary of risk
factors, disclose the risks that your corporate structure and being based in or having the
majority of the company’s operations in China poses to investors. In particular, describe
the significant regulatory, liquidity, and enforcement risks. For example, specifically
discuss risks arising from the legal system in China, including risks and uncertainties
regarding the enforcement of laws and that rules and regulations in China can change
quickly with little advance notice; and the risk that the Chinese government may intervene
or influence your operations at any time, or may exert more control over offerings
conducted overseas and/or foreign investment in China-based issuers, which could result
in a material change in your operations and/or the value of your securities. Acknowledge
any risks that any actions by the Chinese government to exert more oversight and control
over offerings that are conducted overseas and/or foreign investment in China-based
issuers could significantly limit or completely hinder your ability to offer or continue to
offer securities to investors and cause the value of your securities to significantly decline
or be worthless
7.We note your response to our prior comment 7 and reissue it. Given the Chinese
government’s significant oversight and discretion over the conduct of your business,
please revise to highlight separately the risk that the Chinese government may intervene or
influence your operations at any time, which could result in a material change in your
operations and/or the value of your securities. Also, given recent statements by the
Chinese government indicating an intent to exert more oversight and control over
offerings that are conducted overseas and/or foreign investment in China-based issuers,
acknowledge the risk that any such action could significantly limit or completely hinder
your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.
8.We note your statements that "[y]our company is doing the right thing" and "[y]our
company is not contrary to China's national policy." Please revise to provide your basis
for these statements.
9.We note your response to our prior comment 8 and reissue it. In light of recent events
indicating greater oversight by the Cyberspace Administration of China (CAC) over data
security, particularly for companies seeking to list on a foreign exchange, please revise
your disclosure to explain how this oversight impacts your business and your ability to
offer securities to investors and to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date. If you do not believe you
are subject to CAC oversight, please revise your disclose to state so explicitly.

 FirstName LastNameJianjun Zhong
 Comapany NameKenongwo Group US, Inc.
 February 14, 2023 Page 4
 FirstName LastName
Jianjun Zhong
Kenongwo Group US, Inc.
February 14, 2023
Page 4
General
10.We note your response to our prior comment 10. In your discussion of the enforceability
of civil liabilities against foreign persons please revise to explicitly address judgments
obtained in U.S. courts as required by Item 101(g)(1)(ii) and (iii) of Regulation S-K, as
required by Item 1 of Form 10-K.
11.With respect to your disclosure regarding all risks related to doing business in China,
please ensure that your disclosure does not suggest there are mitigating factors regarding
the nature of your relationship with the Chinese government, the manner in which you are
regulated, or the degree to which your operations could be affected by economic,
industrial, or other policies in China.
            You may contact Michael Fay at 202-551-3812 or Brian Cascio at 202-551-3676 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jordan Nimitz at 202-551-5831 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       John Lowy, Esq.