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September 15, 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.
Amendment No. 2 to Form 10-K for the Fiscal Year Ended December 31, 2021
Filed August 14, 2023
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed June 27, 2023
File No. 333-239929
Dear Jianjun Zhong:
            We have reviewed your August 14, 2023 response to our comment letter and filings 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 April 6,
2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9.A. Controls and Procedures
Internal Control over Financial Reporting and Attestation Report of Registered Public
Accounting Firm, page 47
1.We reference your disclosure in Item 9.A that the annual report does not include a report
of management’s assessment regarding internal control over financial reporting  (ICFR)
due to a transition period established by the Commission for newly public
companies. Instruction 1 to Item 308 of Regulation S-K permits management to exclude
its assessment of ICFR only in its first annual report filing and this is your third Form 10-

 FirstName LastNameJianjun Zhong
 Comapany NameKenongwo Group US, Inc.
 September 15, 2023 Page 2
 FirstName LastName
Jianjun Zhong
Kenongwo Group US, Inc.
September 15, 2023
Page 2
K.  Please amend your filing to provide the disclosures required by Item 308 with regard
to ICFR.  Also refer to your response to comment 9 as part of your February 2, 2023
response letter, which set forth that you would make the appropriate correction.
Amendment No. 2 to Form 10-K for the Fiscal Year Ended December 31, 2021
Item 1. Business, page 1
2.We note your revised disclosure in response to our prior comment 1 that the legal and
operational risks associated with being based in or having the majority of the operations in
China could result in “a material change in the Company’s operations.” Please also revise
to reinstate the deleted disclosure on page 2 that such risks may result in a material change
in the value of the securities you are registering for sale and could “significantly limit or
completely hinder [y]our ability to offer to continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.” Please also
revise your disclosure in your Form 10-K for the fiscal year ended December 31, 2022
accordingly.
3.We note your revised disclosure in response to our prior comment 3, which we reissue in
part. Please revise to disclose any restrictions and limitations on your ability to distribute
earnings from the company, including your subsidiary, to the parent company. We note
that you have included a summary risk factor on page 18 that “Transferring cash out of the
PRC could face restriction or taxation on the Company.” Please ensure that you have
included a separate risk factor, as we do not see a risk factor with this heading in your
current filing. Please also revise your Form 10-K for the fiscal year ended December 31,
2022 to include the revised disclosures accordingly.
4.We note your revised disclosure in response to our prior comment 4, which we reissue in
part. If true, please revise to disclose that your determination not to obtain the advice of
counsel is based on a risk-based analysis and include a related risk factor
disclosure. Please revise to explicitly address the consequences to your investors
specifically if you do not receive or maintain the necessary permissions or approvals,
inadvertently conclude that such permissions or approvals are not required or applicable
laws, regulations or interpretations change and your are required to obtain such
permissions in the future. Please also ensure the revised disclosures are included in your
Form 10-K for the fiscal year ended December 31, 2022 accordingly.
Enforceability of Civil Liabilities, page 8
5.We note your revised disclosure in response to our prior comment 5 that shareholders will
have difficulty bringing an action in the PRC. Please revise to explicitly address the
investor’s ability to enforce judgments obtained in U.S. courts in an appropriate foreign
court. Please also revise your Form 10-K for the fiscal year ended December 31, 2022
accordingly.

 FirstName LastNameJianjun Zhong
 Comapany NameKenongwo Group US, Inc.
 September 15, 2023 Page 3
 FirstName LastName
Jianjun Zhong
Kenongwo Group US, Inc.
September 15, 2023
Page 3
Item 1A. Risk Factors, page 17
6.We note your revisions in response to our prior comment 7. Please also revise your Form
10-K for the fiscal year ended December 31, 2022 to include the two additional risks
factors.
7.We note your revised disclosure in response to our prior comment 8, including the
summary risk factor on page 18 with the heading “We may be or become subject to
regulation by the CAC.” Please ensure that you have included a separate risk factor, as we
do not see a risk factor with this heading in your current filing. Please also revise your
Form 10-K for the fiscal year ended December 31, 2022 to include the revised disclosures
accordingly.
General
8.We note your revised disclosure in response to our prior comment 9. Please also revise
your Form 10-K for the fiscal year ended December 31, 2022 accordingly.
9.We note your revised disclosure in response to our prior comment 10, which we reissue in
part. We note that the revised disclosure still includes references that indicate that this is a
prospectus and an offering is taking place on pages 3, 4 and 5. Please also revise your
Form 10-K for the fiscal year ended December 31, 2022 accordingly.
10.We note your revised disclosure in response to our prior comment 11, which we reissue in
part. Please revise to explicitly address whether the Trial Measures will apply to you with
respect to offerings you may conduct. Please also revise your Form 10-K for the fiscal
year ended December 31, 2022 accordingly.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            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 Jane Park at 202-551-7439 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Matthew McMurdo, Esq.