SecProbe.io

CORRESP
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   - Filed by EDGARhub LLC

CARRIAGE HOUSE EVENT
CENTER, INC.
Tian’an Science Park, Tower 23,
20th Floor
Panyu District, Guangzhou 510006

People’s Republic of China

May 12, 2025

United States Securities and Exchange Commission

Division of Corporation Finance
100 F Street, NE
Washington, D.C.
20549

    Attention:
    Blake Grady

    Nicholas Panos

    Re
    Carriage House Event Center, Inc.

    Schedule 13D filed February 11, 2025 by
      Zhonghe Brand Ltd. et al.

    File No. 005-94851

Gentlemen,

Zhonghe Brand, Ltd. and Lei He submit this letter in connection
with their filing today of Amendment No. 1 to the Schedule 13D filed by them on
February 11, 2025 (the “Schedule 13D Amendment”). Set forth below
in italics you will find copies of the Staff’s comments from its letter dated
April 21, 2025 (the “Comment Letter”) followed by responses,
including as responsive disclosure within the Schedule 13D Amendment.

Schedule 13D filed February 11, 2025

General

      1.

      We note that the event reported as requiring the filing
      of the Schedule 13D was January 22, 2025. Rule 13d-1(a) of Regulation 13D-
      G requires the filing of a Schedule 13D within five business days after
      the date beneficial ownership of more than five percent of a class of
      equity securities specified in Rule 13d-1(i)(1) was acquired. Based on the
      January 22, 2025 event date, the Schedule 13D submitted on February 11,
      2025 was not timely filed. Please advise us why the Schedule 13D was not
      filed within the required five business days after the date of the
      acquisition.

Response to Comment 1

When my negotiations to acquire the control interest in
Carriage House Event Center, Inc. (the “Issuer”) commenced, I
engaged U.S. securities counsel to represent Zhonghe Brand and me in all aspects
of the transaction. I anticipated that counsel would assist us in filing the
Schedule 13D and Form 3 after the acquisition. At the time of the acquisition,
however, I learned that counsel intended to charge a fee for those services that
I considered excessive. So I asked my U.S. representative to introduce a
securities attorney whose fee for those services would be reasonable. On
February 4, I engaged the attorney recommended by my U.S. representative. It
took several days of back-and-forth communications before my new attorney fully
understood the transactions, with the result that the Schedule 13D was not filed
until February 11.

Item 4, page 1

      2.

      Please amend Item 4 of the Schedule 13D to include any
      plans or proposals which relate to or would result in the enumerated items
      listed in subsections (a)-(j) of Item 4 of Schedule 13D. To the extent no
      plans or proposals that relate to or would result in any of the actions
      described in Item 4(a)-(j) exist, please affirmatively so state. See
      Instruction A within the “Special Instructions for Complying With Schedule
      13D” at Rule 13d-101 of Regulation 13D-G.

May 12, 2025
Page 2

Response to Comment 2

As requested, pursuant to Instruction A within the “Special
Instructions for Complying with Schedule 13D”, in the Schedule 13D Amendment at
Item 4, I have affirmatively stated that as of February 11, 2025 neither I nor
Zhongke Brand Ltd. was party to any plan or proposal that related to or would
result in an event of the types enumerated in subsections (a)-(j) of said Item
4.

Item 5, page 1

      3.

      We note your disclosure of "N.A." Item 5(c), however,
      requires that each beneficial owner "describe any transactions in the
      class of securities reported on that were effected during the past sixty
      days." Please revise to provide the requisite disclosure for each filing
      person with respect to all transactions in the securities between the
      deadline for timely filing the Schedule 13D and the actual filing of the
      Schedule 13D. In amending the Schedule 13D to include the required
      disclosures, please be advised that the Instruction to Item 5(c) requires
      the beneficial owner to "describe," at a minimum, the following: "(1) The
      identity of the person covered by Item 5(c) who effected the transaction;
      (2) the date of transaction; (3) the amount of securities involved; (4)
      the price per share or unit; and (5) where and how the transaction was
      effected."

Response to Comment 3

As requested, the Schedule 13D Amendment states in response to
Item 5(c): “Except for the acquisition of 4,150,000 shares of common stock on
January 22, 2025 reported herein, the Reporting Persons did not enter into any
transaction in the Common Stock of Carriage House Event Center, Inc. during the
sixty days preceding their filing of Schedule 13D on February 11, 2025.”

Item 7, page 1

      4.

      Multiple beneficial owners have reported their beneficial
      ownership on the above- captioned Schedule 13D. Whenever two or more
      persons are required to file a statement containing the information
      required by Schedule 13D, a single Schedule 13D may be filed provided that
      it includes, as an exhibit, their agreement in writing that such a
      statement is filed on behalf of each of them. Please revise to add the
      required exhibit, or advise. See Rule 13d-1(k)(1)(iii).

Response to Comment 4

As requested, an agreement in writing by Zhonghe Brand, Ltd.
and the undersigned pursuant to Rule 13d-1(k)(1)(iii) has been filed as an
exhibit to the Schedule 13D Amendment.

    Respectfully submitted,

    /s/ Lei He