SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 9, 2025

Ivy Zhen
Chief Financial Officer
MicroCloud Hologram Inc.
Room 302, Building A, Zhong Ke Na Neng Building,
Yue Xing Sixth Road, Nanshan District,
Shenzhen, People's Republic of China 518000

 Re: MicroCloud Hologram Inc.
 Form 20-F for the fiscal year ended December 31, 2024
 Response dated May 30, 2025
 File No. 001-40519
Dear Ivy Zhen:

 We have reviewed your May 30, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our May 20,
2025 letter.

Form 20-F for the fiscal year ended December 31, 2024
Results of Operations
General and administrative expenses, page 70

1. We note your response to prior comment 5. Please explain how the
"exercise" of
 shares issued pursuant to the 2023 Equity Incentive Plan resulted in the
recognition of
 compensation expense. In your response tell us the type of awards issued
in both
 fiscal 2023 and 2024 and the terms of such awards. Also, revise to
include disclosures
 pursuant to ASC 718-10-50-1 and 50-2 in future filings.
 June 9, 2025
Page 2
General

2. Please address the following as it relates to your response to prior
comment 6:
 Tell us the date on which the company determined that Tiger
Initiative Investment
 Ltd (Tiger) and Lucky Monkey Holdings Limited (Lucky Monkey) would
receive
 Class B Ordinary shares and the exact date during fiscal 2025 when
such shares
 were issued to each entity.
 You state that the shares were allocated exclusively to Tiger and
Lucky Monkey
 in accordance with the Convertible Note Purchase Agreement and you
reference a
 Form 6-K filed on August 14, 2024. However, the terms of the
Agreement
 included in such filing do not refer to the issuance of Class B
Ordinary shares.
 Please explain.
 Tell us how you determined that only Tiger and Lucky Monkey would
receive
 Class B Ordinary shares in exchange for their convertible notes.
 Tell us whether there are any related party interests between Tiger
(including it's
 sole owner, Zongge Zhange), Lucky Monkey (including its sole owner,
Jiahui
 Lu), the company, and its officers and directors including Wei Peng,
the
 Chairman of the Board and if so, revise to disclose such
information. In this
 regard, we note as part of the Business Combination with Golden Path
 Acquisition, Tiger, Lucky Monkey and others gave their voting rights
to Best
 Road Holdings Limited, an entity owned by Wei Peng.

 Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at
202-551-
3499 if you have questions regarding comments on the financial statements and
related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
</DOCUMENT>