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Epsium Enterprise
Limited

Alameda Dr. Carlos D’assumpcao Edf China Civil
Plaza 235-243 14 Andar P Macau

Tel (853) 2857 5232．Fax (853) 2857 5215

December 17, 2024

Via EDGAR

Ms. Rebekah Reed

Mr. Dietrich King

Division of Corporation Finance

Office of Financial Services

U.S. Securities and Exchange Commission

    Re:
    Epsium Enterprise Limited

Amendment No. 5 to Registration Statement
on Form F-1

Filed November 4, 2024

File No. 333-276313

Dear Ms. Reed and Mr. King:

This letter is in response to the letter dated
November 19, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Epsium Enterprise Limited (the “Company”, “we”, or “our”) relating
to Amendment No. 5 to Registration Statement on Form F-1 filed with the Commission on November 4, 2024 (the “Original Registration
Statement”) in connection with its application for a listing on the Nasdaq Capital Market (the “Proposed Listing”).
For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly. Amendment No. 6
to the Registration Statement on Form F-1 (“Amendment No. 6”) is being filed to accompany this letter.

Amendment No. 5 to Registration
Statement on Form F-1 filed November 4, 2024

Risk Factors

Risks Related to Our Business and Industry, page
15

 1. We note that your revenues for the six months ended June 30, 2024 declined 61.34%, attributed primarily
to “depression of economic activities in local market” and an “overall economic downturn result[ing] in reduced demand
for alcoholic beverages in Macau.” We further note your risk factor disclosure that your business “may be negatively affected
by various economic and social disruptions, including but not limited to a slowdown, recession, or inflationary pressures in the general
economy…These disruptions could result in reduced demand for the Operating Entity’s products…” Please update
where appropriate if recent inflationary pressures and economic conditions have materially impacted your operations. Identify the types
of inflationary pressures you are facing and how your business has been affected, as well as any actions planned or taken to mitigate
such pressures.

Response:

We acknowledge the Staff’s comments
and respectfully inform you that we have revised the Original Registration Statement as requested in Amendment No. 6.

Epsium Enterprise
Limited

Alameda Dr. Carlos D’assumpcao Edf China Civil
Plaza 235-243 14 Andar P Macau

Tel (853) 2857 5232．Fax (853) 2857 5215

Industry Overview, page 66

 2. Please update the description of the state of your industry for consistency with the results of operations
disclosure that there has been a “noticeable decrease in the demand for alcoholic beverages in Macau” and that a recent “overall
economic downtown” has caused “a serious contraction of the wholesale market for low-priced alcoholic beverages.” In
this regard, we note that much of the disclosure in this section is given as of 2022 or early 2023 and includes statements implying that
the market and demand for alcoholic beverages in Macau is continuing to grow (e.g., “As the economy recovers, the consumption of
alcoholic beverages in Macau is expected to increase…” and “[t]he growth trend likely correlates to the expansion of
the middle and upper classes in Macau and their ability and willingness to purchase high-end and craft alcoholic beverages…”).

Response:

We acknowledge the Staff’s comments and respectfully inform you
that we have revised the Original Registration Statement as requested in Amendment No. 6.

Underwriting, page 117

 3. Provide additional
                                            information as to why your disclosure and Sections 2.27 and 3.18 of the form of underwriting
                                            agreement filed as Exhibit 1.1 indicate that the lock-up arrangements applicable to the company,
                                            directors, officers, and holders of at least 5% of outstanding ordinary shares will be in
                                            favor only of EF Hutton, rather than both underwriters for the offering. Explain the purpose
                                            of this distinction, and clarify whether this is meant to suggest that EF Hutton will be
                                            able to unilaterally release such parties from their lock-up arrangements, and if so, why
                                            this was decided upon. In this regard, we note that Section 3.19 of the form of underwriting
                                            agreement suggests that EF Hutton will have the sole ability to waive the lock-up period,
                                            but the form of press release included within Exhibit 1.1 and description of lock-up agreements
                                            at page 119 are inconsistent on this point.

Response:

We acknowledge the Staff’s comments
and respectfully inform you that the indication of the lock-up arrangements being in favor only of EF Hutton in the Original Registration
Statement and Sections 2.27 and 3.18 of the form of underwriting agreement filed as Exhibit 1.1 thereto was a typographical error. Additionally,
EF Hutton has recently changed its name to D. Boral Capital LLC. As such, we have revised the Original Registration Statement to correct
the typographical error and updated EF Hutton’s name to D. Boral Capital LLC in Amendment No. 6.

We appreciate the assistance the Staff
has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Laura Hemmann, Esq., of iTKG Law
LLC, at (650) 799 2061.

Sincerely,

    /s/ Son I. Tam

    Name:
    Son I. Tam

    Title:
    Chief Executive Officer,

Chief Financial Officer, and Chairman

    cc:
    Laura Hemmann, Esq., iTKG Law LLC