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United States securities and exchange commission logo
April 18, 2024
Kang Liping
Chief Financial Officer
Longduoduo Co Ltd
419 Floor 4 Comprehensive Building
Second Light Hospital, Ordos Street
Yuquan District, Hohhot
Inner Mongolia, China
Re:Longduoduo Co Ltd
Dear Kang Liping:
            We have reviewed your filing and have the following comment(s).
            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.
Form 10-K for the Year Ended June 30, 2023
Part I
Item 1. Business, page 1
1.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 subsidiaries.
2.Please 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. Your
disclosure should make clear whether these risks could result in a material change in your
operations and/or the value of your securities or 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. Your disclosure should address
how recent statements and regulatory actions by China’s government, such as those
related to data security or anti-monopoly concerns, have or may impact the company’s
ability to conduct its business, accept foreign investments, or list on a U.S. or other
foreign exchange.
3.Please revise your disclosure in Item 1 to disclose the location of your auditor’s

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headquarters and whether and how the Holding Foreign Companies Accountable Act, as
amended by the Consolidated Appropriations Act, 2023, and related regulations will affect
your company.
4.Please provide a clear description of how cash is transferred through your organization.
Disclose your intentions to distribute earnings. Quantify any cash flows and transfers of
other assets by type that have occurred between the holding company and its subsidiaries,
and direction of transfer. Quantify any dividends or distributions that a subsidiary have
made to the holding company and which entity made such transfer, and their tax
consequences. Similarly quantify dividends or distributions made to U.S. investors, the
source, and their 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, across borders, and to U.S.
investors. Describe any restrictions and limitations on your ability to distribute earnings
from the company, including your subsidiaries, to the parent company and U.S. investors.
5.Please disclose each permission or approval that you or your subsidiaries are required to
obtain from Chinese authorities to operate your business and to offer securities to foreign
investors. State whether you or your subsidiaries are covered by permissions requirements
from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of
China (CAC) 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. Please also
describe the consequences to you and your investors if you or your subsidiaries: (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.
6.Please revise to include a summary of the risk factors section pursuant to Item 105(b) of
Regulation S-K. In the 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.

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 FirstName LastNameKang Liping
Longduoduo Co Ltd
April 18, 2024
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Item 1A. Risk Factors
Risks Related to Doing Business in the PRC, page 13
7.Given the Chinese government’s significant oversight and discretion over the conduct and
operations of your business, please revise to describe any material impact that
intervention, influence, or control by the Chinese government has or may have on your
business or on the value of your securities. 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.  We remind you
that, pursuant to federal securities rules, the term “control” (including the terms
“controlling,” “controlled by,” and “under common control with”) means “the possession,
direct or indirect, of the power to direct or cause the direction of the management and
policies of a person, whether through the ownership of voting securities, by contract, or
otherwise.
Because our principal assets are located outside of the United States and because all of our
directors and all our officers reside outside, page 14
8.We note your disclosure here that "[a]ll of your present officers and directors reside
outside of the United States. Please identify each officer and/or director located in China
or Hong Kong and disclose that it will be more difficult to enforce liabilities and enforce
judgments on those individuals. Please also revise to disclose all of the enforcement risks
related to civil liabilities due to your officers and directors being located in China or Hong
Kong. For example, revise to discuss more specifically the limitations on investors being
able to effect service of process and enforce civil liabilities in China, lack of reciprocity
and treaties, and cost and time constraints.

The recent joint statement by the SEC and PCAOB and the Holding Foreign Companies
Accountable Act all call for additional..., page 14
9.We note your disclosure about the Holding Foreign Companies Accountable Act. Please
expand your risk factors to disclose that the Holding Foreign Companies Accountable Act,
as amended by the Consolidated Appropriations Act, 2023, decreases the number of
consecutive “non-inspection years” from three years to two years, and thus, reduces the
time before your securities may be prohibited from trading or delisted. Update your
disclosure to describe the potential consequences to you if the PRC adopts positions at any
time in the future that would prevent the PCAOB from continuing to inspect or investigate
completely accounting firms headquartered in mainland China or Hong Kong.
Report of Independent Registered Public Accounting Firm , page F-3
10.Note 1 on page F-9 indicates that on September 21, 2023, the Company implemented a 1-
for-10 reverse split of its outstanding common stock, effective at the close of business on
September 26, 2023. The accompanying financial statements have been adjusted to

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 Comapany NameLongduoduo Co Ltd
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 FirstName LastName
Kang Liping
Longduoduo Co Ltd
April 18, 2024
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retroactively reflect this reverse stock split. Given the retroactive presentation of this
reverse split, it appears that KCCW Accountancy Corp.'s audit report dated October 13,
2022 must be updated. Please request KCCW Accountancy Corp. to address this matter.
            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.
            Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters. Please
contact Conlon Danberg at 202-551-4466 or Jessica Ansart at 202-551-4511 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services