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Correspondence 0001213900-24-076446 from Li Bang International Corp Inc. (LBGJ) (CIK 0001896425) (LBGJ)

Li Bang International Corp Inc. (LBGJ) (CIK 0001896425)
Date: Sept. 6, 2024 · CIK: 0001896425 · Accession: 0001213900-24-076446

AI Filing Summary & Sentiment

File numbers found in text: 333-262367

Referenced dates: September 3, 2024

Date
September 6, 2024
Author
Not clearly detected
Form
CORRESP
Company
Li Bang International Corp Inc. (LBGJ) (CIK 0001896425)

Letter

Via Edgar Correspondence Division of Corporation Finance Office of Technology Re: Li Bang International Corporation Inc. Amendment No. 12 to Registration Statement on Form F-1 Filed August 23, 2024 File No. 333-262367

Dear Ms. Kindelan:

This letter is in response to the letter dated September 3, 2024 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) addressed to Li Bang International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference, we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the “Amendment No. 13 to the Registration Statement”) is being submitted to accompany this letter.

Amendment No. 12 to Registration Statement on Form F-1

General

1) Please update your financial statements, or file as an exhibit to the filing the necessary representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction 2 thereto.

RESPONSE: We note the Staff’s comment, and in response thereto, respectfully advise the Staff that we have filed the Request for Waiver and Representation under Item 8.A.4 of Form 20-F as exhibit 99.8 to the Amendment No. 13 to the Registration Statement.

We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our securities counsel William S. Rosenstadt, Esq., or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or jye@orllp.legal.

Li Bang International Corporation Inc.

/s/ Huang Feng

Name: Huang Feng

Title: Chief Executive Officer

Show Raw Text
CORRESP
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filename1.htm

LI BANG INTERNATIONAL CORPORATION INC.

No. 190 Xizhang Road, Gushan Town

Jiangyin City, Jiangsu Province

People’s Republic of China

September 6, 2024

Via Edgar Correspondence

Melissa Kindelan

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Li Bang International Corporation Inc.

    Amendment No. 12 to Registration Statement on Form F-1

    Filed August 23, 2024

    File No. 333-262367

Dear Ms. Kindelan:

This letter is in response to the letter dated
September 3, 2024 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) addressed
to Li Bang International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference,
we have recited SEC’s comments in this response and numbered them accordingly. An amended registration statement on Form F-1 (the
“Amendment No. 13 to the Registration Statement”) is being submitted to accompany this letter.

Amendment No. 12 to Registration Statement
on Form F-1

General

 1) Please update your financial statements, or file as an
exhibit to the filing the necessary representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction
2 thereto.

RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that we have filed the Request for Waiver and Representation under Item 8.A.4 of
Form 20-F as exhibit 99.8 to the Amendment No. 13 to the Registration Statement.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at
wsr@orllp.legal or jye@orllp.legal.

    Li Bang International Corporation Inc.

    /s/ Huang Feng

    Name:
    Huang Feng

    Title:
    Chief Executive Officer