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August 22, 2023
Yee Man Thomas Law
Chief Executive Officer
Junee Limited
Studio 20, 11 F, International Plaza
20 Sheung Yuet Road
Kowloon Bay, Kowloon, Hong Kong
Re:Junee Limited
Amendment No. 7 to Registration Statement on Form F-1
Filed July 28, 2023
File No. 333-266116
Dear Yee Man Thomas Law:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to our oral comments issued on November 23,
2022.
Amendment No. 7 to Registration Statement on Form F-1
Cover Page
1.We note your disclosure that your auditor is currently subject to PCAOB inspections.
Please revise your cover page to disclose the location of your auditor's headquarters,
including the location of the auditor engaged in April 2023.
Taxation, page 142
2.We note you have included a "short-form" tax opinion as Exhibit 8.2 to the Registration
Statement.  As stated in Section III.B.2 of Staff Legal Bulletin No. 19, if a registrant elects

 FirstName LastNameYee Man Thomas Law
 Comapany NameJunee Limited
 August 22, 2023 Page 2
 FirstName LastName
Yee Man Thomas Law
Junee Limited
August 22, 2023
Page 2
to use a short-form opinion, the Exhibit 8 short-form opinion and the tax disclosure in the
prospectus both must state clearly that the disclosure in the tax consequences section of
the prospectus is the opinion of the named counsel and that disclosure must clearly
identify and articulate the opinion being rendered.  Please revise the Material U.S. Federal
Income Tax Consequences section of the prospectus to clearly state that the disclosure in
the tax consequences section is the opinion of named counsel.
General
3.Please revise the public offering prospectus cover page to discuss the shares to be offered
in your resale prospectus.  In this regard, please clarify the timing of the resale offering.
4.On the resale prospectus cover page, also include a placeholder for the date of
effectiveness of this registration statement, the initial public offering price of your
ordinary shares, and the most recent trading price of your ordinary shares on Nasdaq.
Also confirm that you will include such information in the Rule 424(b) prospectus filed in
connection with the resale offering.  Refer to Instruction 2 to Item 501(b)(3) of Regulation
S-K.
5.Please provide on the cover page of your resale prospectus the offering price of the
securities.  Refer to Item 501(b) of Regulation S-K.  Please also revise to clarify if the
resale shares are part of the firm commitment offering.  In this regard, your legal opinion
filed as Exhibit 5.1 states that the resale shares will be sold on a firm commitment basis.

            You may contact Suying Li at 202-551-3335 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Alyssa Wall at 202-551-8106 or Jennifer López Molina at 202-551-3792 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lisa Forcht