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Hanryu
Holdings, Inc.

160,
Yeouiseo-ro

Yeongdeungpo-gu,
Seoul

Republic
of Korea 07231

February 6, 2023

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Technology

100
F. Street, N.W.

Mail
Stop 6010/3561

Washington,
DC 20549

    Attention:
    Melissa
    Kindelan, Senior Staff Accountant

Kathleen
Collins, Accounting Branch Chief

Larry
Spirgel, Office Chief

Edwin
Kim, Staff Attorney

    Re:
    Hanryu
    Holdings, Inc.

 Registration Statement on Form S-1 Filed

January
26, 2023

File
No. 333-269419

Dear
Mr. Kim:

Hanryu
Holdings, Inc. (the “Company”) confirms receipt of the letter dated February 3, 2023, from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) with respect to the above-referenced filing. We are responding
to the Staff’s comments as set forth below. The Staff’s comments are set forth below, followed by the Company’s response
in bold:

Amendment
No. 1 to Registration Statement on Form S-1 (the “Registration Statement”)

Prospectus
Summary, page 4

    1.
    We note your revised disclosure
    in response to prior comment 1 states that revenue generated as of September 30, 2022 was $904,041. Please further revise to clarify
    that such amount was generated for the nine months ended September 30, 2022 or revise to reflect the cumulative amount of revenue
    recognized as of such date.

RESPONSE:
In response to the Staff’s comment, the Company advises the Staff that the Company updated the relevant disclosure on page 4 of
the Registration Statement to reflect that the $904,041 in revenue was for the nine months ended September 30, 2022.

Chang-Hyuk
Kang

Hanryu
Holdings, Inc.

February 6,

2023

Page
2

Risk
Factors

If
we fail to maintain an effective system of internal controls over financial reporting..., page 45

    2.
    You state that management has
    reviewed your current internal controls over financial reporting and concluded they are effective. You also indicate that during
    the course of documenting and testing your internal control over financial reporting, you may identify weaknesses and deficiencies
    in your internal control over financial reporting. Given you have restated the financial statements as a result of errors coupled
    with the fact that the key performance indicators previously provided were incorrect, please revise these disclosures as appropriate.
    In this regard, while we acknowledge that you are not yet subject to the requirements of Section 404 of the Sarbanes-Oxley Act of
    2002, tell us how management's conclusion regarding your controls is still appropriate, or revise. Further, disclose whether you
    are now aware of any significant deficiencies or material weaknesses in your controls that will need to be addressed when you become
    a public company.

RESPONSE:
In response to the Staff’s comment, the Company advises the Staff that the Company has revised the relevant disclosures throughout
the Registration Statement, where appropriate, to reflect the Company’s weakness in internal controls.

Executive
Compensation, page 104

    3.
    Please update your Executive
    Compensation tables through December 31, 2022 in your next amendment.

RESPONSE:
In response to the Staff’s comment, the Company advises the Staff that the Company has updated the Executive Compensation tables
through December 31, 2022.

Notes
to Consolidated Financial Statements

Note
3 - Restatement, page F-61

    4.
    Please
    revise to include a description of the nature of each error. Similar disclosures should be added in the interim financial statements
    on page F-18. Refer to ASC 250-10-50-7. Also, please have your auditors revise their opinion to include an explanatory paragraph
    with regard to the correction of the material misstatements in your previously issued financial statements. Refer paragraph .18(e)
    of PCAOB AS 3101.

    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.

    Refer
    to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the
    requested effective date of the registration statement.

RESPONSE:
In response to the Staff’s comment, the Company advises the Staff that the Company has revised its disclosures, where appropriate,
to describe the nature of the errors in the Company’s restated financial statements. Additionally, Company’s auditor has
revised its opinion to include an explanatory paragraph regarding the correction of the material restatement.

    2

We
trust that this response satisfactorily responds to your request. Should you require further information, please contact our legal counsel
Matthew Ogurick at (212) 536-4085.

    Very truly yours,

    /s/
    Chang-Hyuk Kang

    Chang-Hyuk Kang,

    Chief Executive Officer

cc:
Matthew Ogurick, Esq. of K&L Gates LLP

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