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January 3, 2024
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 5 to
Registration Statement on Form F-1
Filed December 19, 2023
File No. 333-275242
Dear Eva Yuk Yin Siu:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our November 28, 2023 letter.
Amendment No. 5 to Registration Statement on Form F-1
Compensation of Directors and Executive Officers, page 98
1.Please update your compensation disclosure to reflect the most recently completed fiscal
year. Refer to Part I, Item 4.a. of Form F-1 and Part I, Item 6.B. of Form 20-F.
Related Party Transactions, page 99
2.We reissue comment 2 of our letter dated May 18, 2023. Your disclosure in this section
appears to be current as of June 30, 2023. Please update your disclosure to reflect
transactions up to the date of the document. Please refer to Part I, Item 4.a. of Form F-1

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 January 3, 2024 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
January 3, 2024
Page 2
and Part I, Item 7.B. of Form 20-F.
Index to Financial Statements, page F-1
3.We note that you are a nonpublic company registering its initial public offering of
securities and that the audited financial statements included in the filing are now older
than 12 months. To the extent you are relying on the 15-month requirement for the age of
your financial statements, please file the representations outlined in Instruction 2 to Item
8.A.4 of Form 20-F as an exhibit to the registration statement. Otherwise, please update
the financial statements and other financial information in the filing to comply with
Item 8.A.4 of Form 20-F.
            Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Theodore Paraskevas