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April 16, 2024
Brandon Robinson
Chief Executive Officer
New Horizon Aircraft Ltd.
3187 Highway 35
Lindsay, Ontario, K9V 4R1
Re:New Horizon Aircraft Ltd.
Amendment No. 1 to Registration Statement on Form S-1
Filed on April 8, 2024
File No. 333-277063
Dear Brandon Robinson:
            We have conducted a limited review of your registration statement and have the
following comment.
            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.
Amendment No. 1 to Registration Statement on Form S-1
MD&A, page 49
1.Please revise the MD&A section to cover the periods covered by the financial statements
of New Horizon Aircraft Ltd. that are included in the registration statement.
            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.
            Please contact Bradley Ecker at 202-551-4985 or Evan Ewing at 202-551-5920 with
any questions.

 FirstName LastNameBrandon Robinson
 Comapany NameNew Horizon Aircraft Ltd.
 April 16, 2024 Page 2
 FirstName LastName
Brandon Robinson
New Horizon Aircraft Ltd.
April 16, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing