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AgiiPlus Inc.

March 30, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, DC 20549

    Re:

    AgiiPlus Inc.

    Amendment No. 3 to Registration Statement on Form F-1

    Filed March 22, 2023

    File No. 333-267461

Dear Mr. Lopez and Mr. Holt:

AgiiPlus Inc. (the “Company”,
“we”, “us” or “our”) hereby transmits its response to the letter received from
the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated
March 28, 2023 regarding the Amendment No. 3 to Registration Statement on Form F-1 filed by AgiiPlus Inc. on March 22, 2023. For ease
of reference, we have repeated the Commission’s comments in this response letter and numbered them accordingly. An Amendment No.
4 to the Registration Statement on Form F-1 (“Amendment No. 4 to the Registration Statement”) is being filed by the
Company to accompany this response letter.

Amendment No. 3 to Registration Statement on
Form F-1 filed March 2, 2023

Part II

Item 7. Recent Sales of Unregistered Securities,
page II-1

1. Please revise to provide all of the information
required by Item 701 of Regulation S-K for the 3,215,100 shares of the company sold to individual and institutional investors from September
2022 to March 2023. Additionally, if applicable, please revise to provide all of the information required by Item 701 of Regulation S-K
for the convertible promissory notes issued to Kinfolk Investments Holding Pte Ltd., King Inspiration Limited, and City Connected Communities
Pte. Ltd., respectively. In this regard, we note that it appears the notes mature more than one year from the date of issuance. Refer
to the Instructions to Item 701 of Regulation S-K.

Response: In response to the Staff’s
comment, we revised pages II-2 and II-3 of Amendment No. 4 to the Registration Statement to disclose all information required by Item
701 of Regulation S-K for the 3,215,100 shares of the company sold to individual and institutional investors from September 2022 to March
2023, and promissory notes issued to Kinfolk Investments Holding Pte Ltd., King Inspiration Limited, and City Connected Communities Pte.
Ltd.

General

2. We note your registration statement is an
initial public offering and the current audited financial statements are older than 12 months. Please clarify how you complied with the
requirements outlined in paragraph A(4) of Item 8 of Form 20-F or revise accordingly to either update your audited financial statements
or include the relevant representation as allowed under Step 2 within Instructions to Item 8.A.4 of Form 20-F, as an exhibit to the registration
statement.

Response: In response to the Staff’s
comment, we filed a request for waiver and relevant representation under Item 8.A.4 of Form 20-F as exhibit 99.7 to Amendment No. 4 to
the Registration Statement.

We thank the Staff for its review of the foregoing.
If you have further comments, we ask that you forward them by electronic mail to our counsel, Ying Li at yli@htflawyers.com or
by telephone at 212-530-2206.

    Very truly yours,

    /s/ Jing Hu

    Jing Hu

    Chief Executive Officer and

 Chairman of the Board of Directors

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC