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September 14, 2023
Siyu Yang
Chief Executive Officer
Baiya International Group Inc.
Yifang Capital Industrial Park
No. 33 Pingshan Industrial Road, Building A, 16F
Tangxia, Dongguan, Guangdong, China
Re:Baiya International Group Inc.
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted August 24, 2023
CIK No. 0001944712
Dear Siyu Yang:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 Draft Registration Statement submitted August 24, 2023
Management's Discussion and Analysis and Results of Operations
Comparison of the year ended December 31, 2022 and 2021, page 76
1.In regard to entrusted recruitment service, you disclose revenue decreased by
approximately $6.8 million, or 71.3%, for the year ended December 31, 2022 mainly due
to the Chinese government’s COVID-19 epidemic prevention policy that caused
operations and production of factories of some major customers to be suspended.  Please
revise to quantify the material impacts COVID-19 has had on your results, to the extent
practicable.  As the COVID-19 pandemic was also present during 2021, clarify if your
fiscal 2022 was impacted differently by COVID-19 from your fiscal 2021, and if so, how,

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 September 14, 2023 Page 2
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Baiya International Group Inc.
September 14, 2023
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especially regarding any circumstances that caused 2022 revenues to decrease.  Also,
discuss whether there was any negative impact to your revenue in fiscal 2022 caused by
the disclosed reduction in customers from 36 at December 31, 2021 to 27 at December 31,
2022 and the reason for the decrease in the number of customers.  Additionally, revise to
clearly describe declining revenues during the periods presented and any associated
known trends.  Further, you disclose the demand of labor from employer companies in
China has been continuously decreased since beginning of 2022 as a result of decreased
production orders for factories.  Disclose your expectation of this continuing and the
impact on your results if it does.
2.You state the increase in cost of revenues of project outsourcing service for 2022 was in
line with the increased revenue from project outsourcing service.  Yet, project outsourcing
service revenue decreased for 2022.  Please clarify the reason for the increased cost of
revenues for 2022.
3.Please disclose whether the increase labor cost incurred to fulfill outsourcing services in
2022 is a known trend.
4.You disclose China Post is one of your three major customers.  You disclose the increase
in general and administrative expense in 2022 was mainly due to the increase in bad debt
allowance regarding China Post due to its slow collection.  Please disclose whether you
expect the slow collection with China Post to continue and, if so, the impact on your
operations.
General
5.We note the changes you made to your disclosure appearing on the cover page, Prospectus
Summary and Risk Factor sections relating to legal and operational risks associated with
operating in China and PRC regulations. It is unclear to us that there have been changes in
the regulatory environment in the PRC since the review of your last amendment filed
February 14, 2023, warranting revised disclosure to mitigate the challenges you face and
related disclosures. The Sample Letters to China-Based Companies sought specific
disclosure relating to the risk that the PRC government may intervene in or influence your
operations at any time, or may exert control over operations of your business, which could
result in a material change in your operations and/or the value of the securities you are
registering for sale. We remind you that, pursuant to federal securities rules, the term
“control” (including the terms “controlling,” “controlled by,” and “under common control
with”) as defined in Securities Act Rule 405 means “the possession, direct or indirect, of
the power to direct or cause the direction of the management and policies of a person,
whether through the ownership of voting securities, by contract, or otherwise.” The
Sample Letters also sought specific disclosures relating to uncertainties regarding the
enforcement of laws and that the rules and regulations in China can change quickly with
little advance notice. We do not believe that your revised disclosure referencing the PRC
government’s evolution of its regulatory oversight conveys the same risk. Please restore
your disclosures in these areas to the disclosures as they existed in your amendment filed

 FirstName LastNameSiyu Yang
 Comapany NameBaiya International Group Inc.
 September 14, 2023 Page 3
 FirstName LastName
Siyu Yang
Baiya International Group Inc.
September 14, 2023
Page 3
on February 14, 2023.
            You may contact Nasreen Mohammed at 202-551-3773 or Doug Jones at 202-551-3309
if you have questions regarding comments on the financial statements and related
matters.  Please contact Scott Anderegg at 202-551-3342 or Dieter King at 202-551-8071 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services