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November 15, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment No. 2 to Registration Statement on Form F-1
Filed November 1, 2023
File No. 333-270953
Dear Yingkai Xu:
            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 April 12, 2023 letter.
Amendment No. 2 to Form F-1 filed November 1, 2023
General
1.We note the changes you made to your disclosures appearing on the cover page,
prospectus summary and risk factors 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 amendment that was
filed on May 26, 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

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 November 15, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
November 15, 2023
Page 2
“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 conveys the same
risk.  Please restore your disclosures in these areas to the disclosures as they existed in the
registration statement as of May 26, 2023.
            Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Evan Ewing at 202-551-5920 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing