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August 14, 2023
Edwin Chun Yin Wong
Chief Executive Officer
J-Long Group Ltd
Flat F, 8/F, Houston Industrial Building
32-40 Wang Lung Street, Tsuen Wan
New Territories, Hong Kong
Re:J-Long Group Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted July 25, 2023
CIK No. 0001948436
Dear Edwin Chun Yin Wong:
            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. 2 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Major Factors Affecting Our Financial Results, page 63
1.We note your response to comment 3 and reissue.  Please further augment your disclosure
to quantify the impact on your revenues, or results of operation due to COVID-19 and
supply chain issues, in the past and going forward.  As examples only, quantify 1) the
extent to which the Company experienced "supply chain disruption due to lock downs in
China or its 'zero-covid' policy" and 2) the decline in sales generated from China for the
year ended March 31, 2023.

 FirstName LastNameEdwin Chun Yin Wong
 Comapany NameJ-Long Group Ltd
 August 14, 2023 Page 2
 FirstName LastName
Edwin Chun Yin Wong
J-Long Group Ltd
August 14, 2023
Page 2
Cost of Sales, page 64
2.We note your discussion and analysis of cost of sales is limited to a reference to your
gross profit discussion which does not address changes in your cost of sales directly.
Please expand your disclosure to provide a separate discussion and analysis of cost of
sales.  Also, include separate quantification and discussion of changes in significant
components of cost of sales that caused the item to materially vary from the prior period.
Refer to Item 4(a) of Form F-1 and Item 5 of Form 20-F.
Selling and Marketing Expenses, page 65
3.You attribute the increase in selling and marketing expenses to higher commissions and
increased salaries to your sales and marketing department.  Please tell us and revise to
disclose why commissions were higher given that revenues stayed flat, the underlying
reason(s) for the increased salaries (e.g. increased workforce, annual pay rise, etc.) and
whether this trend of increasing salaries is expected to continue.
Critical Accounting Policies and Estimates, page 67
4.We have read your response to comment 2.  Your risk factor disclosure on page
36 cautions investors that you depend on demand and storage capacity forecast to manage
inventory and such demand can change significantly and may be affected by seasonality,
the economy, changes in trends and consumers’ preferences.  It further describes a risk
that any failures to manage inventory may subject you to the risk of inventory
obsolescence resulting in decline in inventory value, and inventory write-downs or write-
offs which may materially and adversely affect your results of operations and financial
condition.  We note that inventory represents approximately 28% of your total assets as of
March 31, 2023.  It appears there are accounting estimates and assumptions related to
inventory valuation that are susceptible to change given the nature of your business and
your exposure to changes in trends, consumers’ preferences, and general economic
conditions which could have a material effect on your financial condition or operating
performance.  Although you indicate that your accounting estimates would not be critical
accounting estimates due to the level of activity and lack of complex transactions, these
accounting estimates/assumptions appear susceptible to change and the resulting
change(s) could materially impact your financial statements in the future.  Accordingly,
please revise to include, at a minimum, your critical accounting policies for inventory.

 FirstName LastNameEdwin Chun Yin Wong
 Comapany NameJ-Long Group Ltd
 August 14, 2023 Page 3
 FirstName LastName
Edwin Chun Yin Wong
J-Long Group Ltd
August 14, 2023
Page 3
            You may contact Stephen Kim at (202)551-3291 or Linda Cvrkel at (202) 551-3813 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Rucha Pandit at (202) 551-6022 or Donald Field at (202) 551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Virginia Tam