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April 29, 2024
Tim Hoi Ching
Chief Executive Officer
Raytech Holding Ltd
Unit 609, 6/F, Nan Fung Commercial Centre
No. 19 Lam Lok Street
Kowloon Bay, Hong Kong
Re:Raytech Holding Ltd
Amendment No. 6 to Form F-1
Filed April 26, 2024
File No. 333-275197
Dear Tim Hoi Ching:
            We have reviewed your 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.
Amendment 6 to Form F-1
General
1.Please update your compensation disclosure to reflect the fiscal year ended March 31,
2024. Refer to Item 4 of Form 1-A and Item 6.B of Form 20-F.
2.Please update your disclosure as appropriate to reflect any recent developments that
materially impact your business, financial condition, and/or results of operations.
Exhibit 23.1, page 1
3.We note that the consent references the audit report in amendment 6 to Form F-1. As
amendment 6 does is an exhibits only amendment and therefore, does not include the audit
report to which the consent refers, please revise. As an alternative, consider referring only
to the audit report in the F-1 filing rather than to a specific amendment.

 FirstName LastNameTim Hoi Ching
 Comapany NameRaytech Holding Ltd
 April 29, 2024 Page 2
 FirstName LastName
Tim Hoi Ching
Raytech Holding Ltd
April 29, 2024
Page 2
            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 Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Arila Zhou