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February 8, 2023
Jeffrey Chau
Chief Executive Officer
JAAG Enterprises Ltd.
1716 13 Avenue NW
Calgary, AB T2N 1L1
Canada
Re:JAAG Enterprises Ltd.
Amendment No. 1 to Registration Statement on Form S-1
Filed January 18, 2023
File No. 333-267995
Dear Jeffrey Chau:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 18, 2023 letter.
Amendment No. 1 to Registration Statement on Form S-1
General
1.Please note that the Sample Letter to China-Based Companies (December 20, 2021)
indicates that a China-based issuer is a company based in, or with a majority of its
operation in China or Hong Kong. Please note that our comments referencing the PRC
and/or China apply to your operations in Hong Kong. Many of the comments contained in
this letter have numerous components. To facilitate the staff's analysis of your disclosure,
your response letter should separate each comment and component and reproduce the
disclosure and the specific location in your filing where you believe the SEC's concern is
addressed. Please also note that the headings in this comment letter and comments

 FirstName LastNameJeffrey Chau
 Comapany NameJAAG Enterprises Ltd.
 February 8, 2023 Page 2
 FirstName LastNameJeffrey Chau
JAAG Enterprises Ltd.
February 8, 2023
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themselves direct you to where the responsive disclosure should appear if it does not
appear in that location already.
Cover page
2.We note your responses to prior comments 1-4. We reissue those comments, please
provide requested disclosure on your cover page.
Prospectus Summary, page 1
3.Please revise to include summary risk factor. We reissue prior comment 5.
4.In your response letter to prior comment 6, you state that the company’s Hong Kong
subsidiary does not require permission or approval from Chinese authorities to operate the
Company’s or the subsidiaries' business or to offer securities to foreign investors. The
Company and its subsidiary are not covered by the permission requirements from the
CSRS, CAC or other Chinese agencies." Please provide this information in your revised
disclosure.
5.We note your response to prior comment 7. We reissue our comment. Please provide the
requested information in your summary.
Prospectus Summary
Doing Business in Hong Kong, page 5
6.In the second to the last paragraph here and in the last paragraph on page 16, please clarify
in the first sentence that the audit report was for the year ended June 30, 2022. Your
current disclosure states December 31, 2020. In addition, please provide an update to this
section to discuss the PCAOB's December 15, 2022 decision to vacate its
previous determinations issued on December 16, 2021 with respect to its ability to inspect
or investigate completely registered public accounting firms headquartered in Mainland
China and Kong Kong.

Part II, Item 16. Exhibits and Financial Schedules, page 54
7.Refer to the listing for Exhibit 23.1.  Please include a currently dated accountant's consent
in the next amendment.

Note 4. Summary of Significant Accounting Policies
(f). Revenue Recognition, page F-8
8.We have reviewed your response to prior comment 26 but do not consider your response
to fully address our comment in its entirety. In this regard, please further expand your
disclosures in this footnote to address:
•the nature or the types of products or services you provide to your customers,

 FirstName LastNameJeffrey Chau
 Comapany NameJAAG Enterprises Ltd.
 February 8, 2023 Page 3
 FirstName LastName
Jeffrey Chau
JAAG Enterprises Ltd.
February 8, 2023
Page 3
pursuant to ASC 606-10-50-12(c);
•whether you have identified a single or multiple performance obligations in
your contracts with customers, pursuant to ASC 606-10-25-14 and 606-10-50-12, and
how you allocate the transaction price pursuant to ASC 606-10-32-29 and 606-10-50-
13; and,
•also include this expanded disclosure in your revenue recognition policy footnote on
page 49.

            You may contact Jean Yu at 202-551-3305 or Beverly Singleton at 202-551-3328 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Eranga Dias at 202-551-8107 or Asia Timmons-Pierce at 202-551-3754 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing