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April 20, 2023
Zhen Fan
Chief Executive Officer
Haoxi Health Technology Ltd
Room 801, Tower C, Floor 8
Building 103
Huizhongli, Chaoyang District
Beijing, China
Re:Haoxi Health Technology Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted March 30, 2023
CIK No. 0001954594
Dear Zhen Fan:
            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. 1 to Draft Registration Statement on Form F-1 Submitted March 30, 2023
Cover Page
1.You disclose that none of your subsidiaries have made any dividends or distributions to
the Company, and the Company has not made any dividends or distributions to
shareholders.  Please revise here, and elsewhere as appropriate, to disclose whether there
have been any transfers or cash flows, including dividends or distributions, by the
Company (i.e., the holding company) to the subsidiaries.  If so, quantify the transfer and
disclose which entity made such transfer.  We also note your disclosure that you rely to a
significant extent on dividends and other distributions on equity paid by Haoxi Beijing to

 FirstName LastNameZhen Fan
 Comapany NameHaoxi Health Technology Ltd
 April 20, 2023 Page 2
 FirstName LastName
Zhen Fan
Haoxi Health Technology Ltd
April 20, 2023
Page 2
fund offshore cash and financing requirements.  Please confirm that despite this reliance,
Haoxi Beijing has not made any dividends or distributions to you to date.
Risks Related to Doing Business in China
The PRC government exerts substantial influence over the manner in which we conduct our
business activities. The PRC government may also..., page 21
2.We note your response to comment 2, and reissue in part. We acknowledge your updated
disclosure throughout the registration statement regarding the CSRC Overseas Listing
Trial Measures and your corresponding obligations. However, we note that in this risk
factor you still state that you do not require approval from Chinese authorities to list your
securities on a U.S. exchange. Please clarify this discrepancy.
Consolidated Statements of Cash Flows
Years Ended June 30, 2022 and 2021, page F-6
3.Please reconcile repayments of short-term borrowings of $52,062 for the year ended June
30, 2022 with subsequent loan repayments of $69,067 on your short-term borrowings
outstanding at June 30, 2021 as disclosed in Note 9.
General
4.We note your disclosure that you will be subject to the filing requirements of the Trial
Measures. Please disclose whether the offering is contingent on approval from the CSRC.
Please also discuss your responsibilities under the Trial Measures and the current status of
your compliance with the process.
            You may contact Robert Shapiro at 202-551-3273 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li