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September 27, 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 Registration Statement on Form F-1
Filed September 19, 2023
File No. 333-274214
Dear Zhen Fan:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, 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 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 comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 8, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1, Filed September 19, 2023
General
1.We note the changes to your disclosure in the prospectus, including on the prospectus
cover page, Prospectus Summary and Risk Factor sections relating to legal and
operational risks associated with PRC laws and regulations.  It is unclear to us that there
have been changes in the regulatory environment in the PRC since your amendment filed
on August 25, 2023 that warrant revised disclosure. 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

 FirstName LastNameZhen Fan
 Comapany NameHaoxi Health Technology Ltd
 September 27, 2023 Page 2
 FirstName LastName
Zhen Fan
Haoxi Health Technology Ltd
September 27, 2023
Page 2
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 “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 that removes detailed references to the PRC legal system and the nature of the
PRC government's regulatory oversight, uncertainties surrounding PRC regulations, and
interventions by the PRC government in your business conveys the same risks.  Please
restore your disclosures to the disclosures as they existed in the registration statement as
of August 25, 2023.
            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