SecProbe.io

January 2, 2025
Jia Zhang
President
West Lake Club Inc.
14738 SW 23rd Street
Miami, FL 33185
Re:West Lake Club Inc.
INNO Holdings Inc.
Schedule 13D Filed by Jia Zhang and West Lake Club Inc.
Filed September 11, 2024
File No. 005-94615
Dear Jia Zhang:
            We have conducted a limited review of the above-captioned filing and have the
following comments .
            Please respond to this letter by amending the filing or by providing the requested
information. If you do not believe our comments  apply to your facts and circumstances or
that an amendment is appropriate , please advise us why in a response letter.
            After reviewing any amendment to the filing and any information provided in
response to these comments, we may have additional  comments.
Schedule 13D Filed September 11, 2024
General
1.We note that the event reported as requiring the filing of the Schedule 13D was May
31, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of a Schedule 13D
within five business days after the date beneficial ownership of more than five percent
of a class of equity securities specified in Rule 13d-1(i)(1) was acquired. Based on the
May 13, 2024 event date, the Schedule 13D submitted on September 11, 2024 was not
timely filed. Please advise us why the Schedule 13D was not filed within the required
five business days after the date of the acquisition.
2.Please amend to include a separate Cover Page for Jia Zhang. Refer to Instruction 1
within the "Instructions for Cover Page" at Rule 13d-101 of Regulation 13D-G.
Item 2, page 3

January 2, 2025
Page 2
3.Please amend Item 2 of the Statement to include the present principal occupation or
employment for Jia Zhang. See Instruction C within the "Special Instructions for
Complying With Schedule 13D" and subsection (c) of Item 2 at Rule 13d-101 of
Regulation 13D-G.
Item 4, page 3
4.The last paragraph in Item 4 refers "the Reporting Person" in the singular. Please
amend to provide the information required by Item 4 of Schedule 13D for each of the
reporting persons. See Instruction C within the "Special Instructions for Complying
With Schedule 13D" and subsection (c) of Item 2 at Rule 13d-101 of Regulation 13D-
G.
            We remind you that the filing persons are responsible for the accuracy and adequacy
of their disclosures, notwithstanding any review, comments, action or absence of action by
the staff.
            Please direct any questions to Brian Soares at 202-551-3690 or Nicholas Panos at
202-551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions