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Correspondence 0001213900-24-026323 from Zhibao Technology Inc. (ZBAO)

Zhibao Technology Inc.
Date: March 27, 2024 · CIK: 0001966750 · Accession: 0001213900-24-026323

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File numbers found in text: 333-274431

Date
March 27, 2024
Author
EF HUTTON LLC
Form
CORRESP
Company
Zhibao Technology Inc.

Letter

EF HUTTON LLC

590 Madison Avenue, 39th Floor

New York, NY 10022

March 27, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: William Schroeder

Amit Pande

Madeleine Joy Mateo

John Dana Brown

Re:

Zhibao Technology Inc.

Registration Statement on Form F-1

Filed March 22, 2024

File No. 333-274431

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), EF Hutton LLC, as representative of the underwriters of the offering, hereby joins the request of the Company that the effective date of the above-captioned Registration Statement be accelerated so as to permit it to become effective on Friday, March 29, 2024 at 12:00 p.m., Eastern Daylight Time, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act, we, acting on behalf of the several underwriters, wish to advise you that, through March 27, 2024, we distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus dated March 22, 2024, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

We have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

Very truly yours,
EF HUTTON LLC

Show Raw Text
CORRESP
1
filename1.htm

EF HUTTON LLC

590 Madison Avenue, 39th Floor

New York, NY 10022

March 27, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    William Schroeder

    Amit Pande

    Madeleine Joy Mateo

    John Dana Brown

    Re:

    Zhibao Technology Inc.

    Registration Statement on Form F-1

    Filed March 22, 2024

    File No. 333-274431

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), EF Hutton
LLC, as representative of the underwriters of the offering, hereby joins the request of the Company that the effective date of the above-captioned
Registration Statement be accelerated so as to permit it to become effective on Friday, March 29, 2024 at 12:00 p.m., Eastern Daylight
Time, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations
of the Securities and Exchange Commission under the Securities Act, we, acting on behalf of the several underwriters, wish to advise you
that, through March 27, 2024, we distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate
in the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus dated March 22,
2024, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

We have complied and will continue to comply with
the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

Very truly yours,

EF HUTTON LLC

    By:
    /s/ Sam Fleischman

    Name:
    Sam Fleischman

    Title:
    Supervisory Principal