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    E:
    Kevin@bevilacquapllc.com

    T:
    202.869.0888

    W:
    bevilacquapllc.com

June 10, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn: Melissa Kindelan, Christine Dietz, Aliya Ishmukhamedova, Matthew
Derby

 Re: LZ Technology
                                            Holdings Limited

Amendment No. 1 to Registration
Statement on Form F-1

Filed March 21, 2024

File No. 333-276234

Ladies and Gentlemen:

We hereby submit the responses of LZ Technology
Holdings Limited (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission set forth in the Staff’s letter, dated April 3, 2024, providing the Staff’s comments with respect to
the Company’s Amendment No. 1 to Registration Statement on Form F-1. Concurrently with the submission of this letter, the Company
is filing Amendment No. 2 to the Registration Statement (the “Amendment No. 2”) via EDGAR with the Commission.

For the convenience of the Staff, each of the
Staff’s comments is included followed by the corresponding response of the Company. Unless the context indicates otherwise, references
in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment No. 1 to Registration Statement on Form F-1

General

 1. We
                                            note the changes you made to your disclosure appearing on the Cover page, Prospectus Summary,
                                            and Risk Factor sections relating to the legal and operational risks associated with operating
                                            in China and PRC regulations. It is unclear to us that there have been changes in the regulatory
                                            environment in the PRC since the Registration Statement that was filed on December 22, 2023
                                            warranting revised disclosure to mitigate the challenges you face and related disclosures.
                                            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 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. 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 referencing the PRC government’s
                                            intent to strengthen its regulatory oversight conveys the same risk. Please revise or advise.

Response: In response
to the Staff’s comment, we respectfully advise the Staff that we have updated our disclosure on the Cover Page, and in the “Prospectus
Summary” and “Risk Factors” sections relating to the legal and operational risks associated with operating in China
and PRC regulations.

1050 Connecticut Ave., NW, Suite 500

Washington, DC 20036

    PG.
                                            2

June 10, 2024

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact Kevin Sun of Bevilacqua PLLC at (202)
869-0888 (ext. 101) or Runzhe Zhang, Chief Executive Officer of LZ Technology Holdings Limited at +86 186-0592-9066.

    Sincerely,

    /s/
    Kevin Sun, Esq.

    Kevin Sun, Esq.

    Bevilacqua PLLC

 cc: Runzhe Zhang, LZ Technology Holdings Limited