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January 26, 2024
Ma Biu
Chief Executive Officer
Luda Technology Group Limited
Unit H, 13/F, Kaiser Estate Phase 2
47-53 Man Yue Street
Hung Hom, Kowloon
Hong Kong
Re:Luda Technology Group Limited
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted January 16, 2024
CIK No. 0001984124
Dear Ma Biu:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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 a comment applies 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 this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
October 20, 2023 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1 filed January 16, 2024
Compensation of Directors and Executive Officers, page 109
1.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2023.

 FirstName LastName Ma Biu
 Comapany NameLuda Technology Group Limited
 January 26, 2024 Page 2
 FirstName LastName
 Ma Biu
Luda Technology Group Limited
January 26, 2024
Page 2
Certain Relationships and Related-Party Transactions, page 116
2.We note your response to prior comment eight and reissue in part. Please ensure that you
have provided the disclosure required for related party transactions since the beginning of
your preceding three financial years up to the date of the registration statement.
Additionally, Section 402 of the Sarbanes-Oxley Act of 2002 prohibits public companies
from extending or maintaining credit in the form of personal loans to or for any director or
executive officer. To the extent necessary, disclose the action that will be taken to ensure
any applicable arrangements will be extinguished prior to the completion of the initial
public offering or tell us why this provision does not apply to any of the advances
disclosed in this section.
Financial Statements
Consolidated Balance Sheets, page F-3
3.We read your response to comment nine where you indicate there is no additional paid-in
capital as of December 31, 2022 and 2021.  However, we note in your shareholders' equity
and elsewhere throughout your registration statement (e.g., footnote (1) in your
Capitalization table on page 52), the ordinary shares have a $0.03 par value.  Please
explain and revise your disclosure(s) as necessary.
            Please contact Charles Eastman at 202-551-3794 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alex King at 202-551-8631 or Evan Ewing at 202-551-5920 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick