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Park
Ha Biological Technology Co., Ltd.

901
& 901-2, Building C

Phase
2, Wuxi International Life Science Innovation Campus 196 Jinghui East Road

Xinwu
District, Wuxi, Jiangsu Province

People’s
Republic of China 214000

October
9, 2024

Via
EDGAR

Division
of Corporation Finance

Office
of Industrial Applications and Services

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Attn:
    Tracey
    Houser

Terence
O’Brien

Benjamin
Richie

Katherine
Bagley

    Re:
    Park
    Ha Biological Technology Co., Ltd.

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

Filed
September 18, 2024

File
No. 333-281783

Dear
Ms. Houser, Mr. O’Brien, Mr. Richie, and Ms. Bagley:

This
letter is in response to the letter dated October 1, 2024 from the staff (the “Staff”) of the U.S. Securities Exchange Commission
(“SEC”) addressed to Park Ha Biological Technology Co., Ltd. (the “Company”, “we”, and “our”).
For ease of reference, we have recited the SEC’s comments in this response and numbered them accordingly. An amended registration
statement on Form F-1 (the “Registration Statement”) is being filed publicly to accompany this letter.

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

Prospectus
Summary

Our
Franchise Model, page 8

 1. We
                                            note your revised disclosure on page 2 in response to comment 1, including that the decrease
                                            in revenue from franchise fees “was primarily due to a decrease in the franchise fees
                                            as a result of (i) a decrease in the number of our franchisees, (ii) additional franchisee
                                            incentives such as our offering of discounts on franchise fees to incentivize renewals, and
                                            (iii) the change in the franchising model for some of our franchisees, from regional franchisees
                                            to single-store franchisees, which led to certain changes in franchise fees.” Please
                                            revise this section and your description of business beginning on page 86 to provide additional
                                            detail about your franchise model, including the types and amount of discounts and other
                                            incentives you offer to current franchisees for renewal or to attract new franchisees, and,
                                            if material, a quantification of historical discounts or incentives to existing franchisees.
                                            Please also provide additional detail about the franchise fees for regional compared to singe-store
                                            franchisees, including the difference in fees for these two models. In your discussion, clarify
                                            the fees received from each type of model for the periods presented in the filing to provide
                                            context for your disclosure that the change in model resulted in a decrease in franchise
                                            fees for the six months ended April 30, 2024. Finally, please revise your risk factors to
                                            discuss the risks, if any, related to discounts or incentives noted in your revised disclosure.

RESPONSE:
We note the Staff’s comment and in response thereto respectfully advise the Staff that we have revised our disclosures under sections
“Prospectus Summary – Our Franchise Model,” “Business – Our Business Model” and “Management’s
Discussion on and Analysis of Financial Condition and Results of Operations” on pages 3, 8, and 81 to provide additional
detail about our franchise model, franchise fees for different types of franchisees, and the types and amount of incentives such as cash subsidies that we offer to current franchisees for renewal or to attract
new franchisees. We have provided a quantification of historical incentives to existing franchisees and included additional details about
the franchise fees for regional stores compared to single-store franchisees on pages 3, 8, and 81.

We
have also added a risk factor related to our franchise model under “Risk Factors — Risks Relating to Our Business and Industry
— We offer incentives such as cash subsidies to our franchisees and the amount of such incentives could potentially have adverse
impacts on our financial performance.” on page 57.

Risk
Factors Summary, page 10

 2. We
                                            note your revised disclosure in response to prior comment 2. Please revise your Risk Factor
                                            Summary section to include the following removed risk factors and conform the cross-references
                                            to those present:

 ● “You
                                            may experience difficulties in effecting service of process, enforcing foreign judgments
                                            or bringing actions in China against us or our management named in this prospectus based
                                            on foreign laws.”

 ● “Our
                                            results of operation may be materially and adversely affected by a change in China or the
                                            global economy.”

 ● “It
                                            may be difficult for overseas shareholders and/or regulators to conduct cross- border investigation
                                            in China.”

 ● “Changes
                                            in PRC political, economic and governmental policies may have an adverse impact on our business.”

 ● “PRC
                                            regulation of loans to and direct investment in PRC entities by offshore holding companies
                                            and governmental management of currency conversion may delay us from remitting the proceeds
                                            of this offering into China through loans or additional capital contributions to our PRC
                                            subsidiaries, thereby diminishing our ability to fund and expand our business.”

 ● “PRC
                                            regulations relating to offshore investment activities by PRC residents may limit our PRC
                                            subsidiaries’ ability to change their registered capital or distribute profits to us
                                            or otherwise expose us or our PRC resident beneficial owners to liability and penalties under
                                            PRC laws.”

 ● “If
                                            the content we produce and distribute through online social and content platforms, or content
                                            available on our website, is deemed to violate PRC laws or regulations, our business and
                                            results of operations may be materially and adversely affected.”

Please
also include the risk that any actions by the Chinese government to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers could significantly limit or completely hinder your ability to offer or continue
to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

RESPONSE:
We note the Staff’s comment and in response thereto respectfully advise the Staff that we have (i) revised our Risk Factors
Summary on pages 12, 13, and 14 to include the previously removed risk factors and conform the cross-references to those present;
and (ii) revised our disclosure on pages 12 and 27 to specify in the risk factor that any actions by the Chinese government to
exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers could
significantly limit or completely hinder our ability to offer or continue to offer securities to investors and cause the value of
such securities to significantly decline or be worthless.

Exhibits

 3. We
                                            note that the opinion of Mourant Ozannes (Cayman) LLP, filed as Exhibit 5.1, assumes that
                                            “the Company will have sufficient authorised but unissued capital to issue each Share.”
                                            Please revise the legal opinion to remove this assumption. Refer to Section II.B.3.a of Staff
                                            Legal Bulletin No. 19.

RESPONSE:
We note the Staff’s comment and in response thereto respectfully advise the Staff that we have provided a revised legal opinion
by Mourant Ozannes (Cayman) LLP, our Cayman counsel, filed hereto as Exhibit 5.1, to remove the assumption that the Company will have
sufficient authorized but unissued capital to issue each share.

    2

We
hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions
regarding the information contained herein, please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi
“Jason” Ye, Esq. or Yuning “Grace” Bai, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or
gbai@orllp.legal.

    Very
    truly yours,

    Park
    Ha Biological Technology Co., Ltd.

    /s/
    Xiaoqiu Zhang

    Name:
    Xiaoqiu
    Zhang

    Title:
    Chief
    Executive Officer

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