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December 4, 2023
Rongjun Xu
Chief Executive Officer
INLIF Limited
No. 88, Hongsi Road
Yangxi New Area, Honglai Town
Nan’an City, Quanzhou
The People’s Republic of China
Re:INLIF Limited
Draft Registration Statement on Form F-1
Submitted November 6, 2023
CIK No. 0001991592
Dear Rongjun Xu:
            We have reviewed your draft registration statement and have the following comments.
            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.
Draft Registration Statement on Form F-1
Prospectus Summary
Summary of Risk Factors, page 5
1.Please disclose the risk that the Chinese government may intervene or influence your
operations at any time or may exert more control over offerings conducted overseas and/or
foreign investment in China-based issuers, which could result in a material change in your
operations and/or the value of the securities you are registering for sale. Acknowledge any
risks 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.

 FirstName LastNameRongjun Xu
 Comapany NameINLIF Limited
 December 4, 2023 Page 2
 FirstName LastNameRongjun Xu
INLIF Limited
December 4, 2023
Page 2
Risk Factors
Risks Relating to Doing Business in the PRC, page 17
2.We note that one or more of your officers or directors are located in China and Hong
Kong. Please revise to include risk factor disclosure as to address the difficulty of bringing
actions against these individuals and enforcing judgments against them.
The PRC government has significant authority to exert influence..., page 19
3.Please disclose the risk that the Chinese government may intervene or influence your
operations at any time, which could result in a material change in your operations and/or
the value of your securities. Also, given recent statements by the Chinese government
indicating an intent to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers, acknowledge the risk that any
such action 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. We remind you that, pursuant to federal securities rules, the term
“control” (including the terms “controlling,” “controlled by,” and “under common control
with”) means “the possession, direct or indirect, of the power to direct or cause the
direction of the management and policies of a person, whether through the ownership of
voting securities, by contract, or otherwise.”
Risks Relating to Our Business and Industry, page 25
4.Please add a risk factor regarding your customer concentration and reliance on certain
customers including any uncertainties regarding your relationship with them. In this
regard, we note your disclosure on page 81 that three of your customers accounted for
greater than 10% of total revenues for the six months ended June 30, 2023. Please clarify
the percentage of revenue from each of the identified customers and disclose the terms of
any material agreements with these customers, including the term of the agreements and
any termination provisions.
Risks Relating to this Offering and the Trading Market, page 33
5.Please add a risk factor that discusses the concentration of ownership of your common
stock among your existing officers, directors and principal stockholders.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
51
6.Please disclose whether you utilize any key metrics or financial measures to evaluate your
business, measure your performance, identify trends affecting your business, establish
budgets, measure the effectiveness of investments in your technology and development
and sales and marketing, and assess your operational efficiencies. Refer to Item 5
Operating and Finance Review and Prospects to Form 20-F.

 FirstName LastNameRongjun Xu
 Comapany NameINLIF Limited
 December 4, 2023 Page 3
 FirstName LastNameRongjun Xu
INLIF Limited
December 4, 2023
Page 3
Liquidity and Capital Resources, page 61
7.Please revise to separately analyze your ability to generate and obtain adequate amounts
of cash to meet your requirements and plans for cash in the long-term (i.e., beyond the
next 12 months). Refer to Item 5.B of Form 20-F.
Management, page 101
8.Please file the consents of Ms. Zhang and Messrs. Zeng and Zhou as exhibits to your
registration statement. Refer to Securities Act Rule 438.
Underwriting
Lock-Up Agreements, page 140
9.Please describe the exceptions to the lock-up agreements with your officers, directors and
principal stockholders.
Consolidated Balance Sheets, page F-26
10.When the caption "Commitments and Contingencies" is included on the balance sheet, the
amount column should be left blank and not indicated with a dash (-) since the dash might
be interpreted to mean that there are neither commitments nor contingent liabilities.
11.We note from your consolidated balance sheets that there are Ordinary shares ($0.01 par
value, 5,000,000 shares authorized, 5,000,000 shares issued and outstanding as of June 30,
2023 and December 31, 2022).  We also note from your disclosures on page 39 and
elsewhere in the filing that there are 300,000 of your Ordinary Shares that are issued and
outstanding as of the date of this prospectus. Explain how you considered the guidance in
SAB Topic 4C.
Consolidated Statements of Cash Flows, page F-29
12.We note that you present "Amount financed from related parties" as net cash (used in)
financing activities.  Please revise your disclosures to separately present the related party
amounts lent to the operating entity and the related party amounts collected from the
operating entity.  In this respect, we note that you separately disclose these amounts in
your related party footnote beginning on page F-47.  We refer you to ASC 230-10-45-7.
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 2. Summary of significant accounting policies
Revenue recognition, page F-34
13.We note that for the years ended December 31, 2022 and 2021, there was no revenue
recognized on a net basis where the Company is acting as an agent.  Please provide us
with your analysis of the principal versus agent considerations.  We refer you to ASC 606-

 FirstName LastNameRongjun Xu
 Comapany NameINLIF Limited
 December 4, 2023 Page 4
 FirstName LastName
Rongjun Xu
INLIF Limited
December 4, 2023
Page 4
10-55-36 through 55-40.
14.Please explain how you account for the one-year warranty services against defects in
materials and workmanship for your customers. In addition, please describe how you are
determining and allocating the transaction price to each performance obligations. Refer to
ASC 606-10-50-20.
Note 10. Short-term bank loans, page F-42
15.You disclose that the short-term bank loan with Industrial and Commercial Bank of China
matures on October 17, 2023.  Please revise your disclosures to clarify whether the short-
term bank loan is past due as of the date of this prospectus.
General
16.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at 202-551-
3488 if you have questions regarding comments on the financial statements and related
matters. Please contact Marion Graham at 202-551-6521 or Jeff Kauten at 202-551-3447 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology