SecProbe.io

United States securities and exchange commission logo
January 26, 2024
Ye Tao
Chief Executive Officer
3 E Network Technology Group Ltd
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed January 19, 2024
File No. 333-276180
Dear Ye Tao:
            We have reviewed your amended registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1
Capitalization, page 68
1.Please revise to retroactively reflect the split on all share and per share amounts here and
throughout the filing and to remove the "Adjusted (Taking into account of the share split
on January 3, 2024)" column. In this regard, we note that you refer to 1,000 shares
outstanding here are on page F-18. We also note that the net tangible book value per
share of $416 is based on 1,000 shares outstanding. Refer to SAB Topic 4C.

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 January 26, 2024 Page 2
 FirstName LastName
Ye Tao
3 E Network Technology Group Ltd
January 26, 2024
Page 2
            Please contact Chen Chen at 202-551-7351 or Chris Dietz at 202-551-3408 if you have
questions regarding comments on the financial statements and related matters. Please contact
Mariam Mansaray at 202-551-6356 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anna Wang