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CORRESP
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Correspondence

VIA EDGAR

December 13, 2024

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

  Attention:
  Chris Dietz

  Mariam Mansaray

  Jan Woo

    Re:
    3 E Network Technology Group Limited

    Amendment No. 4 to Registration Statement
    on Form F-1

    Filed December 4, 2024

    File No. 333-276180

Ladies and Gentlemen,

On behalf of 3 E Network Technology Group Limited
(the “Company”), we are hereby submitting this letter to the Securities and Exchange Commission (the “Commission”)
via EDGAR in response to the comment letter from the staff of the SEC (the “Staff”), dated December 12, 2024 (the
“Comment Letter”), pertaining to the Company’s above-referenced Amendment No. 4 to the Registration Statement
on Form F-1 (“Amendment No. 4”) filed on December 4, 2024. Concurrently with the submission of this letter, the Company
is filing Amendment No. 5 to the Registration Statement on Form F-1 (“Amendment No. 5”) via EDGAR to the Commission.

Set forth below are the Company’s responses
to the Staff’s comments. The responses set forth below are based upon information provided by the Company, which we have not independently
verified. For the convenience of the Staff, the responses contained herein utilize the numbering of the comments and the headings used
in the Comment Letter, and the text of the Staff’s comments is reproduced in italics below. Capitalized terms used but not defined
herein have the meanings set forth in the Form F-1.

Amendment No.4 to Registration Statement on
Form F-1

Dilution

1. We are unable to recalculate the net tangible book value after
                                            the offering. Please reconcile, in your response, the net tangible book value in dollars
                                            before the offering to the net tangible book value after the offering. As part of your response,
                                            please tell us how deferred IPO costs are considered in your calculations.

Response:

The Company acknowledges the Staff’s comment and respectfully submits that, upon recalculation, the Company’s as-adjusted
net tangible book value as of June 30, 2024 was $1,215,543, or $0.12 per Class A Ordinary Share. After giving effect to the sale of 1,200,000
Class A Ordinary Shares in the initial public offering contemplated hereby, its pro forma as adjusted net tangible book value as of June
30, 2024 is $6,281,048, or $0.56 per Class A Ordinary Share, assuming the underwriter does not exercise the option to purchase additional
Class A Ordinary Shares. In determining the net tangible book value before the IPO, the Company excluded deferred IPO costs of $1,520,975.
For the net tangible book value after the IPO, the Company excluded the estimated underwriting discounts and commissions and offering
expenses with totaling $2,455,470.

Accordingly, the Company
has revised the relevant disclosures on pages 59 and 72 of Amendment No. 5.

*****

Please contact the undersigned at +8610-5680-3969
or via email at rchang@gunder.com if you have any questions with respect to the foregoing.

    Very truly yours,

    /s/ Richard J. Chang

    Richard J. Chang, Esq.

    Gunderson Dettmer Stough Villeneuve

Franklin & Hachigian, LLP

cc: Tingjun Yang, Co-Chief Executive Officer, 3 E Network Technology
Group Limited

  Benjamin A. Tan, Esq, Sichenzia
Ross Friedman Ference LLP