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May 6, 2024
Bin Feng
Chief Executive Officer and Chairman of the Board
Unitrend Entertainment Group Ltd
Suite 1508, Tower B, Wentelai Center
1 Xidawang Road
Chaoyang District, Beijing 100026
People’s Republic of China
Re:Unitrend Entertainment Group Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted April 16, 2024
CIK No. 0001997950
Dear Bin Feng:
            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
April 9, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted April 16, 2024
"With respect to the television program distribution segment of our business . . . ", page 27
1.We note your response to prior comment 3, as well as your revised disclosure that
identifies your three major customers as of December 31, 2022 that comprised your total
sales, as well as your two major customers that comprised the majority of your accounts
receivable as of December 31, 2022.  Please revise to update your discussion to reflect
your major customers as of December 31, 2023 as it pertains to your total sales
and accounts receivable, as your disclosure on page F-20 is now as of the most recent
fiscal year.  In connection therewith, while you filed the form of distribution agreement,

 FirstName LastNameBin Feng
 Comapany NameUnitrend Entertainment Group Ltd
 May 6, 2024 Page 2
 FirstName LastName
Bin Feng
Unitrend Entertainment Group Ltd
May 6, 2024
Page 2
we note that you did not file the executed customer agreements as exhibits to the
registration statement.  Please tell us whether you substantially depend on such customers,
and to the extent so, please summarize the material terms of such agreements in an
appropriate place in the prospectus and file the related agreements as exhibits to the
registration statement.  Refer to Item 8 of Form F-1 and Item 601(b)(10) of Regulation S-
K.

In addition, we note your disclosure on page F-20 that "[f]or the year ended December 31,
2023, one supplier accounted for 59.4% of the Company’s total purchases," and that "[a]s
of December 31, 2023, three suppliers accounted for 42.2%, 28.8% and 20.0% of the
outstanding accounts payable."  Please also tell us whether you substantially depend on
any such suppliers, and to the extent so, please identify such suppliers, summarize the
material terms of the agreements, include appropriate risk factor disclosure and file such
agreements as exhibits to the registration statement.
"Uncertainties with respect to the PRC legal system . . . ", page 37
2.We note your response to prior comment 4, as well as your revised disclosure, and we
reissue the comment in-part.  In particular, we note that you continue to disclose that "we
are actively preparing our filing with the CSRC in accordance with the Trial Measures" on
page 38, and such disclosure is inconsistent with your disclosure elsewhere that you
"submitted initial documents in connection with this offering and our listing on the
Nasdaq Capital Market to the CSRC on January 22, 2024."  Revise to reconcile.
Industry, page 78
3.Please update your discussion of industry data as of a more recent date, to the extent
available, as such discussion provides estimates for 2023 and actual results as of 2022.
Index to Financial Statements
4. Prepayments of Filming of Documentary and TV Series , page F-23
4.Please tell us and revise to disclose in further detail the nature of these prepayments of
filming of documentary and TV series and how they differ from the refundable
prepayments of copyright and filming of TV series discussed in Note 5.

 FirstName LastNameBin Feng
 Comapany NameUnitrend Entertainment Group Ltd
 May 6, 2024 Page 3
 FirstName LastName
Bin Feng
Unitrend Entertainment Group Ltd
May 6, 2024
Page 3
            Please contact Aamira Chaudhry at 202-551-3389 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Brian Fetterolf at 202-551-6613 or Erin Jaskot at 202-551-3442 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Zixuan Guo