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 April 22, 2025

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. 3 to Registration Statement on Form F-1
 Filed March 31, 2025
 File No. 333-280248
Dear Bin Feng:

 We have reviewed your amended registration statement and have the
following
comment(s).

 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. Unless
we note
otherwise, any references to prior comments are to comments in our November 14,
2024 letter.

Amendment No. 3 to Registration Statement on Form F-1 filed March 31, 2025
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-6

1. Please tell us the nature of the cash flows related to the "Due from
related parties" line
 item. In addition, please tell us your consideration of presenting these
cash flows as
 investing activities pursuant to ASC 230-10-45-12a.
 April 22, 2025
Page 2
2. Summary of Significant Accounting Policies
Reclassifications, page F-21

2. Please tell us the basis for and revise to disclose a description of the
nature of the
 reclassification adjustments. Additionally, please revise the table to
correct the total
 asset and total liabilities amounts.
17. Segment Reporting, page F-32

3. Please tell us how your disclosure considered the adoption of ASU
2023-07.
Exhibit Index
Exhibit 23.1, page II-6

4. The consent only refers to the financial statements as of and the year
ended December
 31. 2024. Please request that your auditor revise the consent to refer
to the financials
 statements as of and the years ended December 31, 2024 and 2023.
General

5. Please revise to reconcile the inconsistencies between your registration
statement and
 your exhibit 5.1 and 5.2 opinions with respect to the amount and type of
securities you
 are offering, and ensure that you include an opinion on the shares
underlying the
 warrants you contemplate offering. In this regard, we note that your
revised exhibit
 5.1 opinion covers 1,250,000 shares as well as an additional 187,500
over-allotment
 shares, and it also no longer opines on the shares underlying the
underwriters'
 warrants. The exhibit 5.2 opinion reflects similar offering amounts.
However,
 according to your registration statement, you contemplate offering up to
3,450,000
 shares (including the over-allotment option), as well as underwriters'
warrants.

 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
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