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January 23, 2024
Hoi Lung Chan
Chief Executive Officer
Mint Inc Ltd
503 Park Tower, 15 Austin Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:Mint Inc Ltd
Draft Registration Statement on Form F-1
Submitted December 22, 2023
File No. 377-07022
Dear Hoi Lung Chan:
            We have reviewed your 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.
Form F-1
Permission required from Hong Kong and PRC authorities, page 12
1.We note your disclosure that you are not required to obtain any permission or approval
from Hong Kong authorities to operate your business, or from Hong Kong or PRC
authorities to conduct this offering or list overseas. Please revise to state, if true, that you
are not required to obtain any permission or approval from PRC authorities to operate
your business. Also revise to clarify whether you relied on the opinion of counsel to come
to this conclusion and, if you did not, please explain why. Finally, please revise the last
sentence of this section so that it applies to all permissions or approvals required by PRC
authorities, as opposed to only permissions or approvals required by the CAC and CSRC.
2.Please state here, as you do on the prospectus cover page, that the legal and operational
risks that arise from operating in Mainland China also apply to businesses operating in
Hong Kong and Macau.

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 January 23, 2024 Page 2
 FirstName LastNameHoi Lung Chan
Mint Inc Ltd
January 23, 2024
Page 2
Risk Factors
There remain some uncertainties as to whether..., page 31
3.We note that you do not appear to have relied upon an opinion of counsel with respect to
your conclusions that you do not believe you will be deemed an “operator of critical
information infrastructure,” and therefore will not be subject to cybersecurity review by
the CAC for this offering. If true, state as much and explain why such an opinion was not
obtained. If you did rely on the opinion of counsel, please revise to name counsel and file
the consent of counsel as an exhibit.
Description of Business
Employees, page 85
4.We note your disclosure of 15 full time employees as of March 31, 2023. Please update to
include the number of employees for each of the last three financial years and the
geographic location of these employees. If applicable, also include any significant change
in the number of employees and information regarding the relationship between
management and labor unions. Refer to Item 6.C of Form 20-F.
Taxation, page 117
5.Please revise to describe the impact on you of China’s Enterprise Income Tax Law and
of the arrangement between Mainland China and the Hong Kong Special Administrative
Region for the Avoidance of Double Taxation.
Alternate Prospectus Cover Page, page A-1
6.Please revise the alternate prospectus cover page of the Resale Prospectus to include the
disclosure requested by comments 1-4 of the Division of Corporation Finance's Sample
Letter to China-Based Companies issued by the Staff in December 2021. Also revise to
state, if true and as you do on the prospectus cover page of the Public Offering Prospectus,
that the resale offering is contingent upon the company's Class A ordinary shares
being listed on the Nasdaq Capital Market.
General
7.Please provide us with supplemental 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.
Prospectus Cover Page
8.Please disclose the individual and aggregate ownership percentages to be held by your two
largest shareholders upon completion of this offering, the names of such shareholders, the
controlling persons of such shareholders, and the fact that, if they act together, they will

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 January 23, 2024 Page 3
 FirstName LastNameHoi Lung Chan
Mint Inc Ltd
January 23, 2024
Page 3
control the management and affairs of the company and most matters requiring
shareholder approval, including the election of directors and approval of significant
corporate transactions. This comment applies to the prospectus cover page of the Resale
Prospectus, as well.
9.Here and in the prospectus summary, please state that Chinese regulatory authorities
could disallow your organizational structure, which would likely result in a material
change in your operations and/or a material change in the value of the securities you are
registering for sale, including that it could cause the value of such securities to
significantly decline or become worthless.
10.We note your disclosure regarding whether payments were made by the holding company
to shareholders, by your subsidiaries to the holding company, between the holding
company and the operating subsidiary, and by the operating subsidiary to shareholders.
Here and in the prospectus summary, please revise to also address whether payments were
made by the holding company to your subsidiaries, by your subsidiaries to investors or the
operating subsidiary, and by the operating subsidiary to your subsidiaries. Also provide on
the cover page a general description of how cash is transferred through your organization,
as you do in the first paragraph on page 3.
11.Please amend your disclosure here and in the summary risk factors and risk factors
sections to state that, to the extent cash or assets in the business is in the PRC/Hong Kong
or a PRC/Hong Kong entity, the funds or assets may not be available to fund operations or
for other use outside of the PRC/Hong Kong due to interventions in or the imposition of
restrictions and limitations on the ability of you or your subsidiaries by the PRC
government to transfer cash or assets.  On the cover page, provide cross-references to
these other discussions.
12.We note your discussion of cash management policies on page 3. Please include this
discussion on the prospectus cover page, as well.
13.Please state here, as you do on page 34, that compliance with Hong Kong's Personal Data
(Privacy) Ordinance and other data privacy laws in Hong Kong may entail epenses and
materially affect your business.

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 January 23, 2024 Page 4
 FirstName LastName
Hoi Lung Chan
Mint Inc Ltd
January 23, 2024
Page 4
            Please contact Abe Friedman at 202-551-8298 or Rufus Decker at 202-551-3769 if you
have questions regarding the financial statements and related matters. Please contact Jenna
Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jason Ye