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February 5, 2024
Tingfeng Weng
Chief Executive Officer
Wing Yip Food Holdings Group Ltd
No.9, Guanxian North Rd,
Huangpu Town, Zhongshan City,
Guangdong, China 528429
Re:Wing Yip Food Holdings Group Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted January 23, 2024
CIK No. 0001999860
Dear Tingfeng Weng:
            We have reviewed your amended draft registration statement and have the following
comments.
            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
December 22, 2023 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Liquidity and Capital Resources
Cash Flows
Operating Activities, page 67
1.We have read your response and revised disclosures on page 67 to prior comment five.
Please also revise your discussion on page 68 to provide a more informative discussion
and analysis of cash flows from operating activities, including changes in working capital
components, for the fiscal years ended December 31, 2022 and 2021.

 FirstName LastNameTingfeng Weng
 Comapany NameWing Yip Food Holdings Group Ltd
 February 5, 2024 Page 2
 FirstName LastName
Tingfeng Weng
Wing Yip Food Holdings Group Ltd
February 5, 2024
Page 2
Compensation of Directors and Executive Officers, page 118
2.Please update your compensation information for the fiscal year ended December 31,
2023.
Financial Statements
Note 2. Summary of significant accounting policies
Revenue Recognition, page F-12
3.We have read your response and revised disclosures on pages F-12 and F-37 to prior
comment nine. We note on page F-37 that your disclosures still indicate that "for each
performance obligation satisfied at a point in time, the Company recognizes revenue at a
point in time by measuring the progress toward complete satisfaction of that performance
obligation." Please revise your disclosure to be consistent with your revenue recognition
policy on page F-12.
General
4.We note your disclosure that on November 30, 2023, you submitted the filing report and
related materials to the CSRC.  Please continue to update your disclosure with regard to
the status of the CSRC review.
            Please contact Ernest Greene at 202-551-3733 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Erin Donahue at 202-551-6063 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing