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 May 30, 2025

Yimin Cai
Chief Executive Officer
Gamehaus Holdings Inc.
5th Floor, Building 2, No. 500 Shengxia Road
Pudong New District, Shanghai
The People's Republic of China, 201210

 Re: Gamehaus Holdings Inc.
 Registration Statement on Form F-1
 Filed May 23, 2025
 File No. 333-287535
Dear Yimin Cai:

 We have conducted a limited review of your registration statement and
have the
following comments.

 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.

Registration Statement on Form F-1
Cover Page

1. Provide prominent disclosure about the legal and operational risks
associated with
 being based in or having the majority of the company s operations in
China. Your
 disclosure should make clear whether these risks could result in a
material change in
 your operations and/or the value of the securities you are registering
for sale or could
 significantly limit or completely hinder your ability to offer or
continue to offer
 securities to investors and cause the value of such securities to
significantly decline or
 be worthless. Your disclosure should address how recent statements and
regulatory
 actions by China s government, such as those related to the use of
variable interest
 entities and data security or anti-monopoly concerns, have or may impact
the
 company s ability to conduct its business, accept foreign investments,
or list on a U.S.
 May 30, 2025
Page 2

 or other foreign exchange. Please disclose the location of your auditor
s headquarters
 and whether and how the Holding Foreign Companies Accountable Act, as
amended
 by the Consolidated Appropriations Act, 2023, and related regulations
will affect your
 company. Your prospectus summary should address, but not necessarily be
limited to,
 the risks highlighted on the prospectus cover page.
2. Clearly disclose how you will refer to the holding company and
subsidiaries when
 providing the disclosure throughout the document so that it is clear to
investors which
 entity the disclosure is referencing and which subsidiaries are
conducting the business
 operations. Refrain from using terms such as we or our when
describing activities
 or functions of a subsidiary or other entity. For example, disclose, if
true, that your
 subsidiaries conduct operations in China, and that the holding company
does not
 conduct operations. Disclose clearly the entity (including the domicile)
in which
 investors are purchasing an interest.
3. Provide a description of how cash is transferred through your
organization. State
 whether any transfers, dividends, or distributions have been made to date
between the
 holding company and its subsidiaries, or to investors, and quantify the
amounts where
 applicable. Provide cross-references to the condensed consolidating
schedule and the
 consolidated financial statements.
Prospectus Summary, page 1

4. In your summary of risk factors, disclose the risks that your corporate
structure and
 being based in or having the majority of the company s operations in
China poses to
 investors. In particular, describe the significant regulatory, liquidity,
and enforcement
 risks with cross-references to the more detailed discussion of these
risks in the
 prospectus. For example, specifically discuss risks arising from the
legal system in
 China, including risks and uncertainties regarding the enforcement of
laws and that
 rules and regulations in China can change quickly with little advance
notice; and the
 risk that the Chinese government may intervene or influence your
operations at any
 time, or may exert more control over offerings conducted overseas and/or
foreign
 investment in China-based issuers, which could result in a material
change in your
 operations and/or the value of the securities you are registering for
sale. Acknowledge
 any risks that any actions by the Chinese government to exert more
oversight and
 control over offerings that are conducted overseas and/or foreign
investment in China-
 based issuers could significantly limit or completely hinder your ability
to offer or
 continue to offer securities to investors and cause the value of such
securities to
 significantly decline or be worthless.
5. Disclose each permission or approval that you, or your subsidiaries are
required to
 obtain from Chinese authorities to operate your business and to offer the
securities
 being registered to foreign investors. State whether you or your
subsidiaries are
 covered by permissions requirements from the China Securities Regulatory
 Commission (CSRC), Cyberspace Administration of China (CAC) or any other
 governmental agency that is required to approve your operations, and
state
 affirmatively whether you have received all requisite permissions or
approvals and
 whether any permissions or approvals have been denied. Please also
describe the
 consequences to you and your investors if you or your subsidiaries: (i)
do not receive
 May 30, 2025
Page 3

 or maintain such permissions or approvals, (ii) inadvertently conclude
that such
 permissions or approvals are not required, or (iii) applicable laws,
regulations, or
 interpretations change and you are required to obtain such permissions
or approvals in
 the future.
6. Provide a clear description of how cash is transferred through your
organization.
 Quantify any cash flows and transfers of other assets by type that have
occurred
 between the holding company and its subsidiaries, and direction of
transfer. Quantify
 any dividends or distributions that a subsidiary has made to the holding
company and
 which entity made such transfer, and their tax consequences. Similarly
quantify
 dividends or distributions made to U.S. investors, the source, and their
tax
 consequences. Your disclosure should make clear if no transfers,
dividends, or
 distributions have been made to date. Describe any restrictions on
foreign exchange
 and your ability to transfer cash between entities, across borders, and
to U.S.
 investors. Describe any restrictions and limitations on your ability to
distribute
 earnings from the company, including your subsidiaries to the parent
company and
 U.S. investors.
Risk Factors
Any actions by the Chinese government..., page 11

7. Given the Chinese government s significant oversight and discretion
over the conduct
 of your business, please revise to highlight separately the risk that
the Chinese
 government may intervene or influence your operations at any time, which
could
 result in a material change in your operations and/or the value of the
securities you are
 registering. Also, given recent statements by the Chinese government
indicating an
 intent to exert more oversight and control over offerings that are
conducted overseas
 and/or foreign investment in China-based issuers, acknowledge the risk
that any such
 action could significantly limit or completely hinder your ability to
offer or continue
 to offer securities to investors and cause the value of such securities
to significantly
 decline or be worthless.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rule 461 regarding requests for acceleration. Please allow
adequate time for
us to review any amendment prior to the requested effective date of the
registration
statement.
 May 30, 2025
Page 4

 Please contact Uwem Bassey at 202-551-3433 or Jeff Kauten at
202-551-3447 with
any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Technology
cc: Kanxian Ding
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