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February 16, 2024
Chuanbo Jiang
Chief Executive Officer
STAK Inc.
Building 11, 8th Floor, No. 6 Beitanghe East Road,
Tianning District, Changzhou, Jiangsu,
People’s Republic of China, 213000
Re:STAK Inc.
Draft Registration Statement on Form F-1
Submitted January 18, 2024
CIK No. 0002002453
Dear Chuanbo Jiang:
            We have reviewed your 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.
Draft Registration Statement on Form F-1
Cover page
1.We note that you expect more than 50% of your voting power to be held by an individual,
a group or another company and your Chief Executive Officer currently beneficially holds
77% of your common stock.  Please disclose whether you intend to be a “controlled
company” as defined under the Nasdaq listing rules and, if so, whether you intend to rely
on the exemptions as a controlled company.  If applicable, please include risk factor
disclosure that discusses the effect, risks and uncertainties of being designated a controlled
company, including but not limited to, the result that you may elect not to comply with
certain corporate governance requirements.
2.Please disclose whether any transfers, dividends, or distributions have been made to
investors to date, and quantify the amount if applicable.

 FirstName LastNameChuanbo Jiang
 Comapany NameSTAK Inc.
 February 16, 2024 Page 2
 FirstName LastName
Chuanbo Jiang
STAK Inc.
February 16, 2024
Page 2
Conventions Which Apply to this Prospectus, page 2
3.We note your definition of "China" and the "PRC" appears to exclude Taiwan, Hong
Kong and Macau. Please clarify that the legal and operational risks associated with
operating in China also apply to operations in Hong Kong. This disclosure may appear in
the definition itself or in an appropriate discussion of legal and operational risks.
Market and Industry Data, page 4
4.Please disclose whether the industry report issued by Beijing Bo Yan Zhishang
Information Advise Co., Ltd. was commissioned by the company in connection with this
offering or registration statement.
Our Products
Oilfield-Specialized Vehicles, page 7
5.We note your disclosures on pages 6 and 55 that you do not hold a special vehicle
production permission to produce special vehicles. Clarify your disclosure if the entire
vehicle production is outsourced or if you supply oilfield components to the outsourced
manufacturer. Further disclose if you take ownership of these vehicles prior to being
shipped to customers as well as if these vehicles are branded as your company.
Prospectus Summary
Corporate History and Structure, page 8
6.Please revise your disclosure to provide a complete description of your corporate history.
Risk Factors
Risks Related to Doing Business in China, page 24
7.Please disclose 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 your securities.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Components of Results of Operations
Revenues, page 44
8.Please clarify your statement that sales of specialized oilfield vehicles increased as you,
“expanded [y]our business to the manufacturing and sales of specialized oilfield vehicles
in August 2022.” In this regard, we note your disclosures on pages 31 and 62 that you
outsource specialized vehicle production. In addition, further clarify your statement under
Cost of revenues, “that more staff were hired for production of specialized oilfield
vehicles” in light of your outsourcing of oilfield vehicle production.

 FirstName LastNameChuanbo Jiang
 Comapany NameSTAK Inc.
 February 16, 2024 Page 3
 FirstName LastName
Chuanbo Jiang
STAK Inc.
February 16, 2024
Page 3
Business
Overview, page 53
9.Please explain the form of support your initial public offering plan has received from your
local government. Please also clarify what you mean by "various favorable conditions" for
your initial public offering. In addition, please describe the terms of the Investment
Promotion and Protection Agreement that you entered into with the Changzhou Tianning
Economic Development Zone.
Our Products and Solutions, page 56
10.Please revise your disclosure to explain the "seven categories" you had as of June 30,
2023 and to discuss the stage of development or production the vehicle models and
oilfield-specialized production and maintenance equipment are in.
Our Supply Chain, page 62
11.Please disclose whether you have agreements with the manufacturers holding specialized
vehicle production qualifications with whom you have partnered. If you do have such
agreements, discuss the material terms of those agreements. Also, file them as exhibits or
tell us why they are not required to be filed. Refer to Item 601(b)(10)(ii)(B) of Regulation
S-K.
Related Party Transactions, page 83
12.Please provide context for the shareholder contributions disclosed in this section. For
example, disclose whether the amounts in the table were given to you and whether any
consideration was exchanged for the contribution.
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies , page F-8
13.Please clarify if you provide warranties related to your products. In addition, we note your
disclosures on pages 31 and 62 that you outsource specialized vehicle production. Explain
if there is a warranty on these vehicles and who provides this warranty. Refer to ASC 460-
10-50-8(b) and 50-8(c).
(m) Revenue recognition, page F-10
14.Please address the following items:

•For each of your product lines, identify who you have determined to be your
customer. Refer to ASC 606-10-20.
•Your disclosure states that revenue is recognized at a point in time upon the
customer’s acceptance of products. Expand your disclosure to explain when this
occurs.

 FirstName LastNameChuanbo Jiang
 Comapany NameSTAK Inc.
 February 16, 2024 Page 4
 FirstName LastName
Chuanbo Jiang
STAK Inc.
February 16, 2024
Page 4
•We note your disclosure for service income from automation solutions includes
software development, training, debugging, maintenance, and other services. Please
explain in sufficient detail how you concluded that each of these services are not
distinct as noted in your disclosure. Refer to ASC 606-10-25-14 and 19.
15.We note your disclosure that "[you] outsource specialized vehicle production"(your page
62) and that the "vehicle chassis used in oilfield vehicles and equipment is designed by the
Company and produced by qualified special vehicle manufacturers". Please explain how
you concluded that you bear inventory risk for the sale of vehicles. Disclose if you receive
these vehicles from the manufacturers or if these vehicles are shipped directly from the
manufacturers to your customers. In addition, please explain the nature and reasons for the
inventory item labeled as "Goods in transit" as disclosed within Footnote 5 - Inventories.
16.We note your statement that  "Company would control the source code and script and
would not have the enforceable right to the payment until the delivery of the service".
Describe whether the customer has termination rights.  That is, please clarify whether a
right to payment upon termination is specified in the contract with the customer. If no
such payment is due, consider disclosing that each party has the unilateral right to
terminate the contract at any time without any compensation to the other party for such
termination, if true. Refer to ASC 606-10-25-4.
Note 3 Discontinued Operations, page F-14
17.We note that you recognized a gain of $299,698 was recorded as the result of the disposal
and classified this gain in income from continuing operations. Since the gain is a result of
discontinued operations please consider whether this gain should be classified with
the loss from discontinued operations section of the Consolidated Statements of Income
and Comprehensive Income. Refer to ASC 205-20-45-3 and 45-3A.
General
18.We note your disclosure that you relied upon advice from your PRC counsel, DeHeng
Law Offices (Shenzhen). Please file a consent from your PRC counsel as an exhibit.
19.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,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.

 FirstName LastNameChuanbo Jiang
 Comapany NameSTAK Inc.
 February 16, 2024 Page 5
 FirstName LastName
Chuanbo Jiang
STAK Inc.
February 16, 2024
Page 5
            Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at 202-551-3488 if you
have questions regarding comments on the financial statements and related matters. Please
contact Lauren Pierce at 202-551-3887 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Lawrence S. Venick, Esq.