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June 6, 2024
Yue Zhu
Chief Executive Officer
Lianhe Sowell International Group Ltd
Shenzhen Integrated Circuit Design Application Industry Park
Unit 505-3
Chaguang Road No. 1089
Nanshan District, Shenzhen, China
Re:Lianhe Sowell International Group Ltd
Registration Statement on Form F-1
Filed May 10, 2024
File No. 333-279303
Dear Yue Zhu:
            We have reviewed 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. Unless we note otherwise,
any reference to prior comments are to comments in our January 25, 2024 letter.
Form F-1 filed May 10, 2024
General
1.We note the changes you made to your disclosure appearing on the cover page, Prospectus
Summary and Risk Factor sections relating to legal and operational risks associated with
operating in China and PRC regulations. It is unclear to us that there have been changes in
the regulatory environment in the PRC since your last submission on February 29, 2024
warranting revised disclosure to mitigate the challenges you face and related disclosures.
The Sample Letters to China-Based Companies sought specific disclosure relating to the
risk that the PRC government may intervene in or influence your operations at any time,
or may exert control over operations of your business, which could result in a material
change in your operations and/or the value of the securities you are registering for sale.
The Sample Letters also sought specific disclosures relating to uncertainties regarding the

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Lianhe Sowell International Group Ltd
June 6, 2024
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enforcement of laws and that the rules and regulations in China can change quickly with
little advance notice. Your revised disclosure in response to prior comment 3 that PRC
laws and regulations can be “revised, adjusted or refined with detailed rules” does not
appear to convey the same risk. Please revise your disclosure.
2.Please update your financial statements for the year ended March 31, 2024, or file an
exhibit to the registration statement making the necessary representations as to why such
update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instructions thereto.
Risk Factors
Our business may be exposed to risks associated with an increasingly concentrated customer
base., page 22
3.We note your revised disclosure and response to prior comment 4. Please revise to
disclose specifically when you entered into the long-term contract with Dongguan
Kangzhihui Electronics Co. Ltd. (Dongguan) and identify the specific terms in this
contract (e.g., whether this contract locks in pricing, requires minimum purchase orders,
etc.). Tell us whether you intend to enter into similar long-term contracts with other
customers, or otherwise explain why you entered into a long-term contract with this
customer only. Finally, clarify whether all revenue generated by Dongguan, which you
disclose was 23.4% for the six-months ended September 30, 2023, and 17.6% for the
year-ended March 31, 2023, relates to this contract.
Risks Related to Doing Business in China, page 38
4.We note that you have removed references to China in this risk factor and removed the
statement that "Intellectual Property rights and confidentiality protections in China may
not be as effective as in the US.” Please explain to us the basis for making these revisions.
Capitalization, page 62
5.Please revise to reflect both your capitalization and indebtedness for each scenario
presented. Refer to guidance in Item 3.B of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
65
6.We note one of your growth strategies is to strengthen your marketing and sales network
to serve an expanding customer base in China. Please tell us whether you track the
number of customers and consider this to be a key performance indicator. We also note
your discussion of long-term cooperative relationships. Tell us the number of repeat
customers for each period presented and your consideration to disclose such information.
Additionally, tell us whether management uses any other key performance indicators or
metrics in evaluating your business and if so, revise to include both a qualitative and
quantitative discussion of any such metrics. Refer SEC Release No. 33-10751.

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 Comapany NameLianhe Sowell International Group Ltd
 June 6, 2024 Page 3
 FirstName LastName
Yue Zhu
Lianhe Sowell International Group Ltd
June 6, 2024
Page 3
Critical Accounting Policies and Estimates, page 75
7.Your revised disclosures in response to prior comment 5 appear to be a repetition of
certain of your significant accounting policies as disclosed in Note 2 to your financial
statements. Please revise here to address the material implications of the uncertainties that
are associated with the methods, assumptions and estimates underlying
your critical accounting estimates. Your expanded disclosure should address the risk
related to using different assumptions and analyze their sensitivity to change based on
outcomes that are deemed reasonably likely to occur. Refer to Item 5.E of Form 20-F.
            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 Rules 460 and 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.
            Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499 if
you have questions regarding comments on the financial statements and related matters. Please
contact Uwem Bassey at 202-551-3433 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anna J. Wang