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SEC Comment Letter for Lianhe Sowell International Group Ltd (LHSW) (CIK 0002004024) (LHSW) — Mar 23, 2026

Lianhe Sowell International Group Ltd (LHSW) (CIK 0002004024)
Date: March 23, 2026 · CIK: 0002004024 · Accession: 0000000000-26-002887

Risk Disclosure Financial Reporting Regulatory Compliance

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File numbers found in text: 001-42579

Date
March 23, 2026
Author
Division of
Form
UPLOAD
Company
Lianhe Sowell International Group Ltd (LHSW) (CIK 0002004024)

Letter

Re: Lianhe Sowell International Group Ltd Form 20-F for the Year Ended March 31, 2025 File No. 001-42579 Dear Yue Zhu:

March 23, 2026

Yue Zhu Chief Executive Officer Lianhe Sowell International Group Ltd 15th Floor, Sannuo Smart Building No. 3388 Binhai Ave, Binhai Community Nashan District, Shenzhen, China

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 20-F for the Year Ended March 31, 2025 Introduction, page ii

1. Your definition of China and PRC excludes Macau, Taiwan and Hong Kong for purposes of this Annual Report. Please revise to remove the exclusion of Macau, Taiwan and Hong Kong from such definition. Clarify that all the legal and operational risks associated with having operations in the People s Republic of China (PRC) also apply to operations in Macau, Taiwan and Hong Kong. In this regard, ensure that your disclosure does not narrow risks related to operating in the PRC to mainland China only. Where appropriate, you may describe PRC law and then explain how law in Macau, Taiwan and Hong Kong differs from PRC law and describe any risks and consequences to the company associated with those laws. In your response, please provide us with the revised disclosures that you intend to include in your March 31, 2026 Form 20-F. March 23, 2026 Page 2 Risk Factors We are an "emerging growth company" and we cannot be certain if the reduced disclosure requirements applicable..., page 13

2. We note you have elected to take advantage of the extended transition period provided in Section 7(a)(2)(B) of the Securities Act for complying with new or revised accounting standards. Please revise this risk factor to disclose that, as a result of such election, your financial statements may not be comparable to companies that comply with public company effective dates.

In closing, 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.

Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499 with any questions.

Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Anna J. Wang

Show Raw Text
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<TEXT>
 March 23, 2026

Yue Zhu
Chief Executive Officer
Lianhe Sowell International Group Ltd
15th Floor, Sannuo Smart Building
No. 3388 Binhai Ave, Binhai Community
Nashan District, Shenzhen, China

 Re: Lianhe Sowell International Group Ltd
 Form 20-F for the Year Ended March 31, 2025
 File No. 001-42579
Dear Yue Zhu:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Year Ended March 31, 2025
Introduction, page ii

1. Your definition of China and PRC excludes Macau, Taiwan and Hong Kong
for purposes
 of this Annual Report. Please revise to remove the exclusion of Macau,
Taiwan and
 Hong Kong from such definition. Clarify that all the legal and
operational risks
 associated with having operations in the People s Republic of China
(PRC) also apply to
 operations in Macau, Taiwan and Hong Kong. In this regard, ensure that
your disclosure
 does not narrow risks related to operating in the PRC to mainland China
only. Where
 appropriate, you may describe PRC law and then explain how law in Macau,
Taiwan and
 Hong Kong differs from PRC law and describe any risks and consequences
to the
 company associated with those laws. In your response, please provide us
with the revised
 disclosures that you intend to include in your March 31, 2026 Form 20-F.
 March 23, 2026
Page 2
Risk Factors
We are an "emerging growth company" and we cannot be certain if the reduced
disclosure
requirements applicable..., page 13

2. We note you have elected to take advantage of the extended transition
period provided in
 Section 7(a)(2)(B) of the Securities Act for complying with new or
revised accounting
 standards. Please revise this risk factor to disclose that, as a result
of such election, your
 financial statements may not be comparable to companies that comply with
public
 company effective dates.

 In closing, 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.

 Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at
202-551-3499
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Anna J. Wang
</TEXT>
</DOCUMENT>