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CORRESP
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 June 13, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, NE

Washington, DC 20549

    Re:
    HCYC Holding Company

    Amendment No. 3 to Registration Statement on Form F-4

    Filed May 6, 2025

    File No. 333-282624

Ladies and Gentlemen:

On behalf of our client, AlphaTime
Acquisition Corp. (“ATMC”) and HCYC Holding Company (“HCYC”), represented by Celine & Partners,
PLLC, we are writing to submit responses to the comments of the staff (the “Staff”) of the Division of Corporation
Finance of the United States Securities and Exchange Commission (the “Commission”) set forth in its letter, dated
June 2, 2025, relating to HCYC’s Amendment No. 3 to Registration Statement on Form F-4 filed May 6, 2025.

HCYC is filing via EDGAR Amendment
No. 4 to Registration Statement on Form F-4, which reflects responses to the comments received by the Staff and certain updated information.

We have set forth below the comments
in the Staff’s letter, in bold, and the responses thereto.

Amendment No. 3 to Registration Statement on Form
F-4

General

1. Please
                                            update your registration statement throughout to provide disclosure as of a recent date.
                                            As examples only, we note that your beneficial ownership tables on pages 183 and 184 are
                                            as of January 4, 2024. Similarly, it appears that your related party transactions section
                                            has not been updated to include new related party transactions listed in Note 4 to the financial
                                            statements on page F-50.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on pages 183, 184 and F-36 have been revised to address the Staff’s
comment.

2. Based
                                            on your disclosure on page F-50 it appears that there may be an outstanding loan to Mr. Kwok
                                            Wai Man, Chief Executive Officer of HCYC HK. Please tell us if there are outstanding loans
                                            to be paid off by your officers or directors and if so if the loans will be paid off prior
                                            to completion of the merger.

Response:
 We acknowledge the Staff’s comment and confirm that there are no loans to be paid off by HCYC officers or directors to HCYC.

 For
the sake of clarity, the related party balances with Mr. Kwok Wai Man that appear on page F-54, represent amounts owed by HCYC to him.
These balances consist of payables for referral services and non-interest-bearing borrowings from Mr. Kwok Wai Man.

3. We
                                            note your disclosure on page F-53 that “[f]or six months ended September 30, 2024,
                                            three customers accounted for approximately 45.5 %, 41.8 % and 12.1 % of the Company’s
                                            total revenue. For the six months ended September 30, 2023, two customers accounted for approximately
                                            81.0 % and 13.4 % of the Company’s total revenue. As of September 30, 2024, two customers’
                                            accounts receivable accounted for 72.2 % and 17.3 % of the total outstanding accounts receivable
                                            balance. Two customers accounted for approximately 63.7 % and 32.9 % of the total accounts
                                            receivable balance as of March 31, 2024.” Please revise your business section and the
                                            risk factor on page 54 to update information related to your customer concentrations.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on pages 54 and 164 have been revised to address the Staff’s comment.

Summary of the Proxy Statement/Prospectus

Selected Unaudited Financial Information of HCYC,
page 26

4. Please
                                            revise your discussion here, and on page 162, to properly reflect gross profit of $1,407,344
                                            for the fiscal year ended March 31, 2024, compared to $308,694 for the same period of 2023.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on pages 26 and 162 have been revised to address the Staff’s comment.

Recent Developments, page 47

5. We
                                            note your response to prior comment 1, and your revised disclosure on pages 47 and 72. Noting
                                            that your extension to comply with the Nasdaq Minimum Public Holders Rule appears to have
                                            passed as of May 28, 2025, please update your disclosure here and in the risk factor starting
                                            on page 72 as it relates to compliance with this rule. Similarly, update your disclosure
                                            related to compliance with the Nasdaq Minimum Market Value of Listed Securities Requirement.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on pages 47 and 72 have been revised to address the Staff’s comment.

Redemption Rights, page 47

6. We
                                            note your response to prior comment 3 and your revised disclosure describing the shareholders’
                                            redemption rights. Please further expand your discussion to describe the rights of non-redeeming
                                            shareholders and the events that permit for redemption, such as extensions of deadlines to
                                            consummate the merger or other events.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on page 47 has been revised to address the Staff’s comment.

7. We
                                            note your disclosure that “AlphaTime does not expect to extend the time period to consummate
                                            its initial business combination beyond 36 months from the closing of the IPO (any such extension
                                            would be made in compliance with Nasdaq Rule 5101-2(d)).” We also note that you are
                                            currently listed on Nasdaq and that Nasdaq Rule 5815 was amended effective October 7, 2024
                                            to provide for the immediate suspension and delisting upon issuance of a delisting determination
                                            letter for failure to meet the requirement in Nasdaq Rule IM 5101-2(b) to complete one or
                                            more business combinations within 36 months of the date of effectiveness of its IPO registration
                                            statement. Please revise to state that your securities will face immediate suspension and
                                            delisting action once you receive a delisting determination letter from Nasdaq after the
                                            36-month window ends on December 30, 2025.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on page 47 has been revised to address the Staff’s comment.

Alphatime’s Management’s Discussion and Analysis

Other Contractual Obligations, page 153

8. We
                                            note that you have removed the disclosure that “[a]fter the Company’s IPO, the
                                            underwriters of the Company did not provide other additional services for the merger agreement
                                            and no additional services fees were incurred. The deferred underwriting commission will
                                            be paid upon the completion of the initial business combination.” Please reinstate
                                            your prior disclosure or provide updated disclosure related to underwriter compensation.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on page 153 has been revised to address the Staff’s comment.

Transforming the Customer Journey, page 164

9. Please
                                            revise your disclosure on pages 54 and 164 to include the percentage of revenue and accounts
                                            receivable attributed to your two major partnered insurance providers, similar to that provided
                                            on page F-39.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on pages 54 and 164 have been revised to address the Staff’s comment.

HCYC’s Management’s Discussion and Analysis

Results of Operations

Cost of Revenues, page 179

10. We
                                            note your disclosure that the number of first-year policy referral purchases increased from
                                            485 for the six months ended September 30, 2023 to 239 for the six months ended September
                                            30, 2024. Please revise your disclosure to clarify whether referral purchases increased or
                                            decreased and to ensure that the metrics provided are consistent with this disclosure.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on page 179 has been revised to address the Staff’s comment.

Gross Profit, page 179

11. Please
                                            revise your disclosure to clarify, if true, that the decrease in gross profit was primarily
                                            due to a decrease in the number of first-year policies facilitated.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on page 179 has been revised to address the Staff’s comment.

Compensation and benefits, page 179

12. Please
                                            revise your disclosure to include compensation and benefits as a separate line item in your
                                            breakdown of general and administrative expenses so that it agrees to your statements of
                                            operations. Alternatively, revise your disclosure to clarify that compensation and benefits
                                            expense is included in total general and administrative expenses as disclosed in your statements
                                            of operations.

Response: We acknowledge the Staff’s
comment and advise the Staff that at the disclosure on page179 has been revised to address the Staff’s comment.

Item 21. Exhibits and Financial Statement Schedules, page II-1

13. We
                                            note your disclosure on page F-9 that on April 14, 2025 you amended and restated the promissory
                                            notes with Alphamade Holding LP. Please file the amended promissory notes as exhibits to
                                            your registration statement or advise.

Response: We acknowledge the Staff’s
comment and advise the Staff that the amended and restated promissory notes have been included as Exhibits 10.22 and 10.23 to address
the Staff’s comment.

* * * * * * *

If you have any questions, please
feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter.

    Sincerely,

    /s/ Michael J. Blankenship

    Michael J. Blankenship