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June 6, 2024
Lap Sun Wong
Chief Executive Officer and Chairman of the Board
Hong Kong Pharma Digital Technology Holdings Ltd
Room B1, 5/F., Well Town Industrial Building
13 Ko Fai Road, Yau Tong, Kowloon
Hong Kong
Re:Hong Kong Pharma Digital Technology Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted May 14, 2024
CIK No. 0002007702
Dear Lap Sun Wong:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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. Unless we note otherwise, any references to prior comments are to comments in our
April 26, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Prospectus Summary
Risks Related to Doing Business in Hong Kong, page 5
1.We note your response to prior comment 5 and reissue it. In this regard, we still note your
statements here and on page 35 that "the legal and operational risks associated with
operations in China may also apply to our operations in Hong Kong (emphasis added)."
Additionally, we note your representation on page 11 that "it is possible that all the legal
and operational risks associated with being based in and having operations in the PRC
also apply to operations in Hong Kong in the future (emphasis added)." Please revise your
disclosure here and elsewhere as appropriate to affirmatively clarify that the legal and

 FirstName LastNameLap Sun Wong
 Comapany NameHong Kong Pharma Digital Technology Holdings Ltd
 June 6, 2024 Page 2
 FirstName LastNameLap Sun Wong
Hong Kong Pharma Digital Technology Holdings Ltd
June 6, 2024
Page 2
operational risks associated with operating in China also apply to operations in Hong
Kong.
Transfer of Cash Through Our Organization, page 10
2.We note your response to prior comment 7. Please revise here to explicitly clarify whether
any dividends, or distributions have been made to U.S. investors to date. In this regard,
although we note your response that "no dividends or distributions have been made by any
of our HK Subsidiaries or Hong Kong Pharma to date, including to any U.S. investors,"
your disclosure is silent on this point.
Risk Factors
Certain customers contributed to a significant percentage of our total revenue . . ., page 23
3.We note your response to prior comment 13 and reissue it in part. Please file your
agreements with CaiNiao as exhibits to the registration statement or, alternatively, tell us
why you believe you are not required to do so. See Item 601(b)(10) of Regulation S-K. In
this regard, we note that you have filed summaries of the material terms of your
agreements rather than filing the agreements themselves.
Compensation of Directors and Officers, page 98
4.Revise to update this discussion for the fiscal year ended March 31, 2024, consistent with
Item 6.B. of Form 20-F. This comment also applies to your related party transaction
disclosure on page 101. Refer to Item 7.B. of Form 20-F.
Consolidated Financial Statements, page F-1
5.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F or
include the representation noted in Instruction 2 to Item 8.A.4 of Form 20-F as an exhibit
to your registration statement.
Note 3 - Significant Accounting Policies
Revenue Recognition , page F-10
6.We note your response to prior comment 22 and reissue the comment in part. Please
discuss your policy for returns, refunds, and other similar obligations. Refer to paragraph
119(d) of IFRS 15.
Note 5 - Key Sources of Estimation Uncertainty
Allowance for expected credit losses, page F-20
7.We note your response to prior comment 23 and reissue the comment in part. You state
that “in general, if a receivable’s ageing is more than 1 year, it is very possible to be
uncollectable or with certain disputes. As such, the management will examine all balances
longer than 1 year and distinguish which are in special events to be not collectable.”
Please explain how your policy complies with the current expected credit loss model in

 FirstName LastNameLap Sun Wong
 Comapany NameHong Kong Pharma Digital Technology Holdings Ltd
 June 6, 2024 Page 3
 FirstName LastName
Lap Sun Wong
Hong Kong Pharma Digital Technology Holdings Ltd
June 6, 2024
Page 3
IFRS 9, where it is not necessary for a credit event to have occurred before credit losses
are recorded. Please discuss the judgements, assumptions and estimates utilized
in determining the expected credit loss for each period.
            Please contact Nasreen Mohammed at 202-551-3773 or Suying Li at 202-551-3335 if you
have questions regarding comments on the financial statements and related matters. Please
contact Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Kevin Sun