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Correspondence 0001213900-24-111138 from Cellyan Biotechnology Co., Ltd (HKPD)

Cellyan Biotechnology Co., Ltd
Date: Dec. 20, 2024 · CIK: 0002007702 · Accession: 0001213900-24-111138

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File numbers found in text: 333-282876

Date
December 20, 2024
Author
Bancroft Capital, LLC
Form
CORRESP
Company
Cellyan Biotechnology Co., Ltd

Letter

Bancroft Capital, LLC

501 Office Center Drive, Suite 130

Fort Washington, PA 19034

December 20, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nasreen Mohammed, and Suying Li

Re: Hong Kong Pharma Digital Technology Holdings Limited (CIK No. 0002007702)

Registration Statement on Form F-1, as amended (File No. 333-282876)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and the other underwriters, hereby join in the request of Hong Kong Pharma Digital Technology Holdings Limited that the effective date of the above-referenced registration statement be accelerated so as to permit it to become effective at 4:30 p.m., Eastern Time, on December 20, 2024 or as soon thereafter as practicable.

Pursuant to 460 under the Act, we wish to advise you that the underwriters will distribute as many copies of the preliminary prospectus dated December 10, 2024 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such preliminary prospectus.

The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,
Bancroft Capital, LLC

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CORRESP
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Bancroft Capital, LLC

501 Office Center Drive, Suite 130

Fort Washington, PA 19034

December 20, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Nasreen Mohammed, and Suying Li

    Re:
    Hong Kong Pharma Digital Technology Holdings Limited (CIK No. 0002007702)

    Registration Statement on Form F-1, as
amended (File No.  333-282876)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and
the other underwriters, hereby join in the request of Hong Kong Pharma Digital Technology Holdings Limited that the effective date of
the above-referenced registration statement be accelerated so as to permit it to become effective at 4:30 p.m., Eastern Time, on December
20, 2024 or as soon thereafter as practicable.

Pursuant to 460 under the
Act, we wish to advise you that the underwriters will distribute as many copies of the preliminary prospectus dated December 10, 2024
to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such preliminary prospectus.

The undersigned advises
that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    Bancroft Capital, LLC

    By:
    /s/ Jason Diamond

    Name:
    Jason Diamond

    Title:
    Head of Investment Banking