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MaxsMaking Inc.

Room 903, Building 2, Kangjian Business Plaza

No. 1288 Zhennan Road

Putuo District, Shanghai, China, 200331

VIA EDGAR

December 3, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Heather Clark

    Hugh West

    Eranga Dias

    Evan Ewing

    Re:
    MaxsMaking Inc.

    Registration Statement on Form F-1

    Submitted November 13, 2024

    File No. 333-283211

Ladies and Gentlemen:

MaxsMaking Inc. (the “Company,”
“we,” “our” or “us”) hereby transmits our response to the comment letter received
from the staff (the “Staff”, “you” or “your”) of the U.S. Securities and Exchange
Commission (the “Commission”), dated November 27, 2024, regarding the Registration Statement on Form F-1 filed to the
Commission on November 13, 2024.

For the Staff’s convenience,
we have repeated below the Staff’s comment in bold, and have followed each comment with the Company’s response. In response
to the Staff’s comments, the Company is filing via Edgar the Amendment No.1 to the Registration Statement on Form F-1 (the “Amendment
No.1”) simultaneously with the submission of this response letter.

Registration Statement on Form F-1

Capitalization, page F-60

 1. We
note that the “As Adjusted with full Exercise of Over Allotment Option” column reflects the gross proceeds of $10,350,000
(2,300,000 shares*$4.50 per share). However, the third bullet point above states that it reflects the sale of the shares “after
deducting the underwriting discounts and commissions and estimated offering expense.” Please revise the last column in the table
to deduct these expenses.

Response:

In response to the Staff’s comment,
we have revised our disclosures under “Capitalization” section on page 60 of the Amendment No.1.

Dilution, page 61

 2. Please
tell us how you calculated that a $1.00 increase or decrease will change your as adjusted capitalization by $20,675,434. In this regard,
a $1 change in price for 2 million shares would change the capitalization by $2 million less any additional expenses. Please clarify.

Response

We
respectfully advise the Staff that the amount should be $1,820,000  instead
of $20,675,434. Accordingly, we have revised our disclosures under “Dilution” section on page 61 of the Amendment No.1.

 3. Please
tell us how your post offering as adjusted net tangible book value per share of $0.83 per share was determined.

Response:

We respectfully advise the Staff that tangible assets are calculated as total equity minus intangible assets and deferred offering cost,
amounting to $14,054,099. After dividing this amount by the total number of shares, 17,000,000, the adjusted net tangible assets book
value per share is $0.83. Please see the illustration below for our calculations.

    Adjusted Proforma

    Total equity
      14,791,732

    Intangible assets
      7,963

    Deferred offering cost
      729,670

    Tangible assets
      14,054,099

    Total shares
      17,000,000

    Adjusted net tangible assets book value per share
      0.83

Related Party Transactions, page 123

 4. Please
revise your disclosure in this section to provide information up to a more recent date as required by Item 7.B of Form 20-F

Response:

In response to the Staff’s comment,
we have revised our disclosures under “Related Party Transactions” section on page 123 of the Amendment No.1.

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We thank the Staff in advance
for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel, Wei Wang,
Esq., of Ellenoff Grossman & Schole LLP, at (212) 370-1300.

    Sincerely,

    By:
    /s/ Xiaozhong Lin

    Name:
    Xiaozhong Lin

    Title:
    Chief Executive Officer

    cc:

    Wei Wang, Esq.

    Ellenoff Grossman & Schole LLP

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