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June 24, 2024
Albert Wong
Chief Executive Officer
Eastern International Ltd.
Suite 901-903, 9th Floor, Building #2, Qianwan Zhigu
Chuanhua Smart CenterScience and Technology City Block
Xiaoshan Economic and Technological Development Zone
Xiaoshan District, Hangzhou, Zhejiang Province, China 311231
Re:Eastern International Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted June 12, 2024
CIK No. 0002013320
Dear Albert Wong:
            We have reviewed your amended draft registration statement and have the following
comments.
            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 18, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Enforceability of Civil Liabilities, page 51
1.We note your response to prior comment 7, including added disclosure that, among your
executive officers and directors, Albert Wong, Ching Hei Li, Chung Leung Cheung, Lin
Tan, Chun Pong (Colman) Chiu and Shiu Wing Joseph Chow are residents of Hong Kong
or China. Please revise to clarify which individuals are located in China, and which are
located in Hong Kong. Please also include a separate sub-section addressing the
enforceability of civil liabilities in Hong Kong and revise your related risk factor at page
28 accordingly.

 FirstName LastNameAlbert Wong
 Comapany NameEastern International Ltd.
 June 24, 2024 Page 2
 FirstName LastName
Albert Wong
Eastern International Ltd.
June 24, 2024
Page 2
Compensation of Directors and Executive Officers, page 95
2.We note your response to prior comment 12. Please clarify whether any compensation
paid to your executive officer for his services was paid pursuant to a bonus or profit-
sharing plan, or in the form of stock options. If so, please provide the disclosure required
by Item 6.B.(1)(a) and (b) of Form 20-F.
Principal Shareholders, page 99
3.We note your response to prior comment 13 and reissue it. You indicate here that your
principal shareholders are those who beneficially own more than 5% of your Ordinary
Shares. Item 7.A.1 of Form 20-F requires information for shareholders who are beneficial
owners of 5% or more of each class of the voting securities. Please revise your disclosure,
including your tabular disclosure, to include each class of the voting securities, including
your preferred shares.
            Please contact Myra Moosariparambil at 202-551-3796 or Shannon Buskirk at 202-551-
3717 if you have questions regarding comments on the financial statements and related
matters. Please contact Michael Purcell at 202-551-5351 or Liz Packebusch at 202-551-8749
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Jeffrey Li