SecProbe.io

CORRESP
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filename1.htm

    Direct
                                            Phone: 703.618.2503

    jeffrey.li@fisherBroyles.com

January
21, 2025

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Myra
                                            Moosariparambil

    Shannon
    Buskirk

    Michael
    Purcell

    Liz
    Packebusch

    Re:
    Eastern
                                            International Ltd.

    Amendment
    No. 2 to Registration Statement on Form F-1

    Filed
    December 31, 2024

    File
    No. 333-281900

Ladies
and Gentlemen:

On
behalf of our client, Eastern International Ltd, a foreign private issuer organized under the laws of Cayman Islands (the “Company”,
“We” or “Our”), we are submitting this letter and the following information in response to a letter,
dated January 13, 2025, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
with respect to the Company’s Registration Statement on Form F-1 (the “Registration Statement”) filed
with the Commission on December 31, 2024. Concurrently with the submission of this letter, the Company is filing herewith its Amendment
No.3 to the registration statement on Form F-1 (the “Amended Registration Statement”) and certain exhibits
via EDGAR to the Commission.

To
facilitate your review, we have separately delivered to you a courtesy copy of the Amended Registration Statement, marked to show changes
to the Registration Statement filed with the Commission on December 31, 2024.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used in this letter but otherwise
not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

In
addition to revising the disclosure in response to the Staff’s comments, the Company has also included other information and data
to reflect recent developments.

Amendment
No. 2 to Registration Statement on Form F-1

Index
to Consolidated Financial Statements

Notes
to Unaudited Interim Condensed Consolidated Financial Statements

Note
13 - Segment reporting, page F-29

1. We
                                            note you disclose gross profit, income from operations and segment profit for each segment.
                                            Please tell us, and revise to disclose, the profitability measure used by the CODM for purposes
                                            of making decisions about allocating resources to the segments and assessing performance.
                                            See ASC 280-10-50-28. In addition, please note that the reconciliation required by ASC 280-10-50-30
                                            in the footnotes is the total segment profit measure to your consolidated income before taxes
                                            for each reporting period presented. Last, to the extent a measure is not identified as the
                                            segment measure of profit or loss under ASC 280 and the measure is presented outside the
                                            consolidated financial statements, please label the measures as non-GAAP financial measures
                                            and provide the required disclosures under Item 10(e) of Regulation S-K. As it relates to
                                            the presentation of gross profit, which appears to exclude depreciation, revise your disclosures
                                            as necessary to comply with SAB Topic 11:B.

Response:
We respectfully inform the Staff that our CODM uses gross profit as the primary profitability measure in making decisions about allocating
resources to the segments and assessing performances, and we have added the disclosure in Note 13 on page F-19 accordingly. In addition,
we have revised the tables in Note 13 to reflect the reconciliation of segment profit measure to our consolidated income before income
taxes in accordance with ASC 280-10-50-30. Lastly, we respectfully inform the Staff that our charges for depreciation are included in
cost of revenues and general and administrative expenses and revised the disclosure on pages F-19 to F-20 in accordance with SAB Topic 11:B.

We
thank the Staff for its review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact
me at Jeffrey.li@fisherbroyles.com or by telephone at (703) 618-2503.

    Very
    truly yours,

    /s/
    Jeffrey Li

    Jeffrey
    Li

Enclosures

    cc:
    Albert
    Wong, Chief Executive Officer of Eastern International Ltd.

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