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Correspondence 0001493152-25-008001 from Eastern International Ltd. (ELOG)

Eastern International Ltd.
Date: Feb. 24, 2025 · CIK: 0002013320 · Accession: 0001493152-25-008001

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File numbers found in text: 333-281900

Date
Feb. 24, 2025
Author
Jeffrey Li
Form
CORRESP
Company
Eastern International Ltd.

Letter

Direct Phone: 703.618.2503

jeffrey.li@fisherBroyles.com

February 24, 2025

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

F Street, N.E.

Washington, D.C. 20549

Attn: Myra Moosariparambil

Shannon Buskirk

Michael Purcell

Liz Packebusch

Re: Eastern International Ltd.

Amendment No. 4 to Registration Statement on Form F-1

Filed February 14, 2025

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 February 20, 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 September 3, 2024, amended on October 1, 2024, December 31, 2024, January 21, 2025 and February 14, 2025. Concurrently with the submission of this letter, the Company is filing herewith an exhibit only Amendment No. 5 to the registration statement on Form F-1 (the “Amended Registration Statement”) to include certain exhibits.

The Staff’s comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used in this letter but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

Amendment No. 4 to the Registration Statement on Form F-1

Exhibits

1. We note Yu-yun Tristan Kuo, Chun Pong (Colman) Chiu, and Shiu Wing Joseph Chow have been appointed as independent directors of the Board of Directors and will serve as directors following effectiveness of this registration statement. Please file the consents required by Rule 438 of the Securities Act.

Response: We have filed the consent letters of Yu-yun Tristan Kuo, Chun Pong (Colman) Chiu, and Shiu Wing Joseph Chow as exhibits 23.6, 23.7 and 23.8 to the Amended Registration Statement.

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

Show Raw Text
CORRESP
1
filename1.htm

    Direct
    Phone: 703.618.2503

    jeffrey.li@fisherBroyles.com

February
24, 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. 4 to Registration Statement on Form F-1

    Filed
    February 14, 2025

    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 February 20, 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 September 3, 2024, amended on October 1, 2024, December 31, 2024, January 21, 2025 and February 14, 2025. Concurrently
with the submission of this letter, the Company is filing herewith an exhibit only Amendment No. 5 to the registration statement on
Form F-1 (the “Amended Registration Statement”) to include certain exhibits.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used in this
letter but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

Amendment
No. 4 to the Registration Statement on Form F-1

Exhibits

  1.
  We note Yu-yun Tristan Kuo, Chun Pong (Colman) Chiu, and
Shiu Wing Joseph Chow have been appointed as independent directors of the Board of Directors and will serve as directors following effectiveness
of this registration statement. Please file the consents required by Rule 438 of the Securities Act.

Response:
We have filed the consent letters of Yu-yun Tristan Kuo, Chun Pong (Colman) Chiu, and Shiu Wing Joseph Chow as exhibits 23.6, 23.7 and
23.8 to the Amended Registration Statement.

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.

    2