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CORRESP
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RISING DRAGON ACQUISITION CORP.

No. 604, Yixing Road, Wanbolin District, Taiyuan City,

Shanxi Province, People’s Republic of China 030024

October 8, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 RE: Rising Dragon Acquisition Corp. (the “Company”)

Registration Statement on Form S-1

(File No. 333-280026) (the “Registration Statement”)

Ladies and Gentlemen:

The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement
so that such Registration Statement will become effective as of 4:30 p.m., Eastern Time, on October 10, 2024, or as soon thereafter as
practicable.

The
Company hereby acknowledges that:

 ● Should
                                            the Securities and Exchange Commission (the “Commission”) or the Staff, acting
                                            pursuant to delegated authority, declare the Registration Statement effective, it does not
                                            foreclose the Commission from taking any action with respect to the Registration Statement;

 ● The
                                            action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
                                            the Registration Statement effective, does not relieve the Company from its full responsibility
                                            for the adequacy and accuracy of the disclosure in the Registration Statement; and

 ● The
                                            Company may not assert Staff comments and the declaration of effectiveness as a defense in
                                            any proceeding initiated by the Commission or any person under the federal securities laws
                                            of the United States.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule
461 of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S.
counsel, Loeb & Loeb LLP.

[Signature page follows]

    Very truly yours,

    Rising Dragon Acquisition Corp.

    By:
    /s/ Lulu Xing

    Name: Lulu Xing

    Title: Chief Executive Officer and Director