SecProbe.io

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 March 18, 2025

Elvis Cheung
Chief Executive Officer
707 Cayman Holdings Ltd.
5/F., AIA Financial Centre
712 Prince Edward Road East
San Po Kong, Kowloon, Hong Kong

 Re: 707 Cayman Holdings Ltd.
 Amendment No. 3 to Registration Statement on Form F-1
 Filed February 20, 2025
 Amendment No. 4 to Registration Statement on Form F-1
 Filed March 10, 2025
 File No. 333-281949
Dear Elvis Cheung:

 We have reviewed your amended registration statement and have the
following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our February 12,
2025 letter.

Amendment No. 3 to Form F-1 filed February 20, 2025
Capitalization, page 33

1. As a related matter, the footnote to this table states "[t]he number of
our Ordinary
 Shares to be outstanding after this Offering is based on 21,950,000
Ordinary Shares
 outstanding as of the date of this prospectus." This appears to be a
conflicting
 statement as the number of shares outstanding as of the date of this
prospectus is
 20,200,000. Please revise the disclosure to clearly state the shares
outstanding after
 the Offering or as of the date of the prospectus.
 March 18, 2025
Page 2

2. Please revise the description of ordinary shares issued and outstanding
on a pro forma
 and pro forma as adjusted basis after the offering to include the
ordinary shares issued
 and outstanding prior to the offering. It appears the figures presented
subsequent to
 the offering should be 21,950,000.
Dilution, page 35

3. Please revise your narrative disclosure to include a description,
calculation, and values
 of net tangible book value and net tangible book value per share
immediately prior to
 the offering.
General

4. We note that your forum selection provision in Section 161 of your
amended and
 restated charter identifies the United States District Court for the
Southern District of
 New York (or, if such court lacks subject matter jurisdiction, the state
courts in New
 York County, New York) as the exclusive forum for claims arising from
the US
 federal securities laws. Please describe this provision in a new risk
factor, as well as in
 the Description of Share Capital section. In both places, further state
that investors
 cannot waive compliance with the federal securities laws and the rules
and regulations
 thereunder and that there is uncertainty as to whether a court would
enforce such
 provision given that Section 22 of the Securities Act creates concurrent
jurisdiction
 for federal and state courts over all suits brought to enforce any duty
or liability
 created by the Securities Act or the rules and regulations thereunder.
In the risk
 factor, describe the risks or other impacts of this provision on
investors, including
 increased costs to bring a claim and that these provisions can
discourage claims or
 limit investors' ability to bring a claim in a judicial forum that they
find favorable.
Amendment No. 4 to Registration Statement on F-1
Exhibit 5.1, page 1

5. Please revise this opinion or include a separate opinion that opines on
the legality of
 the shares being offered pursuant to the Resale Prospectus. Refer to
Section II.A of
 Staff Legal Bulletin No. 19.
Exhibit 5.2

6. Please revise your statement in Section D that "[o]ther than the
Company, no other
 person or entity may use or rely on this opinion...," given that it is
impermissible to
 state or imply that only the registrant or its board is entitled to rely
upon the opinion.
 Refer to Section III.D.1 of Staff Legal Bulletin No. 19. Also revise
Section E.7 to
 include the statement that the disclosure in the section "Hong Kong Tax
 Considerations" constitutes your opinion. Refer to Section III.B. 2 of
Staff Legal
 Bulletin No. 19.
 Please contact Amy Geddes at 202-551-3304 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
 March 18, 2025
Page 3

matters. Please contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at
202-551-3222
with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
cc: David L. Ficksman
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