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CORRESP
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707
Cayman Holdings Ltd

5/F.,
AIA Financial Centre

712
Prince Edward Road East

San
Po Kong, Kowloon, Hong Kong

September
5, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Alyssa Wall

    Re:
    707
    Cayman Holdings Ltd (the “Company”)

    Amendment
    No. 3 to Draft Registration Statement on Form F-1

    CIK
    No. 0002018222

Ladies
and Gentlemen:

We
have set forth below responses to the comment of the staff (the “Staff”) of the Securities and Exchange Commission
contained in its letter of August 23, 2024 with respect to the Company’s Draft Registration Statement, as noted above.

For
your convenience, the text of the Staff’s comment is set forth below in italics, followed by the Company’s response. Please
note that all references to page numbers in the responses are references to the page numbers in F-1 to the Registration Statement
submitted concurrently with the submission of this letter in response to the Staff’s comment.

Draft
Registration Statement submitted August,5, 2024

General

 1. We
                                            note your revised disclosure pursuant to comment 2 and reissue in part. Please revise
                                            the resale prospectus cover page to discuss your status as a controlled company:

We
have revised the resale prospectus cover page to update the disclosure, as requested.

If
you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com
or Joilene Wood at 415-305-4651 or jwood@troygould.com.

    Sincerely,

    707
    Cayman Holdings Limited

    /s/
    Cheung Lui

    By:

    Cheung
    Lui

    Chief
    Executive Officer and Executive Director

    cc:
    David
    L. Ficksman

    R.
    Joilene Wood