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707
Cayman Holdings Ltd

5/F., AIA Financial

Centre
712 Prince

Edward
Road East

San
Po Kong, Kowloon, Hong Kong

November
14, 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. 1 to Registration Statement on Form F-1

    File
    Number 333-281949

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 November 8, 2024 with respect to the Company’s 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 the Amendment No. 1 to the Registration
Statement that was filed on October 18, 2024 (the “Registration Statement”). We have not filed a corresponding amendment
as we believe that our letter is responsive to the questions raised. Defined terms used herein have the same meaning as attributed to
them in the Registration Statement.

Amendment
No. 1 to Form F-1 filed October 18, 2024

Unaudited
Condensed Combined and Consolidated Financial Statements

Notes
to Condensed Combined and Consolidated Financial Statements

Note
1 - Business Overview and Basis of Presentation

Reorganization,
page F-6

 1. It
                                            appears from your disclosure that on October 9, 2024, your current shareholders purchased
                                            an additional 19,200,000 ordinary shares for $19,200. Please tell us how you determined this
                                            issuance of shares should be accounted for on a retrospective basis and cite the specific
                                            authoritative literature you utilized to support your accounting treatment. It appears these
                                            shares represent an issuance to increase your outstanding equity prior to the completion
                                            of the IPO and do not appear to be related to the shares that were exchanged to complete
                                            the business combination transaction between the Company, Beta Alpha and 707IL Hong Kong.

As
the part of the reorganization, we completed a share swap transaction on August 26, 2024 whereby the entire share capital of 707IL was
transferred to Beta Alpha resulting in our Group being comprised of Beta Alpha and 707IL as our direct and indirect wholly-owned subsidiaries,
respectively. Immediately following the share swap transaction, we increased the number of ordinary shares in proportion to the current
shareholders by issuing the additional 19,200,000 ordinary shares, at par value to the respective shareholders, which was completed on
October 9, 2024. The increase of share numbers at par value (so-called as “nominal issuances”) is considered as a change
in share/capital structure in the same manner as shares issued in a stock split or a recapitalization effected.

Under
SAB Topic 4.C, a change in a registrant’s capital structure occurring after the date of the latest reported balance sheet, but
before the issuance of the financial statements or the effective date of the registration statement, whichever is later, should be given
retroactive effect on the balance sheet. Similarly, ASC 260-10-55-12 requires retrospective presentation and disclosure of such changes
in capital structure in the calculation of earnings per share.

 2. We
                                            note your response to prior comment 3 and reissue it. In this regard, we note that the response
                                            discusses only the small portion of the Resale Shares that the Resale Shareholders purchased
                                            from JME on March 20, 2024, and not the much larger portion of the Resale Shares that the
                                            Resale Shareholders purchased from the company on October 9, 2024. We also note that the
                                            Resale Shares purchased on October 9, 2024 were purchased “for the purpose and preparation
                                            of the offering.”

On
March 19, 2024, Goldstone and Long Vehicle each purchased 46,000 from JME, and on March 20, 2024, Harmony Prime and Expert
Core each purchased 49,000 shares from JME. As part of the reorganisation that took place on October 9, 2024, each of the existing
shareholders, namely, JME, Goldstone, Long Vehicle, Harmony Prime and Expert Core were allotted and issued, respectively, 15,552,000
shares, 883,200 shares, 883,200 shares, 940,800 shares and 940,800 shares for cash at par (see the table below). This allotment and issuance
were conducted on pro rata basis and for the purpose of the reorganizing the shareholding structure of the intended offering and pricing
estimates as well as taking into account the dilution as a part of the offering. There was no change to the proportionate percentages
of ownership held by each shareholder.

    Shareholders
    Shareholding as of

                                                                  March 19, 2023

    Shares Alloted on

                                                                              October 9, 2024

    Total Current

                                                                              Shareholding

    JME
    810,000
    81.0%
      15,552,000
    81.0%
      16,362,000

    Harmony Prime
    49,000
    4.9%
      940,800
    4.9%
      989,800

    Expert Core
    49,000
    4.9%
      940,800
    4.9%
      989,800

    Goldstone
    46,000
    4.6%
      883,200
    4.6%
      929,200

    Long Vehicle
    46,000
    4.6%
      883,200
    4.6%
      929,200

      TOTAL

      20,200,000

The
reorganization was undertaken solely for the purpose of ensuring the appropriate number of shares outstanding in light of the expected
valuation of the public offering and not as an additional investment into the Company. As noted in our response to question 1 above,
we respectfully submit that the increase of share numbers issued at par value (so-called as “nominal issuances”) is considered
as a change in share/capital structure in the same manner as shares issued in a stock split or a recapitalization effected. The increase
of share numbers at par value was a “nominal issuance” solely done as part of a reorganization to align with the expected
valuation of the Company in anticipation of the upcoming offering, and was not an issuance done in connection with an additional investment
in the Company.

 3. Please
                                            clarify the circumstances regarding the agreement that the Resale Shareholders “would
                                            be permitted to sell those [Resale Shares] in a resale prospectus,” including with
                                            whom the Resale Shareholders made such an agreement and why a registration rights agreement
                                            was not entered into.

 It was a commercially
agreed term at the time of issuance that the shares acquired by Harmony Prime and Expert Core would have no restrictions and that
the Company would seek to include them in a resale at the time of the public offering. The Company was willing to make this
agreement on the basis that the principals of Harmony Prime and Expert Core have contacts with potential customers and suppliers.
Goldstone and Long Vehicle negotiated separate terms, and a condition of the purchase of these shares is that these shares would be
subject to certain lock up and leak out terms to be determined as deemed appropriate at the time of the offering. The Resale
Shareholders did not require formal documentation of these rights through a Registration Rights Agreement.

 4. We
                                            note that the company engaged in private placements on October 9, 2024. Please provide an
                                            analysis as to whether such private placements are required to be integrated with the offering
                                            registered on the Form F-1 and why.

As
noted in our response number 2 above, we respectfully advise that the October 9 transaction was not a private placement, but rather a
reorganization where shareholdings were proportionally increased by all existing shareholders. No meaningful investment was made in the
Company as the only amount paid was nominal par value contribution for the respective shares acquired.

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