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CORRESP
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filename1.htm

707
Cayman Holdings Ltd

5/F.,
AIA Financial Centre

712
Prince Edward Road East

San
Po Kong, Kowloon, Hong Kong

February
20, 2025

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Thomas Jones

    Re:
    707
    Cayman Holdings Ltd

    Amendment
    No. 2 Registration Statement on Form F-1 (the “Registration Statement”)

    File
    No. 333-281949

Ladies
and Gentlemen:

We
note your comment  dated February 12, 2025 to Amendment No. 2 Registration Statement on Form F-1, which we have restated below.

Summary
Financial Data

Balance
Sheet Data, page 10

1. Please
                                            review the headers in the table here to ensure the proper fiscal years are identified. Specifically,
                                            it appears some of the columns labeled “2023” should be labeled “2024.”

We have updated the Registration
with Amendment No. 3 in order to correct the column headings on page 10 and provide other updated disclosure.

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