SecProbe.io

CORRESP
 1
 filename1.htm

 707
Cayman Holdings Limited

 5/F.,
AIA Financial Centre

 712
Prince Edward Road East

 San
Po Kong, Kowloon

 Hong
Kong

 January
23, 2026

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:

 Cara
 Wirth

 Division
 of Corporate Finance

 Re:

 707
 Cayman Holdings Limited

 Registration
 Statement on Form F-1, as amended (File No. 333-292904)

 Request
 for Acceleration of Effectiveness

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended (the
"Securities Act"), 707 Cayman Holdings Limited, a Cayman Islands company (the "Company"), respectfully requests
that the effective date of its Registration Statement on Form F-1 (File No. 333-292904) (the "Registration Statement"), be
accelerated so that it will become effective at 3:30 p.m., Eastern Time, Tuesday, January 27, 2025, or as soon thereafter as possible.

 In
making this acceleration request, the Company acknowledges that:

 (i)
 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;

 (ii)
 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 of the disclosure in the Registration Statement; and

 (iii)
 the
 Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement
 as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Once
the Registration Statement is effective, please orally confirm the event with our counsel, TroyGould PC by calling Joilene Wood at (415)
305-4651 or David Ficksman at (310) 789-1290. We also respectfully request that a copy of the written order from the Commission verifying
the effective time and date of the Registration Statement be sent to our counsel, TroyGould PC, Attention: David Ficksman, by facsimile
to (310) 789-1290 or email at dficksman@troygould.com.

 If
you have any questions regarding this request, please contact Joilene Wood at (415) 305-4651.

 Very
 truly yours,

 By:
 /s/
 Cheung Lui

 Name:
 Cheung
 Lui

 Title:
 Chief
 Executive Officer

 cc:

 David
 Ficksman, TroyGould PC

 R.
 Joilene Wood, TroyGould PC