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707
Cayman Holdings Limited

5/F.,
AIA Financial Centre

712
Prince Edward Road East

San
Po Kong, Kowloon

Hong
Kong

April
21, 2026

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Attention:

    Kate
    Beukenkamp

    Division
    of Corporate Finance

    Re:

    707
    Cayman Holdings Limited

    Registration
    Statement on Form F-1, as amended (File No. 333-294721)

    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. 333-294721) (the “Registration Statement”), be accelerated so that it will become effective at 3:30 p.m.,
Eastern Time, Thursday, April 23, 2026, 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