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CORRESP
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Suite
1919, 45 Rockefeller Plaza

630
Fifth Avenue

New
York, NY 10111, USA

T:
(1-737) 215-8491

F:
(1-917) 672-3642

VIA
EDGAR

November
15, 2024

Division
of Corporation Finance

Office
of Energy & Transportation

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Cheryl Brown, Liz Packebusch

    Re:
    Intercont
    (Cayman) Limited

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

Filed
on October 21, 2024

CIK
No. 0002018529

Ladies
and Gentlemen:

On
behalf of our client, Intercont (Cayman) Limited (the “Company”), a company incorporated in the Cayman Islands, we are submitting
to the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”) this letter setting
forth the Company’s responses to the comments contained in the Staff’s letter dated November 4, 2024 (the “Comment
Letter”) on the Company’s Amendment No.1 to Registration Statement on Form F-1 filed on October 21, 2024 (the “Registration
Statement”).

Concurrently
with the submission of this letter, the Company is submitting via EDGAR the Amendment No.2 to Registration Statement (the “Revised
Registration Statement”). The Company has responded to all of the Staff’s comments by revising the Registration Statement
to address the comments, or by providing an explanation if the Company has not so revised the Registration Statement. For ease of reference,
each comment contained in the Comment Letter is printed below in bold, followed by the Company’s responses to such comment. All
page references in the responses set forth below refer to the page numbers in the Revised Registration Statement.

Cover
Page

    1.
    Please
    provide to us your calculation of the increase in net tangible book value, increase in net tangible book value per share, pro forma
    net tangible book value, and pro forma net tangible book value per share.

In
response to the Staff’s comment, the Company has provided the required calculations in the tables displayed below.

Net
tangible Assets

    June 30, 2024

    Actual
    Pro-forma Adjustment (1)
    Pro forma

    $
    $
    $

    Total Assets
    $ 65,147,487
    $ 26,417,835
    $ 91,277,487

      (287,835 )

    Less: total liability
      (54,214,684 )
      -
      (54,214,684 )

    Less: deferred IPO cost
      (287,835 )
      287,835
      -

    Total net tangible assets
    $ 10,644,968

    $ 37,062,803

    The number of outstanding ordinary shares
      25,000,001
      3,700,000
      28,700,001

    Net tangible book value per share
    $ 0.43

    $ 1.29

    Assumed offering price

    $ 8.00

    Less Pro-forma net tangible assets per share

    $ (1.29 )

    Dilution in net tangible book value per share to IPO investors

    $ 6.71

    Pro-forma net tangible assets per share

    $ 1.29

    Less: Net tangible book value per share before offering

    $ (0.43 )

    Increase in net tangible book value per share

    $ 0.86

Note
-1 Offering information

    Assumed offering shares
      3,700,000

    Assumed offering share price
    $ 8.00

    Gross proceeds
    $ 29,600,000

    Expenses

    Underwriting Commission (7%)
    $ 2,072,000

    Underwriting accountable expense
    $ 250,000

    Underwriting non-accountable expense (0.5%)
    $ 148,000

    Other expenses related to this offering
    $ 1,000,000

        Less: deferred IPO cost paid by June 30, 2024
    $ (287,835 )

        Subtotal
      3,182,165

    Net proceeds
    $ 26,417,835

The
pro-forma adjustments reflect (i) net proceeds of $ $26,417,835 from a sale of 3,700,000 shares at an assumed initial public offering
price of $8.00 per share the midpoint of the estimated price range set forth on the cover page of the prospectus, and to reflect the
application of the proceeds after deducting the estimated underwriting discounts and estimated offering expenses payable by us. and (ii)
deferred IPO cost of $287,835 as of June 30, 2024 is subsequently reclassified to additional paid in capital at the time of consummation
of IPO.

    2

If
you have any questions regarding this submission, please contact Lan Lou at (917) 661-8175 or loul@junhe.com.

Thank
you again for your time and attention.

    Yours sincerely,

    /s/
    Lan Lou

    Lan Lou

    Partner

    Jun He Law Offices LLC

cc:

Muchun
Zhu, Chairman of the Board and Chief Executive Officer, Intercont (Cayman) Limited

Michael
Burke, Partner, UHY LLP

Jason
Ye, Ortoli Rosenstadt LLP

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