SecProbe.io

January 6, 2025
Ka Wai Victor Mo
Chief Executive Officer
ANEW Health Limited
Unit 2301-05, 23/F, Tower 5, The Gateway
Harbour City, 15 Canton Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:ANEW Health Limited
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted December 20, 2024
CIK No. 0002019042
Dear Ka Wai Victor Mo:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our December 5, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted December 20,
2024
Management's Discussion and Analysis of Financial Condition
Revenue, page 63
We note your response to prior comment 7 and the updates made to the revenue
discussion within results of operations. Please update your discussion so that an
investor can easily understand what drives the $12,573,332 increase in Pain
Management and Health Services income. Please describe the increase in the number 1.

January 6, 2025
Page 2
of contracts and the average annual contract value. Refer to Item 303(2) of Regulation
S-K.
Pain Management and Function Enhancement Services, page 84
2.We note your response to prior comment 12 and your analysis of aggregation criteria
provided as outlined ASC 280-10-50-11 and reissue. Please revise your disclosure on
segment reporting to either report revenues for each product and service, or disclose
that providing such information is impracticable, as required by ASC 280-10-50-40.
Service Center, page 87
3.We note your response to prior comment 3 that before your Tsim Sha Tsui Service
Center become operational, you operated several service centers in the district of
Mong Kok, Tsim Sha Tsui, and Wanchai in Hong Kong. Please include a similar
statement in your prospectus to explain the context of your operating history prior to
the opening of the Tsim Sha Tsui Service Center.
Note 11 - Equity, page F-19
4.We note your response to prior comment 13. Please expand Note 17 to provide more
detailed disclosure regarding these amounts due, including the nature of the
transactions that resulted in these amounts due as well as the significant terms and
conditions of the amounts due. Please also disclose whether Mr. Ka Wai Victor, Mo
will settle the outstanding receivables in cash.
General
5.Please file your exhibits in proper text-searchable format, including exhibits 10.4,
10.5, 10.6, 10.7, 10.8 and 10.9. Please refer to Item 301 of Regulation S-T.
            Please contact Tayyaba Shafique at 202-551-2110 or Terence O'Brien at 202-551-
3355 if you have questions regarding comments on the financial statements and related
matters. Please contact Conlon Danberg at 202-551-4466 or Jane Park at 202-551-7439 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:William S. Rosenstadt, Esq.