SecProbe.io

September 10, 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. 5 to Registration Statement on Form F-1
Filed September 2, 2025
File No. 333-285657
Dear Ka Wai Victor Mo:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our April 4, 2025 letter.
Amendment No. 5 to Registration Statement on Form F-1 filed September 2, 2025
Prospectus Summary
Overview, page 4
1.We note your disclosure here comparing your total revenue for the years ended March
31, 2025 and 2024. Please also discuss the year-over-year decrease in net income in
the summary along with a brief discussion of your increased cost of revenue and
operating expenses. To the extent material, please also include additional risk factor
disclosure regarding variability in earnings and increased expenses given the
approximately 53% decrease in net income from FY 2024 to 2025.

September 10, 2025
Page 2
Results of Operations, page 63
2.Please address the following comments related to your results of operations
disclosure, referencing instructions under Item 5.A of Form 20-F:
•We note your discussion of revenue for the periods presented. Please revise to
discuss any changes in significant underlying components, such as changes in
price, volume, or mix, to help investors better understand the drivers of revenue
performance.
•We also note your disclosure that general and administrative expenses related to
related parties increased significantly year over year, and that $1.3 million of the
increase was attributable to a discretionary bonus. Please revise to further quantify
and describe the remaining material components of the increase, including the
nature of the related party transactions.
Item 8. Exhibits and Financial Statement Schedule
Exhibit 10.5 Lease Agreement for 22/F, Grand Central Plaza..., page II-2
3.The term of the Lease Agreement filed as Exhibit 10.5 to the Registration Statement
ran through July 3, 2025, with the option to renew for a further term of three years.
Please update your disclosure to explain the status of this lease and any material
impact on your business, including if the lease expired pursuant to its terms or if it
was renewed.
Exhibit 10.11 Lease Agreement for 42/F, Tower 1, Time Square..., page II-2
4.Please refile Exhibit 10.11 in proper text-searchable format. It appears to have been
uploaded as an image. For guidance, 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.