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OFA
Group

Unit
B, 16/F, Easy Tower, 609 Tai Nan West Street,

Cheung
Sha Wan, Hong Kong

VIA
EDGAR

February
20, 2025

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

    Attention:

    Scott
    Stringer

    Joel
    Parker

    Jenna
    Hough

    Erin
    Jaskot

    Re:
    OFA
    Group

    Amendment
    No. 2 to Draft Registration Statement on Form F-1

    Submitted January 14, 2025

    CIK
    No. 0002036307

Ladies
and Gentlemen:

OFA
Group (the “Company,” “we,” “our” or “us”) hereby transmits
its response to the comment letter received from the staff (the “Staff”, “you” or “your”)
of the U.S. Securities and Exchange Commission (the “Commission”), dated February 4, 2025, regarding the Company’s
Amendment No. 1 to Draft Registration Statement on Form F-1 (the “Draft Registration Statement”) submitted to the
Commission on January 14, 2025.

For
the Staff’s convenience, we have repeated below the Staff’s comment in bold, and have followed each comment with the Company’s
response. In response to the Staff’s comments, the Company is filing via Edgar a registration statement (the “Registration
Statement”) with this response letter.

Amendment
No. 2 to Draft Registration Statement on Form F-1 submitted January 14, 2025

Prospectus
Summary, page 1

    1.
    We
                                            note your revisions in response to prior comment six. However, it is still unclear whether
                                            you are currently engaged in discussions with Houzz about your potential role as a “strategic
                                            partner for Asian market expansion.” Please tell us, and clearly disclose, the date
                                            you entered into discussions with Houzz about such role, the progression and status of such
                                            discussions, and whether you and Houzz have discussed the specific role of strategic partner
                                            and the obligations and responsibilities of such a role. If you intend to engage in discussions
                                            with Houzz, or you have contacted Houzz but have not engaged in negotiations with Houzz over
                                            such a role, please remove your disclosure regarding the specifics of such a role and make
                                            clear that Houzz has not entered into any discussions, negotiations or agreements
                                            with you related to this role. If you have not engaged in any such discussions with Houzz,
                                            please tell us why you believe it is appropriate to discuss the proposed role prior to engaging
                                            with Houzz about the role.

Response:
In response to the Staff’s comment, we have revised the disclosures on pages 1, 13, and 54 of the Registration Statement.

We
may become subject to a variety of PRC laws and other regulations regarding data security… page 22

    2.

    We
    note your revisions to prior comment 5 and reissue in part. Here and throughout the prospectus, you disclose you have been advised
    by law firms on certain legal matters. In doing so, it appears you are relying on the opinion of counsel as an expert. As such, please
    revise these disclosures to characterize them as opinions of counsel.

Response:
In response to the Staff’s comment, we have revised the disclosures throughout the Registration Statement.

***

We
thank the Staff in advance for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our
legal counsel, Lijia Sanchez, Esq., of Ellenoff Grossman & Schole LLP, at (212) 370-1300.

    Sincerely,

    By:
    /s/
    Larry Wong

    Name:

    Larry
    Wong

    Title:
    Chief
    Executive Officer

    cc:
    Lijia
    Sanchez, Esq.