SecProbe.io

CORRESP
 1
 filename1.htm

 OFA
Group

 609
Deep Valley Drive, Suite 200

 Rolling
Hills, CA 90274

 VIA
EDGAR

 December
30, 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:

 Nicholas
 Nalbantian

 Cara
 Wirth

 Re:
 OFA
 Group

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

 Filed
 September 26, 2025

 File
 No. 333-289618

 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 December 2, 2025, regarding the Company's
Registration Statement on Form F-1 (the " Registration Statement ") filed by the Company to the Commission on September
26, 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 an Amendment No. 2 to the Registration Statement
(the " Amendment No. 2 ") with this response letter.

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

 Prospectus
Summary, page 1

 1.
 We
 note your response to prior comment 1 and reissue in part. Please disclose the identities of your qualified third-party custodians.
 In addition, you disclose that you plan on "originating mortgages that are recorded on-chain and represented by Real World
 Asset (RWA) tokens." Please clarify if these mortgages will exist in two forms, a "smart contract" version and
 a "paper-based" version, and if the former, please disclose which financial institutions, if any, have agreed to assist
 with originating smart contract mortgages. Similarly, please disclose which "regulators, auditors, and investors" have
 agreed to hold or review smart contract mortgages. If you currently do not have partners for these RWA token represented smart contract
 mortgages, please disclose as much. In addition, please disclose if the RWA tokens are purely internal and whether they will be held
 by a third-party custodian.

 Response:
In response to the Staff's comment, we have revised the disclosures on pages 2 and 79 of the Amendment No. 2.

 Recent
Developments, page 2

 2.
 We
 note your response to prior comment 2 and reissue in part. Please disclose your allocation ranges, target distribution percentages,
 and minimum liquidity thresholds, so that potential investors can better assess the potential impact of your crypto-treasury strategy
 on your business.

 Response: In response to the Staff's
comment, we have revised the disclosures on pages 7, 8, 79 and 80 of the Amendment No. 2.

 Risk
Factors

 Risks
Related to Our Cryptocurrency Treasure Strategy, page 43

 3.
 We
 note your response to prior comment 4 and reissue in part. While we acknowledge the addition of the first paragraph, the remainder
 of the risk factor is focused on bitcoin alone. As one example only, for illustrative purposes, you state "bitcoin does not
 pay interest or other returns..." by contrast you do not disclose any information around Solana and SUI being "proof-of-stake"
 tokens that are able to generate interest. Please amend this risk factor, or consider drafting separate risk factors, to highlight
 the unique risks of each proposed crypto-treasury asset. In addition, please update your Risk Factor Summary section on page 6 to
 reflect the changes to this sub-section heading.

 Response:
In response to the Staff's comment, we have revised the disclosures on pages 11 and 49 - 52 of the Amendment No. 2.

 ***

 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/
 Li Hsien Wong

 Name:

 Li
 Hsien Wong

 Title:
 Chief
 Executive Officer

 cc:
 Lijia
 Sanchez, Esq.