SecProbe.io

CORRESP
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filename1.htm

Lõõtsa
8, 11415 Lasnamäe

District
Tallinn, Harju County

Estonia

March
26, 2025

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

U.S.A.

Re:  Xdata
                                            Group

    Registration
                                            Statement on Form F-4, as amended (File No. 333-285858)

    Acceleration
                                            Request

Ladies
and Gentlemen:

Pursuant
to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended (the “Act”), Xdata Group (the
“Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-4 (the
“Registration Statement”) be accelerated to, and that the Registration Statement become effective at, 4:00 P.M. Eastern
Standard Time on March 28, 2025, or as soon thereafter as practicable.

If
there is any change in the acceleration request as set forth above, the Company will promptly notify you of the change, in which case
the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with the Act.
Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Han Kun Law
Offices LLP.

In
making this acceleration request, the Company hereby acknowledges the following:

    ●
    should
    the U.S. Securities and Exchange Commission (“SEC”) or the staff of the SEC (the “Staff”),
    acting pursuant to delegated authority, declare the filing effective, it does not foreclose the SEC from taking any action with respect
    to the filing;

    ●
    the
    action of the SEC or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company
    from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Company may not assert Staff’s comments and the declaration of effectiveness as a defense in any proceedings initiated by the
    SEC or any person under the federal securities laws of the United States.

If
you have any questions regarding this request and to provide notice of effectiveness, please contact Zhe Zhang at zhangzhe@siftcap.cn
by email, or by telephone at +447529975699.

[Signature
page follows]

    Very
truly yours,

    Xdata Group

    By:
    /s/
    Zhe Zhang

    Name:
    Zhe
    Zhang

    Title:
    Sole
    Director

    (Principal
    Executive Officer)

    (Principal
    Financial and Accounting Officer)

[Signature
Page to Acceleration Request]