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Hamco Ventures Limited

Mandar House, 3rd Floor

Johnson’s Ghut, Tortola

British Virgin Islands

February 21, 2025

VIA EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:

        Hamco Ventures Limited

        Registration Statement on Form
F-1

        Response to the Staff’s Comments Dated January
16, 2025

        Registration No. 333-283829

Dear Mr. Rhodes, Mr. Decker, Ms. Hough
and Mr. Field:

Hamco Ventures Limited
(the “Company”), a foreign private issuer incorporated in the British Virgin Islands (the “Company”),
submits to the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated January 13,
2025 on the Company’s registration statement on Form F-1 submitted on December 13, 2024. Concurrently with the submission
of this letter, the Company is filing its amendment No. 1 to the registration statement on Form F-1 (the “Amendment No.
1 to the Registration Statement”).

The Staff’s comments
from its letter dated January 16, 2025 are repeated below in bold and followed by the Company’s responses.

Cover Page

1. Please disclose on the prospectus cover page the anticipated
trading symbol for your Ordinary Shares on OTC Pink. Refer to Item 501(b)(4) of Regulation S-K.

As we previously disclosed on the cover
page, the Company has yet to engage a broker dealer to assist the Company with a listing onto the OTC Markets. Therefore, we have
not yet determined the anticipated trading symbol for quotation.

2. We note your disclosure regarding risks relating to your
corporate structure. Please also provide a cross reference to your detailed discussion of risks facing the company and the offering
as a result of this holding company structure.

The Company has updated our disclosure to
include the referenced disclosure on the cover page with the following language: “See “Risk Factors — Risks
Related to Doing Business in Hong Kong — All of our operations are in Hong Kong, a special administrative
region of the PRC. Due to the long-arm provisions under current PRC laws and regulations, the Chinese government may exercise significant
oversight and discretion over the conduct of our business and may intervene in or influence our operations at any time, which could
result in a material change in our operations and/or the value of our Ordinary Shares. Any actions by the Chinese government to
exert more oversight and control over offerings that are conducted overseas and/or foreign investment in Hong Kong or China-based
issuers could significantly limit or completely hinder our ability to offer or continue to offer securities to investors and cause
the value of such securities to significantly decline or be worthless. The Chinese government may intervene or impose restrictions
on our ability to move money out of Hong Kong to distribute earnings and pay dividends or to reinvest in our business outside of
Hong Kong. Changes in the policies, regulations, rules, and the enforcement of laws of the Chinese government may also be quick
with little advance notice, and our assertions and beliefs of the risk imposed by the PRC legal and regulatory system cannot be
certain”.

3. Where you discuss recent regulatory actions by the Chinese
government, such as those relating to data security and anti-monopoly concerns, please include cross references to individual risk
factors.

The Company has included the referenced
disclosure on the cover page with the following language: “See “Risk Factors — Risks Related to
Doing Business in Hong Kong — All of our operations are in Hong Kong, a special administrative region of the
PRC. Due to the long-arm provisions under current PRC laws and regulations, the Chinese government may exercise significant oversight
and discretion over the conduct of our business and may intervene in or influence our operations at any time, which could result
in a material change in our operations and/or the value of our Ordinary Shares. Any actions by the Chinese government to exert
more oversight and control over offerings that are conducted overseas and/or foreign investment in Hong Kong or China-based issuers
could significantly limit or completely hinder our ability to offer or continue to offer securities to investors and cause the
value of such securities to significantly decline or be worthless. The Chinese government may intervene or impose restrictions
on our ability to move money out of Hong Kong to distribute earnings and pay dividends or to reinvest in our business outside of
Hong Kong. Changes in the policies, regulations, rules, and the enforcement of laws of the Chinese government may also be quick
with little advance notice, and our assertions and beliefs of the risk imposed by the PRC legal and regulatory system cannot be
certain”.

4. Please disclose that the same "legal and operational”
risks associated with operating in China also apply to operations in Hong Kong. Please also include a discussion of China's Enterprise
Tax Law.

The Company has updated the disclosure
to include this information, as well as a discussion of China’s Enterprise Tax Law.

5. Where you discuss cash transfers throughout your organization,
please provide a cross-reference to the consolidated financial statements. Also, where you discuss the risk that cash may not be
available for use outside of the PRC or Hong Kong due to restrictions imposed by the Chinese government and restrictions on your
ability to transfer cash, please provide cross-references to individual risk factors discussing this risk.

The Company has included a cross reference
to the consolidated financial statements.

The Company has also included a cross reference to
the risk factor as follows: “ “Risk Factors — Risks Related to Doing Business in Hong Kong — All
of our operations are in Hong Kong, a special administrative region of the PRC. Due to the long-arm provisions under current PRC laws
and regulations, the Chinese government may exercise significant oversight and discretion over the conduct of our business and may intervene
in or influence our operations at any time, which could result in a material change in our operations and/or the value of our Ordinary
Shares. Any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in Hong Kong or China-based issuers could significantly limit or completely hinder our ability to offer or continue to offer
securities to investors and cause the value of such securities to significantly decline or be worthless. The Chinese government may intervene
or impose restrictions on our ability to move money out of Hong Kong to distribute earnings and pay dividends or to reinvest in our business
outside of Hong Kong. Changes in the policies, regulations, rules, and the enforcement of laws of the Chinese government may also be quick
with little advance notice, and our assertions and beliefs of the risk imposed by the PRC legal and regulatory system cannot be certain”.

6. We note your prospectus cover page disclosure regarding
whether and how the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, and related regulations
will affect your company appears overly repetitive and appears in a large number of paragraphs. Please revise to remove duplicative
disclosure and to present this information in a more consolidated manner.

The Company has revised the disclosure to
remove the overly repetitive language.

7. We note your capital structure authorizes different classes
of stock (i.e. ordinary and preferred) with disparate voting rights. Please revise the prospectus cover page to quantify the voting
power that the preferred shares will have after the offering due to the disparate voting rights attached to the two classes of
stock and, to the extent material, identify any major holder or holders of such shares. Additionally, please add a section to the
prospectus summary and a risk factor to discuss your capital structure to include these disparate voting rights.

The Company has revised the disclosure on the
prospectus cover page to quantify the voting power that the preferred shares will have after the offering due to the disparate
voting rights attached to the two classes of stock. We have also identified the majority holder of such shares. We have also added
a section to the prospectus summary and have added a risk factor to discuss our capital structure.

Overview, page 1

8. Please revise to clarify that you have one officer, director
and employee. Additionally, please revise to clarify the limited development activities that you have completed since inception.
In this regard, we note the limited development activities detailed on page 54.

The Company has revised the disclosure to
indicate that we have one officer, no additional employees, and two directors. Further we have disclosed that we have limited
development activities that we have completed since inception, that being that on June 5, 2024, our Hong Kong subsidiary Hamco Creek
entered into a service agreement with a client in Hong Kong. The client is considering entering into the Hong Kong market to develop
a franchise business.

9. Please revise to discuss your auditor’s going concern
opinion. Disclose your monthly “burn rate” and the month you will run out of funds without additional capital. Also,
revise to state that you must raise additional capital in order to continue operations and to implement your plan of operations
and quantify the amounts needed for each. Additionally, please revise to disclose your limited revenues and net losses for the
financial periods contained in the registration statement.

In response to the SEC comment, the Company
had updated the disclosure to provide the auditor’s going concern opinion to address the specific  comment above.

Prospectus Summary, page 1

10. Please disclose each permission
or approval that you and your subsidiaries, are required to obtain from Chinese authorities to operate your business and to offer
the securities being registered to foreign investors. State whether you or your subsidiaries are covered by permissions requirements
from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency
that is required to approve your operations, and state affirmatively whether you have received all requisite permissions or approvals
and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors if you
or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions
or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain
such permissions or approvals in the future. If you relied on an opinion of counsel to reach these conclusions, then counsel should
be named and a consent of counsel filed as an exhibit. If you did not consult counsel, then explain why, as well as the basis for
your conclusions regarding whether approvals are required. If you have determined that certain permissions/approvals are not required/applicable,
please discuss how you came to that conclusion, why that is the case, and the basis on which you made that determination.

The Company is not
organized in China, and it does not have operations in China. Therefore, the Company has no operations in China that pose a risk
to investors. The Company is not subject to the legal system of China, but instead is operating in Hong Kong, under the Hong Kong
Basic Law.

The Company’s
Hong Kong subsidiary does not require permission or approval from Chinese authorities to operate the Company’s or the subsidiaries'
business or to offer securities to foreign investors. The Company and its subsidiary are not covered by the permission requirements
from the CSRS, CAC or other Chinese agencies. The subsidiary is incorporated in Hong Kong and has received a business license to
operate in Hong Kong.

Risk Related to Doing Business in Hong
Kong, page 2

11. Where you discuss the risk that
the Chinese government could exert more control over offerings conducted overseas and/or foreign investment in China-based issuers,
please clarify that this risk could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless. For each summary risk factor listed
in this section, please provide a cross-reference (title and page number) to the relevant individual detailed risk factor.

The Company has revised the disclosure
to indicate risk that the Chinese government could exert more control over offerings conducted overseas and/or foreign investment in China-based
issuers. In addition, we have cross referenced the relevant individual detailed risk factor in our disclosure, along with the applicable
page number.

Cash Transfers and Dividend Distributions,
page 4

12. Please provide a more detailed description
of how cash is transferred through your organization. Additionally, please provide cross-references to the consolidated financial
statements.

The Company has updated
the disclosure to state that we conduct the majority of our operations in Hong Kong and maintains our bank accounts and balances
primarily in licensed banks in Hong Kong. If needed, cash can be transferred between our holding company and subsidiary through
intercompany fund advances, and there are currently no restrictions that would prevent the transferring of funds between our BVI
holding company and our subsidiary in Hong Kong. No transfer of cash or other types of assets has been made between our BVI holding
company and our subsidiary as of the date of this prospectus. We also have provided a cross reference to the consolidated financial
statements.

Summary Consolidated Financial Data,
page 9

13. Please revise to also include interim
balance sheet and interim statement of operations financial information.

The Company has revised
the disclosure to include interim balance sheet and interim statement of operations financial information as of September 30, 2024.

Risk Factors, page 11

14. We note that a number of risk factors
reference dated information from your audited financial statements for the fiscal year ended June 30, 2024 rather than updated
information from your most recent interim financial statements. For example, the second risk factor references a dated cash balance.
Please revise this section and the prospectus throughout to reference the most up to date financial information.

The Company has revised
this disclosure in the risk factor section and throughout prospectus to reference the most up to date financial information.

Our performance and growth depend on
our ability to generate client referral..., page 13

15. Please revise this risk factor to
disclose that you currently have one client, thus increasing your difficulty in obtaining client referrals. We also note your disclosure
that you will depend "on the financial advisors, financial institutions, law firms and other third parties who use our services."
Please disclose that you have no such clients yet, if true.

The Company has revised
the disclosure to state that its business model depends on users of our services to generate client referrals for our services.
As of the date of this prospectus, we have one client, thus increasing our difficulty to rely on client referrals. A decline in
the number of referrals we receive could require us to devote substantially more resources to the sales and marketing of our services,
which would increase our cos