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Hamco
Ventures Limited

Mandar House, 3rd Floor

Johnson’s Ghut, Tortola

British Virgin Islands

May
8, 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 Amendment No. 1

Response to the Staff’s Comments Dated March 28, 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 March 28, 2025 on
the Company’s registration statement on Form F-1, Amendment No. 1 submitted on February 24, 2025. Concurrently with the submission
of this letter, the Company is filing its amendment No. 2 to the registration statement on Form F-1 (the “Amendment No. 2 to
the Registration Statement”).

The
Staff’s comments from its letter dated March 28, 2025 are repeated below in bold and followed by the Company’s responses.

Prospectus
Summary, page 1

    1.
    We
    note your response to comment 9 and reissue. 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 revenue and net losses for the financial periods contained in the registration
    statement.

The
Company has revised the disclosure accordingly.

2.
We note your response to comment 10 and reissue. 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 has revised the disclosure accordingly. The Company engaged PRC counsel to address the issues presented in this comment. We have
included the consent of PRC counsel as Exhibit 8.1 to the disclosure.

Cash
Transfers and Dividends, page 4

3.
We note your revised disclosure in response to comment 12 and reissue in part. Where you discuss cash transfers through your organization,
please provide a cross-reference to the consolidated financial statements.

The
Company has revised the disclosure by providing the cross reference to the consolidated financial statements.

Business,
page 54

4.
We note your revised disclosure in response to comment 18 and reissue in part. Please revise your organizational chart on page 54 to
include ownership (ordinary and preferred shares) and voting information pre and post-offering regarding public stockholders and your
controlling shareholders. Please include enough information so that investors can clearly understand your capital structure and disparate
voting rights post-offering.

The
Company has revised the disclosure accordingly.

Related
Party Transactions, page 69

5.
We note your revised disclosure in response to comment 28 and reissue in part. Please revise to disclose the nature of the transaction
which created the amount due and any material terms (i.e. maturity dates or interest rates) associated with the amounts due to a director.
Refer to Item 7(B) of Form 20-F.

The
Company has revised the disclosure accordingly.

 General

6.
We note your revised disclosure in response to comment 36 and reissue in part. While we note the experience disclosed for each officer
and director, it does not appear to be experience specific to operating a franchise consultant business, and we note there are still
instances of expertise disclosed throughout the prospectus. Please reconcile.

The
Company has revised the disclosure throughout to reconcile accordingly.

7.
We note that the prospectus throughout references a "sole officer." However, we also note that the Management section on page
66 discloses two officers and two directors. Please revise the prospectus throughout as applicable.

The
Company has revised this disclosure throughout accordingly.

If
you have any questions or further comments regarding the Amendment No. 2 to the Registration Statement, please contact me via email at
eddy.chow@hamcopartners.com

  Sincerely.

  By:
  /s/ Chun
    Leung Chow, (Eddy)

  Name:
  Chun
    Leung Chow, (Eddy)

  Title:
  Chief
    Executive Officer, Chief Financial Officer, Director