SecProbe.io

February 19, 2025
Yee Kar Wing
Chief Executive Officer
ChowChow Cloud International Holdings Limited
Unit 03, 23/F, Aitken Vanson Centre
No. 61 Hoi Yuen Road, Kwun Tong
Kowloon, Hong Kong
Re:ChowChow Cloud International Holdings Limited
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted February 10, 2025
CIK No. 0002041829
Dear Yee Kar Wing:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our January 28, 2025 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
(m) Revenue recognition, page F-12
As previously requested in prior comment 3, in your response, please describe in
reasonable detail the nature of each of the promises and the intended benefit to the
customer for each of your contracts with multiple promises. That is, explain the
functionality of the IT solutions that you provide to your customers in each type of
contract scenario. When hardware is sold with IT professional services, describe why 1.

February 19, 2025
Page 2
the hardware system is not functional without the accompanying installation and
integration. When software and IT application products are sold with IT professional
services, describe why the customer cannot deploy or use the software effectively
without IT professional services. When hardware, software and IT application
products are sold with IT professional services, describe why the IT system is not
functional unless all the components are integrated. Explain the difference between
these types of contracts and contracts for hardware or software with immediate
functionality. As part of your response, also tell us how the contract scenarios
identified correlate to the services and solutions described in your Business section
starting on page 73.
2.You indicate in response to prior comment 4 that, in many cases, the customer’s
primary objective is to obtain a fully customized and integrated IT solution, consistent
with your disclosures that you deliver a fully integrated IT solution and the customer
expects a turnkey solution. In this regard, it appears the deliverable to the customer is
a product. Please provide further evidence for why certain contracts with multiple
promises are not categorized as revenue from products. Alternatively, consider
presenting revenue from contracts with multiple promises that include non-distinct
products and services as a separate line item.
(n) Cost of revenues, page F-19
3.We note the significant reclassification of costs from cost of products to cost of
services in each of periods presented, in addition to the reclassification of product
revenue to service revenue for the six months ended June 30, 2023. Tell us what
consideration you gave to labeling your statement of operations and related
disclosures throughout your filing as restated and providing disclosures required by
ASC 250-10-50-7. In addition, tell us what consideration your auditors gave to
including an explanatory paragraph regarding the correction and dual dating their
opinion. Refer to paragraph 16 of PCAOB Auditing Standard (“AS”) 2820 and
paragraph 18(e) of AS 3101.
4.You indicate in response to prior comment 5 that your revised classification of the
types of cost of revenue reflects your methodology of allocating costs to performance
obligations in proportion to the revenues recognized. Please elaborate on your
allocation methodology and indicate which types of costs are being allocated. While
we understand that certain costs may need to be allocated, tell us how your
classification takes into consideration the direct costs of your contracts. In this regard,
please clarify whether cost directly related to the contract are being presented as the
cost of sales in satisfaction of that single performance obligation.
Please clarify how costs of revenue are recognized. In this regard, your disclosure
appears to indicate that costs are matched with the associated performance obligation
by allocating costs to performance obligations in proportion to revenues recognized.
We also note from your response to prior comment 4 that hardware and software costs
are front-loaded. Tell us what consideration you gave to capitalizing costs in
accordance with ASC 340-40-25-6 and recognizing costs as expenses in accordance
with ASC 340-40-25-8. Also, refer to ASC 340-40-55-7 through 55-9. Consider
clarifying your disclosure to address when you recognize cost of revenue separately 5.

February 19, 2025
Page 3
from your discussion of the methodology used to classify cost of revenue among cost
of products and cost of services.
Unaudited Condensed Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
(a) Basis of presentation, page F-45
6.Please revise the statement indicating that your interim financial statements have been
audited. In addition, please include the required statements outlined within Rule 10-
01(b)(8) of Regulation S-X.
            Please contact Melissa Walsh at 202-551-3224 or Stephen Krikorian at 202-551-3488
if you have questions regarding comments on the financial statements and related
matters. Please contact Marion Graham at 202-551-6521 or Mitchell Austin at 202-551-3574
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Meng Ding