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 March 13, 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. 4 to Draft Registration Statement on Form F-1
 Submitted February 28, 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 February 19, 2025 letter.

Amendment No. 4 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

1. We note your response to prior comment 1. It appears you provide a
significant
 service of integrating goods and services with other goods and services
into a bundle
 of goods and services that represent the combined output for which your
customer has
 contracted. Refer to ASC 606-10-25-21(a). Please confirm that your
accounting for
 March 13, 2025
Page 2

 contracts with multiple promises are similar to Case B of Example 11 in
ASC 606-10-
 55-146 through 55-150.
(n) Cost of revenues, page F-19

2. We note your response to prior comment 4. As previously requested,
please clarify
 your methodology for classifying costs as cost of products or as cost of
services. Help
 us understand if you track and classify the costs associated with each
of your contracts
 individually. That is, confirm that when the costs are incurred, such
costs are assigned
 to the appropriate cost category. Confirm that you are not aggregating
all costs of
 revenue and then allocating the total amount among the cost categories
based on a
 proportionate revenue allocation methodology for presentation purposes.
In addition,
 as previously requested in prior comment 5, please consider revising
your disclosure
 to also explain 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

3. We note your revision in response to prior comment 6. As previously
requested,
 please also revise to include the required statements outlined within
Rule 10-01(b)(8)
 of Regulation S-X. That is, include a statement that the unaudited
interim financial
 statements include all adjustments that, in the opinion of management,
are necessary
 to a fair statement of the results for the interim periods presented. In
addition, if all
 such adjustments are of a normal recurring nature, a statement to that
effect shall be
 made; otherwise, disclose information describing in appropriate detail
the nature and
 amount of any adjustments other than normal recurring adjustments
entering into the
 determination of the results shown.
Exhibits

4. Exhibit 3.1 appears to have been filed as an image file. Please re-file
this exhibit,
 and ensure all other exhibits are filed, in a text-searchable format.
 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
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