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 April 28, 2025

Chun Ki Wan
Chief Executive Officer
Idea Tech Holding Ltd
Room 721, 7/F Cyberport One
100 Cyberport Road
Pokfulam, Hong Kong

 Re: Idea Tech Holding Ltd
 Draft Registration Statement on Form F-1
 Submitted April 1, 2025
 CIK No. 0002045440
Dear Chun Ki Wan:

 We have reviewed your draft registration statement and have the following
comment(s).

 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.

Draft Registration Statement on Form F-1
Prospectus Summary, page 1

1. Please revise your disclosure here and in your Business section to
balance your
 discussion under the subheadings "Our Competitive Strengths" and "Our
Growth
 Strategies" with discussion of the challenges you and your business may
face. We
 note the subsection titled "Our Challenges" beginning on page 86 of your
Business
 section. Additionally, we note the bulleted list and discussion under
your risk
 factor beginning "We have a limited operating history. As such, our
historical results
 of operations..." on page 18 discussing competitive pressures in the
STEM
 educational market.
 April 28, 2025
Page 2

We are exposed to the concentration risk of reliance on our largest
supplier..., page 28

2. For context and clarity, please revise this risk factor to provide a
cross-reference to
 your section titled "Related Party Transactions" on page 107. We note
that Next
 Education Limited is a related party engaged in tutor management
services that
 accounted for 7.88% of revenues and 19.18% of your total cost of
revenues for the
 year ended June 30, 2024.
Risk Factors
Risks Related to our Business and Industry
Our executive officers and directors hold certain management positions..., page
35

3. Please revise your disclosure here to state whether any of the companies
where your
 executive officers and directors are currently serving on the board and
management
 team, for which they may be entitled to substantial compensation, are
reflected in your
 Related Party Transactions disclosure. Revise accordingly, including
stating the
 names of applicable companies and providing a cross-reference this
section. For
 example, we note your table on page 107 reflecting major related parties
and their
 relationships with the company.
Management's Discussion and Analysis...
Business Overview
Continued growth of the market for the STEM educational program..., page 67

4. Please revise your statement here and elsewhere as appropriate that you
have achieved
 "relatively stable" income during the part two fiscal years to more
accurately reflect
 your current financial results, including net income. In this regard, we
note that you
 experienced a 10.65% decrease in revenues and a 23.38% decrease in net
income
 from the years ended June 30, 2023 to 2024. We also note your discussion
at the top
 of page 70 discussing the impact of the COVID-19 pandemic on results for
fiscal year
 2023, including a substantial increase in revenue that you state does
not imply that
 your operating performance for the year ended June 30, 2024, "has ceased
to grow."
Industry, page 78

5. Please revise this section of your prospectus to update certain
statistics and dates as
 applicable to reflect data, including HKD or USD figures and
percentages, reflective
 of 2024. In this regard, we note that the graph on page 79, for example,
reflect
 projected "Total Revenue of Robotics Programming Education Market, Hong
Kong
 2019-2028E" with the total revenue for 2024 as estimated. By way of
further example,
 the figure on page 82 reflects rankings based on sales revenues as of
2023; however, it
 is now the second quarter of 2025. For accuracy and consistency, please
update
 accordingly.
 April 28, 2025
Page 3
Business
Our Growth Strategies
Phase 1 - Nationwide Business Rollout, page 86

6. Please briefly expand your discussion here and elsewhere as appropriate
to explain
 what is entailed in "seeking local cooperation" in executing your
planned growth
 across mainland China.
Our Products and Services
Software and Hardware Products, page 87

7. Please revise your disclosure here and elsewhere throughout your
registration
 statement to briefly expand your discussion of your relationship with
DJI and High
 Great. Specifically, expand your discussion to clarify what is entailed
in by being the
 "exclusive partner" of DJI as well as the nature of your "partnerships"
with each
 entity, respectively. Last, please revise to explain the relationship
with iFlight
 Technology Company Limited and DJI as we note that you state that
iFlight provides
 you with DJI drones but your discussion elsewhere refers to you as the
"partner of
 DJI." We note that your disclosure elsewhere, including in your Risk
Factors section
 reflecting that a portion of your customer base and brand recognition in
Hong Kong
 depends on these partnerships.
Our Suppliers, page 90

8. Please revise your disclosure here and elsewhere as applicable to expand
your
 discussion of your relationships with your key suppliers. Specifically,
discuss whether
 you have entered into written agreements with each of these parties,
respectively, and
 if so, the key terms of any agreements (e.g., duration). We note the
placeholders in
 your Exhibit Index for certain agreements to be file as Exhibits
10.7-10.10.
9. Revise your discussions to make clear whether you employ the mentors
offered by
 Next Education Limited, or whether you engage in contractual
arrangements for the
 supply of these individuals to facilitate your STEM education offerings
to schools.
 Additionally, briefly expand your disclosure here and elsewhere as
appropriate to
 discuss how these mentors enable you to "tailor training courses"
specifically to your
 school clients.
Properties, page 91

10. Please revise your disclosure to provide any updates regarding your
lease agreements.
 We note that the two lease agreements related to a use of "store and
demonstration"
 reflected here have a term that expires May 31, 2025. To the extent
applicable, revise
 your disclosure to reflect the impact to your business operations or
otherwise if you do
 not intend to continue leasing spaces at these locations.
Regulations, page 93

11. Revise to disclose the material effects the various government
regulations discussed
 here have on your business. Refer to Item 4.B.8. of Form 20-F.
 April 28, 2025
Page 4
Financial Statements, page F-1

12. Please provide updated financial statements and related disclosures as
required by
 Item 8.A.5 of Form 20-F.
General

13. Please provide us with supplemental copies of all written
communications, as defined
 in Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your
 behalf, have presented or expect to present to potential investors in
reliance on Section
 5(d) of the Securities Act, whether or not you retained, or intend to
retain, copies of
 those communications.

 Please contact Abe Friedman at 202-551-8298 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Yarona L Yieh
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