SecProbe.io

CORRESP
 1
 filename1.htm

 HAPPY
CITY HOLDINGS LIMITED

 May
28, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade & Services

 100
F Street, NE

 Washington,
D.C., 20549

 Attn: Jenna
Hough

 Re:
 Happy City Holdings
 Limited

 Registration Statement
 on Form F-1

 File No. 333-285856

 Request for Acceleration
 of Effectiveness

 Ladies
and Gentlemen:

 In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Happy City Holdings
Limited hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form F-1, as amended,
so that such Registration Statement will become effective at 5:00 p.m., Eastern Time, on May 30, 2025, or as soon thereafter as practicable.

 The
Company understands that the Commission will consider this request for acceleration of the effective date of the Registration Statement
as a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed
public offering of the securities specified in the Registration Statement.

 Very truly yours,

 Happy City Holdings Limited

 By:
 /s/
 Suk Yee, Kwan

 Name:
 Suk Yee, Kwan

 Title:
 Chief Executive Officer and Director