SecProbe.io

September 15, 2025
Kwok Tin Ming
Chief Executive Officer
TDE Group Limited
Unit 2101, 21/F
The Bay Hub
17 Kai Cheung Road
Kowloon Bay
Hong Kong
Re:TDE Group Limited
Registration Statement on Form F-1
Filed August 29, 2025
File No. 333-289968
Dear Kwok Tin Ming:
            We have reviewed your registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe the comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1
General
1.Please revise and expand your disclosure throughout to clarify the terms of your
partnership with LEGO Education, including whether there are any associated
agreements and a discussion of the terms of such agreements. Please file the
agreements as exhibits to the registration statement, or tell us why you are not
required to do so. Refer to Item 601(b)(10) of Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.

September 15, 2025
Page 2
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alyssa Wall at 202-551-8106 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Erik Mengwall