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 May 29, 2025

Kit Shing Cheung
Chief Executive Officer
Etoiles Capital Group Co., Ltd
Room 1109, 11/F, Tai Yau Building
No. 181 Johnston Road, Wanchai, Hong Kong

 Re: Etoiles Capital Group Co., Ltd
 Amendment No. 1 to Registration Statement on Form F-1
 Filed May 23, 2025
 File No. 333-287302
Dear Kit Shing Cheung:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 2, 2025
letter.

Amendment No. 1 to Registration Statement on Form F-1 Filed May 23, 2025
Our Corporate History and Structure, page 56

1. We note your statement that "Etoiles Zeneo Investment Limited proposed
to surrender
 5,000,000 Class B Ordinary Shares to the Company for the cancellation,
and the
 Company approved the surrender and cancellation of such shares on May 8,
2025."
 Please revise to note whether Etoiles Zeneo Investment Limited received
any
 consideration for cancellation of the shares, and if so state the
amount. If it did not
 receive any consideration, please revise to state as much and state why
not.
 Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309
if you
have questions regarding comments on the financial statements and related
matters. Please
 May 29, 2025
Page 2

 contact Alyssa Wall at 202-551-8106 or Cara Wirth at 202-551-7127 with
any other
questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
cc: Lawrence Venick
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