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CORRESP Filing

Hang Feng Technology Innovation Co., Ltd.
Date: Aug. 11, 2025 · CIK: 0002060083 · Accession: 0001213900-25-074182

Financial Reporting Offering / Registration Process Capital Structure

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File numbers found in text: 333-287284

Referenced dates: August 7, 2025

Date
August 11, 2025
Author
/s/ XU Zhiheng
Form
CORRESP
Company
Hang Feng Technology Innovation Co., Ltd.

Letter

Hang Feng Technology Innovation Co., Ltd.

August 11, 2025

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

Attention: Valeria Franks

Joel Parker

Re: Hang Feng Technology Innovation Co., Ltd.

Amendment No. 1 to Registration Statement on Form F-1

Filed July 25, 2025

File No. 333-287284

Ladies and Gentlemen:

This letter is in response to the letter dated August 7, 2025, from the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission") addressed to Hang Feng Technology Innovation Co., Ltd. (the "Company," "we," and "our"). For ease of reference, we have recited the Commission's comment in this response and numbered it accordingly. An amended registration statement (the "Amendment No.2") on Form F-1 is being filed to accompany this letter.

Amendment No. 1 to Registration Statement on Form F-1

Capitalization, page 53

1. Please revise your as adjusted cash balance to reflect the $3.77 million of net proceeds, or explain how you calculated the $7.59 million amount.

Response: In response to the Staff's comments, we have revised the as adjusted cash balance to reflect the $3.77 million of net proceeds on page 53 of the Amendment No.2 accordingly.

* * * * * * * * * * * * * * * *

In responding to your comments, the Company acknowledges that:

● the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

● Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

● the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. and Sally Yin, Esq. of Hunter Taubman Fischer & Li LLC, at (212) 530-2208 and (212)-202-6380.

Very truly yours,
/s/ XU Zhiheng

Show Raw Text
CORRESP
 1
 filename1.htm

 Hang Feng Technology Innovation Co., Ltd.

 August 11, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:
 Valeria Franks

 Joel Parker

 Re:
 Hang Feng Technology Innovation Co., Ltd.

 Amendment No. 1 to Registration Statement on Form F-1

 Filed July 25, 2025

 File No. 333-287284

 Ladies and Gentlemen:

 This letter is in response to the letter dated
August 7, 2025, from the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission")
addressed to Hang Feng Technology Innovation Co., Ltd. (the "Company," "we," and "our"). For ease
of reference, we have recited the Commission's comment in this response and numbered it accordingly. An amended registration statement
(the "Amendment No.2") on Form F-1 is being filed to accompany this letter.

 Amendment No. 1 to Registration Statement
on Form F-1

 Capitalization, page 53

 1.
 Please revise your as adjusted cash balance to reflect the $3.77 million of net proceeds, or explain how you calculated the $7.59 million amount.

 Response: In response to the Staff's comments,
we have revised the as adjusted cash balance to reflect the $3.77 million of net proceeds on page 53 of the Amendment No.2 accordingly.

 * * * * * * * * * * * * * * * *

 In responding to your comments, the Company
acknowledges that:

 ●
 the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 ●
 Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

 ●
 the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. and Sally Yin, Esq. of Hunter
Taubman Fischer & Li LLC, at (212) 530-2208 and (212)-202-6380.

 Very truly yours,

 /s/ XU Zhiheng

 Name:
 XU Zhiheng

 Title:
 Chief Executive Officer

 cc:

 Joan Wu, Esq.
 Sally Yin, Esq.
 Hunter Taubman Fischer & Li LLC