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 April 17, 2025

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No, 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Draft Registration Statement on Form F-4
 Submitted March 21, 2025
 CIK No. 0002060614
Dear Lulu Xing and Bin Xiong:

 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.
 April 17, 2025
Page 2

Draft Registration Statement on Form F-4 submitted March 21, 2025
Cover Page

1. We note your disclosure on page 195 that Bin Xiong through XB B Limited
will have
 80% voting power via their Class B Ordinary Share ownership upon
completion of the
 business combination. To the extent PubCo will be a controlled company
after the
 business combination, please revise the proxy statement/prospectus cover
page to (i)
 clearly state as much, (ii) disclose the percentage of voting power to
be held by the
 controlling shareholder following the business combination and (iii) if
true, state that
 the controlling shareholder will have the ability to determine all
matters requiring
 approval by shareholders. Additionally, and if applicable, please
include a standalone
 risk factor that addresses the risks of being a controlled company.
2. Please revise the proxy statement/prospectus cover page to disclose more
clearly the
 RDAC board of directors determination required by Items 1604(a)(1) and
1606(a) of
 Regulation S-K.
3. Please revise your table regarding the Equity Capitalization Summary,
and any other
 tabular representation regarding redemption scenarios throughout your
proxy
 statement/prospectus including the Dilution table on page 20, to
disclose redemption
 scenarios at quartile intervals. Refer to Item 1604(c) of Regulation
S-K.
4. Please refer to the Compensation Received by the Sponsor table on the
proxy
 statement/prospectus cover page. Please revise the "Interest in
Securities" column to
 detail the purchase of Private Units by the Sponsor in connection with
RDAC's
 IPO. Refer to Item 1604(a)(3) of Regulation S-K. Additionally, please
make
 conforming changes to the comparable table on page 29 and elsewhere as
 applicable. Refer to Item 1604(b)(4) of Regulation S-K.
5. Please refer to the "Conflicts of Interest" section on the proxy
statement/prospectus
 cover page. Please revise to address whether, in connection with the
de-SPAC
 transaction, there may be any actual or potential material conflict of
interest between:
 on one hand, the target company officers or target company directors;
and, on the
 other hand, unaffiliated security holders of the SPAC. Refer to Item
1604(a)(4) of
 Regulation S-K.
6. Please revise the "Conflicts of Interest" section to provide a
cross-reference to your
 risk factor beginning "We may have conflicts of interest with our
largest
 shareholders..." on page 64. Refer to Item 1604(a)(4) of Regulation S-K.
Use of Certain Terms, page i

7. For clarity and consistency, please briefly revise certain terms here to
make clear the
 relationship of certain entities to PubCo, RDAC, HZJL or others. For
example, but not
 limited to, we note that "Lucid" refers to Lucid Capital Markets, LLC.
However, it is
 not until page 168 where you disclose Lucid to be the representative of
the
 underwriters in Rising Dragon's IPO.
 April 17, 2025
Page 3
8. We note your disclosure that "Investors will only hold equity interests
in HZJL, a
 Cayman Islands holding company and will never have a direct ownership
interest in
 HZJL's PRC Operating Entities." We also note that this registration
statement relates
 to the registration of securities related to PubCo not HZJL. Please
reconcile and revise
 this disclosure as applicable.
Questions and Answers about the Business Combination and the Extraordinary
General
Meeting
Q: What is the redemption scenario accompanying with the Business Combination?,
page 5

9. For the RDAC Public Shareholders, RDAC Initial Shareholders and Others
share
 amounts presented here and elsewhere throughout the filing, please
disclose with
 quantification in a footnote to the table the composition of the share
amounts
 presented. Also, ensure that the RDAC Public Shareholders and RDAC
Initial
 Shareholders line items are reconciled to share amounts shown in the
latest RDAC
 balance sheet as well. This comment also applies to share amounts titled
differently
 elsewhere in the filing (e.g., shares subject to possible redemption,
shares not subject
 to possible redemption, etc.).
Questions and Answers about the Business Combination...
Q: What is the redemption scenario accompanying with the Business Combination?,
page 5

10. We note that the answer to the included question discusses "book value
per share" and
 pro forma impacts on such value. We also note that the included table
doesn't appear
 to align with the answer and doesn't detail any book value calculations.
Please
 reconcile the answer and included table as applicable.
11. We note that page 114 notes that the parties intend to adopt an Employee
Stock
 Ownership Plan. To the entent known, please revise the "potential
sources of dilution"
 to include details regarding the plan, i.e. the number of reserved
shares, etc.
Q: What will PubCo's share structure be following the Business Combination?,
page 6

12. We note that Bin Xiong through XB B Limited will own all of PubCo's
Class B
 Ordinary Shares. Please revise to disclose their ownerhsip of the Class
B Ordinary
 Shares and the respective voting power to be held by XB B Limited upon
closing of
 the business combination.
Q: Did Rising Dragon obtain a fairness opinion prior to entering into the
Merger Agreement?,
page 9

13. Please revise your disclosure here and elsewhere throughout the proxy
 statement/prospectus where appropriate to briefly describe the
qualifications of CHFT
 as well as describe the method of selection of CHFT. Refer to Item
1607(b)(1)-(3) of
 Regulation S-K.
Q: After redemptions, how many shares will be outstanding?, page 10

14. We note that the table includes an "Others" line. Please revise to
include a footnote to
 disclose who is included within this line item (i.e. underwriters or
financial
 advisors).
 April 17, 2025
Page 4

Q: What happens to the funds deposited in the trust account following the
Business
Combination?, page 13

15. Please revise the answer to discuss in greater detail how the funds in
the trust account
 will be used in connection with the business combination. Consider
adding a table or
 chart to detail the use of such funds.
Post-Business Combination Structure and Impact on the Public Float, page 19

16. Please revise this post-business combination structure diagram to
include both share
 holdings as well as voting percentages held by the respective parties.
17. Please revise this corporate structure diagram to include the place of
incorporation for
 each entity. Consider the use of footnotes. In this regard, we note that
below the
 diagram you state that "HZJL 100% owns Joy A Limited, a British Virgin
Islands
 business company, which 100% owns HZJL's other subsidiaries."
Summary of the Proxy Statement/Prospectus
Dilution, page 20

18. The redemption of public shares in an amount that would cause Rising
Dragon s net
 tangible assets to be less than $5,000,001 could prevent the Business
Combination
 from proceeding. Please revise your dilution table and other redemption
scenarios
 throughout the filing to only reflect redemption scenarios that are
possible under
 current terms, without the need for a waiver.
19. Please revise your SPAC dilution disclosures to start with the SPAC's
net tangible
 book value as of the most recent SPAC balance sheet date presented.
20. The company valuation amounts presented here and elsewhere throughout
the
 filing do not represent your company's valuation. Please revise the
title to better
 reflect what it actually represents. Refer to Item 1604(c)(1) of
Regulation S-K.
Regulatory Approvals, page 24

21. We note your disclosure that you are required to file with the CSRC in
connection
 with this offering and the business combination. In subsequent
amendments, please
 disclose the date of filing and the status of your filing with the CSRC.
Interests of Certain Persons in the Business Combination, page 30

22. Please revise this section or add a new conflicts of interest section
for the target
 company to disclose any actual or potential material conflict of
interests due to the de-
 SPAC transaction between the target company officers and directors and
unaffiliated
 security holders of RDAC. Refer to Item 1604(b)(3) of Regulation S-K.
Summary of Risk Factors, page 33

23. Please amend your disclosure here and risk factors sections to provide
an appropriate
 risk factor and state that, to the extent cash/assets in the business is
in the PRC/Hong
 Kong or a PRC/Hong Kong entity, the funds/assets may not be available to
fund
 operations or for other use outside of the PRC/Hong Kong due to
interventions in or
 the imposition of restrictions and limitations on the ability of you or
your subsidiaries
 April 17, 2025
Page 5

 by the PRC government to transfer cash/assets. On the cover page,
provide cross-
 references to these other discussions. We note your discussion under the
subheading
 "Cash Transfers among HZJL and its Subsidiaries" on page 23.
Risk Factors
Risks Related to Ownership of PubCo's Securities
We may have conflicts of interest with our largest shareholder..., page 64

24. Please revise this risk factor and elsewhere throughout the proxy
statement/prospectus
 where appropriate to quantify the voting power that will be held by your
largest
 shareholder immediately after the completion of the business
combination. In this
 regard, we note that here you describe the largest shareholder as having
"a fair
 amount" of voting rights. Additionally, we note that the tables in the
section titled
 "Security Ownership of the Combined Company after the Business
 Combination" reflects voting power by Mr. Bin Xiong of up to 80%
assuming no
 redemptions and up to 83.1% assuming maximum redemptions. Further,
please revise
 this risk factor to name your largest shareholder and state his
position.
Capitalization, page 84

25. Please discuss each adjustment being made to arrive at the as adjusted
amounts in
 each scenario presented. Also, break out the shareholders' equity line
item into its
 separate components.
26. Your total capitalization equals the sum of your total stockholders'
equity and non-
 controlling interest, however, please note capitalization is generally
defined in
 practice as the sum of a company's debt and equity. Please revise or
advise
 accordingly. Refer to Item 3.B of Form 20-F.
U.S. Federal Income Tax Consequences of the Reincorporation Merger to U.S.
Holders, page
93

27. Please provide a tax opinion covering the material federal tax
consequences to RDAC
 security holders regarding the Reincorporation Merger and revise the
disclosure in
 this section to acknowledge and reflect that the tax consequences are
the opinion of
 counsel. Refer to Item 4(a)(6) of Form F-4 and Items 601(b)(8) and
1605(b)(6) of
 Regulation S-K. For guidance in preparing the opinion and related
disclosure, please
 refer to Section III of Staff Legal Bulletin No. 19. Additionally,
please revise to
 address and express a conclusion for each material federal tax
consequence, i.e.
 whether the Reincorporation Merger qualifies as a reorganization with in
the meaning
 of Section 368 of the Code. A description of the law is not sufficient.
If there is a lack
 of authority directly addressing the tax consequences of the
transaction, conflicting
 authority or significant doubt about the tax consequences of the
transaction, counsel
 may issue a should or more likely than not opinion to make
clear that the opinion
 is subject to a degree of uncertainty. In such cases, counsel should
explain clearly why
 it cannot give a will opinion. Refer to Sections III.C.1, III.C.2
and III.C.4 of Staff
 Legal Bulletin No. 19.
 April 17, 2025
Page 6
Proposal No. 2 - The Acquisition Merger
General Description of the Acquisition Merger, page 99

28. Please revise to disclose whether Mr. Bin Xiong, the Chief Executive
Officer of
 HZJL, has entered into any agreement with the company to continue his
employment
 and role with HZJL in connection with the business combination.
29. Please revise this section to describe the effects of the de-SPAC
transaction and any
 related financing transaction on the special purpose acquisition company
and its
 affiliates, the SPAC sponsor and its affiliates, and unaffiliated
security holders of the
 special purpose acquisition company. The description must include a
reasonably
 detailed discussion of both the benefits and detriments of the de-SPAC
transaction and
 any related financing transaction to the special purpose acquisition
company and its
 affiliates, the SPAC sponsor and its affiliates, and unaffiliated
security holders of the
 special purpose acquisition company. The benefits and detriments of the
de-SPAC
 transaction and any related financing transaction must be quantified to
the extent
 practicable. We note your discussion under the subheading "Benefits and
Detriments
 of the Business Combination HZJL" on page 128. Refer to Item 1605(c) of
Regulation
 S-K.
Selected Comparable Companies:, page 118

30. We note your disclosure regarding the selection of Supply of Food
Products, Online
 Software Services and Branding Services comparable companies used in
reaching the
 valuation of $350 million for HZJL, including the disclosed differences
between
 HZJL and these companies, and employing a conservative valuation metric.
However,
 please revise your disclosure to briefly discuss why you did not select
any earlier-
 stage companies or companies that are otherwise at more similar revenue
or other
 financial metric levels to that of HZJL in determining a valuation. In
this regard, we
 note your disclosure that states that HZJL is "an early-stage company"
as compared to
 the comparable companies, which are generally better capitalized and
more
 established business operations than HZJL.
2. Online Software Services Business, page 126

31. Please explain the source of and assumptions behind forecasted income
derived from
 agency fees and subscription revenues, as these sources of revenue are
not found
 elsewhere in your filing. In addition, please provide the basis for and
discuss the
 assumptions and factors used to determine the 580 agents in 2025,
including how this
 number of agents was derived from historical data. Similarly revise your
disclosures
 regarding the assumptions and factors used in arriving at the forecasted
revenues for
 the branding services business. Also, disclose your rationale for
assuming the volume
 of promotional units will increase from 260 thousand in 2025 to 11.65
million in
 2029.
 April 17, 2025
Page 7
Proposal No. 2 - The Acquisition Merger Proposal
Rising Dragon Board of Director's Reasons for Approving the Business
Combination
Summary of HZJL Financial Analysis
HZJL Management Projections
1. Supply of Food Product Business, page 126

32. Food product busine