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 June 11, 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.
 Amendment No. 1 to Draft Registration Statement on Form F-4
 Submitted May 19, 2025
 CIK No. 0002060614
Dear Lulu Xing and Bin Xiong:

 We have reviewed your amended 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. Unless we note otherwise, any references to prior comments are to
comments in
our April 17, 2025 letter.
 June 11, 2025
Page 2

Amendment No. 1 to Draft Registration Statement on Form F-4
Cover Page

1. We note your response to prior comment 1, including that PubCo will be a
"controlled
 company" within the meaning of the corporate governance standards of the
Nasdaq
 listing rules immediately after the consummation of the Business
Combination. Please
 further revise your disclosure here and in your risk factor on page 179
beginning
 "Because PubCo will be a "controlled company"..." to state whether you
plan to elect
 to rely on any of the corporate governance exemptions that will be
available to you
 under Nasdaq rules.
2. We note your response to prior comment 3 and reissue. Please further
revise your
 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. In
 this regard, we note that you provide four redemption scenarios, but
have excluded the
 25% quartile in the presentations. Please revise accordingly.
Questions and Answers About this Business Combination...
Q: After redemptions, how may shares will be outstanding?, page 10

3. We note your response to prior comment 14, including the addition of a
table listing
 the "Others." Please further revise your disclosure to make clear the
name of the
 "financial advisory" listed in the first line under "Others" here. In
this regard, we note
 that elsewhere you describe how Chain Stone Capital Limited ("CTM") was
engaged
 by HZJL as a financial consultant via a financial advisory engagement
agreement and
 that CTM is entitled to receive $600,000 in cash and 1,750,000 PubCo
Class A
 Ordinary Shares upon completion of the Business Combination as
compensation for
 its services.
Summary of the Proxy Statement/Prospectus
Dilution, page 20

4. We read your response to prior comment 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 (i.e., March 31, 2025).
5. We read the changes you made in response to prior comment 20. The pro
forma
 market value amount reflected appears to be neither a pro forma amount
nor a market
 value amount. Please revise to the title to more accurately reflect what
the amount
 represents.
Comparative Per Share Information, page 40

6. Please present pro forma book value (deficit) per share information as
of the most
 recent pro forma balance sheet date only (i.e., December 31, 2024).
Also, revise the
 pro forma net (loss) income and basic and diluted net income (loss) per
share
 information for the year ended June 30, 2024, so that it agrees to your
pro forma
 June 11, 2025
Page 3

 financial information on page 184. Also, present pro forma net (loss)
income and
 basic and diluted net income (loss) per share information for the six
months ended
 December 31, 2024.
Capitalization, page 86

7. We read your response to comment 25. Similar to your pro forma balance
sheet on
 page 181, please include a separate line item for each equity security
and disclose the
 number of shares authorized, issued and outstanding for each equity
security on a
 historical basis and under each redemption scenario.
8. We read your response to prior comment 26. Your total capitalization and
 indebtedness should comprise only the sum of your total shareholders
 equity (deficit) and your indebtedness. Please revise the total
capitalization and
 indebtedness line item so that it sums correctly. Also, remove the other
unrelated line
 items that you have presented, which do not relate to your total
capitalization and
 indebtedness (e.g., prepaid expense, accrued liabilities, etc.). Refer
to Item 3.B of
 Form 20-F.
Summary of HZJL Financial Analysis, page 126

9. We note your response to prior comment 33 and reissue in part. Please
revise to
 disclose whether or not HZJL has affirmed to Rising Dragon that its
projections
 reflect the view of the HZJL's management or board of directors about
its future
 performance as of the most recent practicable date prior to the date of
the disclosure
 document required to be disseminated to security holders. If the
projections no longer
 reflect the views of HZJL's management or board of directors regarding
the future
 performance of HZJL as of the most recent practicable date prior to the
date of the
 disclosure document required to be disseminated to security holders,
state the purpose
 of disclosing the projections and the reasons for any continued reliance
by the
 management or board of directors on the projections. Refer to Item
1609(c) of
 Regulation S-K.
Proposal No. 2 - The Acquistion 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 128

10. We read your response to prior comment 32. Please reconcile your
disclosures
 regarding future anticipated food product increases with those on page
158, which
 state the decrease in food products through June 30, 2024, was because
you intend to
 place more focus on development of branding services. In your response,
tell us why
 you believe you have not experienced the synergistic growth you
anticipated in food
 products considering branding services and online software services
revenues
 increased significantly during the six months ended December 31, 2024.
 June 11, 2025
Page 4
Business of HZJL
Overview, page 140

11. We note your response to prior comment 35 and reissue in part.
Specifically, we note
 that your response states that there is an agreement in place between
Beijing Dianqier
 and Shanghai China Business News Media, effective from July 1, 2024 to
December
 30, 2025, Beijing Dianqier will procure guests for Founder s Glory
 and pay
 Shanghai China Business News Media the relevant production fees in
exchange for
 the advertising revenues generated from Founder s Glory. Please
revise your
 disclosure accordingly to include a description and terms (e.g.,
duration) of this
 agreement. Additionally, please file this agreement as an exhibit or
tell us why you do
 not believe it is necessary to be filed under Item 601(b) of Regulation
S-K.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
HZJL
Discussion of Certain Balance Sheet Items, page 162

12. Certain liabilities in the December 31, 2024 column are not consistent
with those
 presented in the unaudited balance sheet on page F-60. Please revise for
consistency.
Selected Historical Financial Information of Rising Dragon, page 175

13. The middle columns in the Income Statement Data and Statement of Cash
Flow
 Data tables appear to represent the period from March 8, 2024 through
March 31,
 2024 rather than three months then ended. Please revise.
Unaudited Pro Forma Condensed Combined Financial Information
Basis of Pro Forma Presentation, page 179

14. We read your response to prior comment 39. Please include the same
number of
 redemption scenarios throughout your pro forma financial information, in
your
 comparative per share information on page 40 and in your capitalization
table on page
 86 that you do elsewhere throughout the filing.
Unaudited Pro Forma Condensed Combined Balance Sheet, page 181

15. Please disclose your basis for not reflecting the payment of the
deferred underwriting
 fees payable under any pro forma scenario. Also, disclose why the
deferred
 underwriting fees payable are not reflected as a current liability under
any pro forma
 scenario that they remain unpaid. In addition, disclose here and in the
footnotes to
 Rising Dragon's historical financial statements:
 the terms of their payment under your agreement with the
underwriter, and
 the ramifications of not meeting those payment terms upon
consummation of the
 Business Combination.
Unaudited Pro Forma Combined Statement of Operations for the Year Ended June
30, 2024,
page 184

16. We read your response to prior comment 41. You continue to exclude the
other
 income, net, net loss attributable to non-controlling interest and net
income (loss)
 June 11, 2025
Page 5

 attributable to ordinary shareholders line items shown on page F-34 from
column (B)
 HZJL on page 184. HZJL's net income in column (B) on page 184 also still
differs
 from the amount shown on page F-34. Please revise or advise.
 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David J. Levine
 Yu Wang
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