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 September 10, 2025

Ricky Ling Fung Sung
Chief Executive Officer
Monkey Tree Investment Ltd
Suite 2514, 25/F, 1111 King s Road
Taikoo Shing, Hong Kong

 Re: Monkey Tree Investment Ltd
 Registration Statement on Form F-1
 Filed August 15, 2025
 File No. 333-289637
Dear Ricky Ling Fung Sung:

 We have reviewed your 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.

Registration Statement on Form F-1 filed August 15, 2025
Corporate History and Structure, page 3

1. We note your disclosure that your Controlling Shareholder and
Timberworks Limited
 owns 11,205,600 Class A Ordinary Shares. However, we also note your
disclosure
 that Timberworks Limited was issued 13,999,999 Class A Ordinary Shares
on May
 12, 2025. Please revise throughout to reconcile or otherwise reflect any
transfers
 between Timberworks Limited and other shareholders. Additionally, please
revise
 your organizational chart to reflect the ownership of each separate
class of ordinary
 shares.
 September 10, 2025
Page 2
Risk Factors
Risks Related to Our Business and the Industry
Our success depends significantly on the market recognition of our brand, . .
., page 21

2. We note your response to prior comments 2 and 6 and reissue in part.
Please clarify
 your statement that Monkey Tree HK currently does not operate other
language
 learning centers or carry out business operations under the Monkey
Tree brand, in
 light of the fact that Monkey Tree HK essentially controls the
operations and
 decision-making for your 20 learning centers and the approximately 38
other
 operators. Additionally, we note your statement that other
franchisees of Monkey
 Tree HK are independent from . . . [y]our Controlling Shareholder.
Please revise to
 state clearly the relationship between the other franchisees and your
Controlling
 Shareholder, who we note is the Chief Executive Officer of Monkey Tree
HK,
 where Monkey Tree HK controls a number of the operations and
decision-making for
 the other franchisees. If that is not the case, please revise to state
as much and explain
 the relationship further.
Business
Suppliers, page 89

3. We note your revised disclosure in response to prior comment 12. If
material, please
 revise to disclose the pre-agreed amount to be paid by Monkey Tree as
liquidated
 damages as a result of a breach as well as appropriate risk factor
disclosure.
Related-Party Transactions
Name and relationship of related parties, page 105

4. We note your response to prior comments 4 and 15 and reissue in part.
Please revise
 to identify the "common ultimate holding company" and include it on your
 organizational chart. We note that you refer to Monkey Tree as your
ultimate holding
 company on page 3. However, your response indicates that Monkey Tree HK,
Panda
 Garden Language Learning Ltd., and Canadian Bookstore Ltd. are related
companies
 with "the common ultimate holding company of the Company." Please revise
here to
 clearly state the nature of the relationship between Monkey Tree
Investment Limited
 and each of the entities listed as related parties. Further, please
revise your
 organizational chart, and throughout, to clearly reflect the
relationship between
 Monkey Tree and Monkey Tree HK.
Bank borrowings guaranteed by a director, page 106

5. We note your response to prior comment 16 and reissue in part. For any
outstanding
 loans made by the company, its parent or any of its subsidiaries,
disclose the largest
 amount outstanding during the period covered, if not already indicated.
Refer to Item
 7.B.2 of Form 20-F.
General

6. We note your response to prior comment 21 and reissue in part. Please
provide the
 percentage of outstanding shares of Class B Ordinary Shares that the
Controlling
 Shareholder must keep to continue to control the outcome of matters
submitted to
 shareholders for approval.
 September 10, 2025
Page 3

 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.

 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 Patrick Kuhn at 202-551-3308 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Eddie Kim at 202-551-8713 or Cara Wirth at 202-551-7127
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Virginia Tam
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