SecProbe.io

September 12, 2025
Hongyan Yu
Chief Executive Officer
Cybriatech Inc
B2, 6/F, Phase-2 Hang Fund Industrial Building
2G, Hok Yuen Street, Hung Hom, Kowloon
Hong Kong
Re:Cybriatech Inc
Amendment No. 2 to Registration Statement on Form S-1
Filed August 22, 2025
File No. 333-287896
Dear Hongyan Yu:
            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 July 8, 2025 letter.
Amendment No. 2 to Registration Statement on Form S-1
Cover Page
We note your response to prior comment 2 and reissue in part. Please revise your
disclosure to state specifically that you are not a Hong Kong/PRC operating company
but a Nevada holding company with operations in Hong Kong and that this structure
involves unique risks to investors. Further, revise your disclosure to state directly that
PRC regulatory authorities could disallow this structure, which would likely result in
a material change in your operations and/or a material change in the value of the
securities you are registering for sale, including that it could cause the value of such
securities to significantly decline or become worthless. We note the cross-reference to
your detailed discussion of the risks facing the company, including the risk factor 1.

September 12, 2025
Page 2
beginning "All of our operations are in Hong Kong, a special administrative region of
the PRC... ."
Prospectus Summary, page 7
2.We note your response to prior comment 8, including that your PRC counsel has
advised your that you are not required to obtain and permissions or approvals from the
PRC authorities, and reissue in part. Please state whether any permissions or
approvals have been denied.
Risk Factors
Risks Relating to Doing Business in Hong Kong
It will be difficult to acquire jurisdiction and enforce liabilities..., page 21
3.We note your response to prior comment 12 and reissue in part. Please state plainly
here and elsewhere as appropriate, including the "Enforceability of Civil Liabilities"
section that your sole officer and director is located in Hong Kong rather than stating
that they reside "outside of the United States."
Description of Business, page 33
4.We note your revised disclosure and filed exhibits in response to prior comment 16.
Please revise to acknowledge your customer agreements and disclose the material
terms of the agreements here, including the compensation structure in each.
Dilution, page 37
5.Please update your dilution calculations for the most recent balance sheet presented.
Item 8. Exhibits.
Exhibit 8.1, page II-2
6.We note your response to prior comment 10. Please revise your disclosure here and
refile as necessary to reflect that this is not a "form of" opinion but rather the opinion
of your PRC legal counsel.
General
7.We note that you mention your "officers and directors" throughout the registration
statement. Please revise to reflect that you currently have one officer and director.
            Please contact Abe Friedman at 202-551-8298 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters. Please
contact Kate Beukenkamp at 202-551-3861 or Cara Wirth at 202-551-7127 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services