SecProbe.io

September 26, 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. 3 to Registration Statement on Form S-1
Filed September 16, 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 September 12, 2025
letter.
Amendment No. 2 to Registration Statement on Form S-1
Description of Business
Contracted Clients, page 34
Please revise to clarify the duration of your customer service agreements described
here. Make clear the respective effective dates and whether these agreements are still
in effect. With regard to Service Agreement No. 1, you disclose that you entered into
this agreement on November 26, 2024 and that the term of the agreement
commences on the effective date and continues for a period of three months, or until
February 26, 2025. Similarly, with regard to Service Agreement No. 2 you entered
into the agreement on May 2, 2025 for a period of two months from the effective date, 1.

September 26, 2025
Page 2
or until July 2, 2025. To the extent you no longer have any effective
service agreements, or other effective customer agreements that are currently
generating revenue, please revise your disclosure throughout the registration statement
to state the same. Please update your Business, Management's Discussion and
Analysis, and Risk Factors sections accordingly.
Exhibits to Registration Statement, page II-2
2.We note that you legal opinion, filed as Exhibit 5.1, states that you are registering up
to 500,000,000 shares of common stock. However, the cover page and fee table, filed
as Exhibit 107, state that you are offering 2,000,000 shares of common stock. Please
reconcile for consistency. Additionally, please file a written consent for each of L&C
Law Group P.C. and Guangdong Shenmou Law Firm. Refer to Item 601(b)(23) of
Regulation S-K.
General
3.We note that all of your operations are conducted through your sole entity, Cybriatech
Inc., a Nevada corporation operating in Hong Kong. It appears that you do not have
any subsidiaries. If true, please revise to remove references that describe yourself as
a holding company and any disclosure that may suggest you currently have operating
subsidiaries. Maintain disclosure that the PRC government/Chinese regulatory
authorities could disallow your structure.
            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