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Cybriatech Inc.

B2, 6/F, Phase-2 Hang Fund Industrial Building

2G, Hok Yuen Street, Hung Hom, Kowloon

Hong Kong

August 7, 2025

Via Edgar

Office of Trade & Services

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Cybriatech Inc.

    Registration Statement on Form S-1

    Filed June 10, 2025

    File No. 333-287896

Dear Officer:

This letter is in response to the letter dated July 8, 2025, from the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed to Cybriatech Inc.
(the “Company,” “we,” and “our”). For ease of reference, the Staff’s comments are recited below
in bold and are followed by the Company’s responses. Amendment No. 1 to the Registration Statement on Form S-1 (the “S-1/A”)
is being filed to accompany this letter.

Registration Statement on Form S-1 filed on June 10, 2025

Cover Page

    1.
    Please revise your cover page and elsewhere as appropriate throughout the registration statement to reflect the percentage voting power that your CEO, Mr. Yu, will continue to hold if all 2,000,000 shares are sold in this offering. We note your statement that Mr. Yu will hold 75% of the stock. Additionally, for clarity revise your statements to make clear that Mr. Yu currently controls 100% of the voting power of your company. Last, please revise to briefly describe the substantial voting power and control over certain corporate matters that Mr. Yu will have (e.g., election of the board of directors). Consider a cross-reference to your risk factor on page 7 beginning "Our President, Hongyan Yu, owns and controls 100% of the voting power ... ."

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on the cover page of the Registration Statement the percentage voting power that
our CEO, Mr. Yu, will continue to hold if all 2,000,000 shares are sold in this offering, and that Mr. Yu currently controls 100% of the
voting power of your company, and a brief description of the substantial voting power and control over certain corporate matters that
Mr. Yu will have.

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    2.
    Please disclose prominently on the prospectus cover page that you are not a Chinese operating company but, if true, a Nevada holding company with operations conducted by subsidiaries based in China and operating in Hong Kong and that this structure involves unique risks to investors. Disclose that investors may never hold equity interests in the Chinese operating company. Additionally, please disclose whether operations conducted by your subsidiaries are through contractual arrangements with a variable interest entity(ies) based in China and that, regardless, this structure involves unique risks to investors. If true, disclose that these contracts have not been tested in court. Explain whether the VIE structure is used to provide investors with exposure to foreign investment in China-based companies where Chinese law prohibits direct foreign investment in the operating companies, and disclose that investors may never hold equity interests in the Chinese operating company. To the extent there is a VIE structure, we may have additional comments. Alternatively, if true, please state that your corporate structure does not include VIEs. Your disclosure should acknowledge that Chinese 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. Provide a cross-reference to your detailed discussion of risks facing the company and the offering as a result of this structure.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on the prospectus cover page of the Registration Statement that we are not a
Chinese operating company, that we do not have any subsidiary, that our corporate structure does not include any variable interest entity,
and that any investor who purchases shares may never hold equity interests in the Chinese operating company.

    3.
    Provide prominent disclosure about the legal and operational risks associated with being based in or having the majority of your operations in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or the value of the securities you are registering for sale or could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure should address how recent statements and regulatory actions by China’s government, such as those related to data security or antimonopoly concerns, have or may impact the company’s ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange. We note you intend to seek OTCQB quotation. Please disclose the location of your auditor’s headquarters and whether and how the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, 2023, and related regulations will affect your company. Your prospectus summary should address, but not necessarily be limited to, the risks highlighted on the prospectus cover page. Last, provide cross-references to the individual risk factors identified on the cover page.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on the cover page of the Registration Statement the legal and operational risks
associated with being based in or having the majority of our operations in Hong Kong, and whether these risks could result in a material
change in our operations and/or the value of the securities we are registering for sale or could significantly limit or completely hinder
our ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be
worthless. The Company has also disclosed the location of our auditor’s headquarter, and how the Holding Foreign Companies Accountable
Act, as amended by the Consolidated Appropriations Act, 2023, will affect our company.

    4.
    Clearly disclose your corporate structure, including identifying how you will refer to the holding company and any subsidiaries when providing the disclosure throughout the document so that it is clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business operations. Disclose, if true, that your subsidiaries conduct operations in China and that the holding company does not conduct operations. Disclose clearly the entity (including the domicile) in which investors are purchasing an interest.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed our corporate structure to reflect that we currently have only one entity, Cybriatech
Inc., in our corporate structure, that we do not have any subsidiary, and that investors will hold shares in Cybriatech Inc.

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    5.
    Provide a description of how cash is transferred through your organization. State whether any transfers, dividends, or distributions have been made to date between the holding company and its subsidiaries, or to investors, and quantify the amounts where applicable.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on the cover page of the Registration Statement that the Company does not have
any subsidiary, that there is no cash transfer through our organization, and that none of transfers, dividends, or distributions have
been made to date from the Company to investors.

    6.
    To the extent you have cash management policies that dictate how funds are transferred between you and your subsidiaries, summarize the policies on your cover page and in the prospectus summary, and disclose the source of such policies (e.g., whether they are contractual in nature, pursuant to regulations, etc.); alternatively, state on the cover page and in the prospectus summary that you have no such cash management policies that dictate how funds are transferred. Provide a cross-reference on the cover page to the discussion of this issue in the prospectus summary.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on the cover page of the Registration Statement that the Company has not established
or maintained any cash management policies that dictate how funds are transferred.

Prospectus Summary, page 1

    7.

    In your summary of risk factors, disclose the risks that your
corporate structure and being based in or having the majority of the company’s operations in China poses to investors. In particular,
describe the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these
risks in the prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties
regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk
that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted
overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value
of the securities you are registering for sale. Acknowledge any risks that any actions by the Chinese government to exert more oversight
and control over offerings that are conducted overseas and/or foreign investment in China based issuers could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly
decline or be worthless. For each PRC-related summary risk factor, provide a cross-reference to the relevant individual detailed risk
factor.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed in our summary of risk factors section on page 3 of the Registration Statement
the risks that our corporate structure and being based in or having the majority of the company’s operations in China poses to investors,
and has provided a cross-reference to the relevant individual detailed risk factor for each PRC-related summary risk factor.

    8.
    Disclose each permission or approval that you and/or your subsidiaries are required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors. State whether you and/or your subsidiaries are covered by permissions requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC), and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors if you and/or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on page 7 of the Registration Statement that as advised by our PRC counsel,
we are not required to obtain any permissions or approvals from PRC authorities, including the CSRC or the CAC, and that the Company has
described the consequences to us and our investors if we: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you
are required to obtain such permissions or approvals in the future.

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    9.
    Provide a clear description of how cash is transferred through your organization. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, and direction of transfer. Quantify any dividends or distributions that a subsidiary has made to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure should make clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on Cash Flows through Our Organization on page 2 of the Registration Statement
that the Company does not have any subsidiary, that there is no cash transfer through our organization, and that none of transfers, dividends,
or distributions have been made to date from the Company to investors. The Company has also disclosed that there are no restrictions or
limitations on our ability to distribute earnings from the Company to U.S. investors.

    10.
    We note that you do not appear to have relied upon an opinion of counsel with respect to your conclusions that you do not need any permissions and approvals from PRC governmental agencies to operate your business and to offer securities to investors. If true, state as much and explain why such an opinion was not obtained.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has disclosed on page 7 of the Registration Statement that our conclusion that we do not
need any permissions and approvals from PRC governmental agencies to operate our business and to offer securities to investors is based
on the opinion of our PRC counsel. The Company has also filed the opinion of our PRC counsel as Exhibit
8.1.

Risk Relating to Doing Business in Hong Kong

All our operations are in Hong Kong. However, due to the long
arm provisions under the current PRC laws..., page 9

    11.

    Please revise the last paragraph of this risk factor to state
specifically that given recent statements by the Chinese government indicating an intent to exert more oversight and control over offerings
that are conducted overseas and/or foreign investment in China-based issuers, acknowledge the risk that any such action could significantly
limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities
to significantly decline or be worthless.

Response: In response to the Staff’s comment, the
Company advises the Staff that the Company has revised the last paragraph of this risk factor on page 16 of the Registration Statement
to state specifically that given recent statements by the Chinese government indicating an intent to exert more oversight and control
over offerings that are conducted overseas and/or foreign investment in China-based issuers, any such action could significantly limit
or completely hinder our ability to offer or continue to offer securities to investors and cause the value of such securities to significantly
decline or be worthless.

    12.

    Please revise your disclosure to state whether