SecProbe.io

CORRESP
 1
 filename1.htm

 AGAPE
ATP CORPORATION

 1705
 – 1708, Level 17, Tower 2, Faber Towers, Jalan Desa Bahagia,

 Taman
Desa, Kuala Lumpur, Malaysia 58100

 April
17, 2025

 Via
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Industrial Applications and Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Ms. Jane Park

 Re:
 Agape ATP Corporation

 Registration Statement on Form S-1, as amended

 File No. 333-286470

 Request for Acceleration of Effective Date

 Dear
Ms. Park:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant (the " Registrant ")
hereby requests that the U.S. Securities and Exchange Commission (the " Commission ") take appropriate action
to cause the Registration Statement on Form S-1, as amended (File No. 333-286470) (the " Registration Statement ")
to become effective on Tuesday, April 21, 2025, at 4:00 p.m., Eastern Time, or as soon as practicable thereafter, or at such later time
as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes Huan Lou of
Sichenzia Ross Ference Carmel LLP, counsel to the Registrant, to make such request on its behalf.

 Once
the Registration Statement has been declared effective, please orally confirm that event with Huan Lou of Sichenzia Ross Ference Carmel
LLP, counsel to the Registrant, at (646) 810-2187.

 Very
truly yours,

 AGAPE ATP CORPORATION

 By:

 /s/ How Kok Choong

 Name:
 How Kok Choong

 Title:

 Chief Executive Officer

 cc:
 Huan Lou, Sichenzia Ross Ference Carmel LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 15, 2025

How Kok Choong
Chief Executive Officer
Agape ATP Corporation
1705-1708, Level 17, Tower 2, Faber Towers, Jalan Desa Bahagia
Taman Desa, Kuala Lumpur, Malaysia 58100

 Re: Agape ATP Corporation
 Registration Statement on Form S-1
 Filed April 11, 2025
 File No. 333-286470
Dear How Kok Choong:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Jane Park at 202-551-7439 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Huan Lou, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

VIA
EDGAR

September
28, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

Attn:
Laura Crotty

    Re:
    AGAPE
    ATP CORPORATION

    File
    No. 333 – 239951

    Registration
    Statement on Form S-1, as amended

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), Network 1 Financial Securities, Inc, acting as representative of the underwriters, hereby
joins AGAPE ATP CORPORATION in requesting acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective on September 29, 2023, at 4:30 p.m. Eastern Time, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated
September 7, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

The
undersigned confirm that it has complied and will continue to comply with, and it has been informed or will be informed by participating
dealers that it has complied or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection
with the above-referenced issue.

Very
truly yours,

    Network
    1 Financial Securities, Inc.

    By:
    /s/
    Adam Pasholk

    Name:
    Adam
    Pasholk

    Title:
    Managing
    Director Investment Banking

CORRESP
1
filename1.htm

AGAPE
ATP CORPORATION

VIA
EDGAR

September
28, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

Attn:
Laura Crotty

    Re:
    AGAPE
    ATP CORPORATION

    Registration
    Statement on Form S-1

    File
    No. 333-239951

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Agape ATP Corporation hereby requests acceleration of effectiveness of the
above referenced Registration Statement so that it will become effective at 4:30 p.m. ET on September 29, 2023, or as soon as thereafter
practicable.

    Very
    truly yours,

    /s/
    How Kok Choong

    How
    Kok Choong

    Chief
    Executive Officer and Director

    cc:
    Loeb
    & Loeb LLP

    Hunter
    Taubman Fischer & Li LLC

CORRESP
1
filename1.htm

Agape
ATP Corporation

VIA
EDGAR

September
19, 2023

U.S.
Securities & Exchange Commission

Division
of Corporation Finance

Office
of Finance

Washington,
D.C. 20549

Attn:
Conlon Danberg, Laura Crotty

    Re:
    Agape
    ATP Corporation

    Registration
    Statement on Form S-1

    Filed
    July 20, 2020, as amended

    File
    No. 333-239951

Ladies
and Gentlemen:

On
September 15, 2023, Agape ATP Corporation requested acceleration of the effective date of the above referenced Registration Statement
so that it would become effective at 4:00 p.m. ET on September 19, 2023, or as soon as thereafter practicable. We hereby withdraw our
request for acceleration of effectiveness.

    Very
    truly yours,

    /s/
    How Kok Choong

    How
                                            Kok Choong

    Director,
    Chairman of the Board of Directors, Chief Executive Officer, Chief Operating Officer and Secretary (Principal Executive Officer)

    cc:
    Loeb
                                            & Loeb LLP

    Hunter
    Taubman Fischer & Li LLC

CORRESP
1
filename1.htm

VIA
EDGAR

September
19, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

Attn:
Conlon Danberg, Laura Crotty

    Re:
    AGAPE
    ATP CORPORATION

    File
    No. 333-239951

    Registration
    Statement on Form S-1, as amended

Ladies
and Gentlemen:

On
September 15, 2023, we, as the representative of the underwriters, filed a letter with the U.S. Securities and Exchange Commission via
EDGAR requesting, pursuant to Rule 461 under the Securities Act of 1933, as amended, the acceleration of the effective date of the above-referenced
Registration Statement so that it may be declared effective on September 19, 2023, at 4:00 p.m. Eastern Time, or as soon thereafter as
practicable. We are no longer requesting that such Registration Statement be declared effective at this specific date and time and we
hereby formally withdraw such request for acceleration.

Very
truly yours,

Network
1 Financial Securities, Inc.

    By:
    /s/
    Adam Pasholk

    Name:

    Adam
    Pasholk

    Title:

    Managing
    Director Investment Banking

CORRESP
1
filename1.htm

Agape
ATP Corporation

VIA
EDGAR

September
15, 2023

U.S.
Securities & Exchange Commission

Division
of Corporation Finance

Office
of Finance

Washington,
D.C. 20549

Attn:
Conlon Danberg, Laura Crotty

    Re:
    Agape
    ATP Corporation

    Registration
    Statement on Form S-1

    Filed
    July 20, 2020, as amended

    File
    No. 333-239951

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Agape ATP Corporation hereby requests acceleration of effectiveness of the
above referenced Registration Statement so that it will become effective at 4:00 p.m. ET on September 19, 2023, or as soon
as thereafter practicable.

    Very
    truly yours,

    /s/
    How Kok Choong

    How
                                            Kok Choong

    Director,
    Chairman of the Board of Directors, Chief Executive Officer, Chief Operating Officer and Secretary (Principal Executive Officer)

    cc:
    Loeb
    & Loeb LLP

    Hunter
    Taubman Fischer & Li LLC

CORRESP
1
filename1.htm

VIA
EDGAR

September
15, 2023

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, NE

Washington,
D.C. 20549

Attn:
Laura Crotty

    Re:
    AGAPE
    ATP CORPORATION

    File
    No. 333 – 239951

    Registration
    Statement on Form S-1, as amended

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), Network 1 Financial Securities, Inc, acting as representative of the underwriters, hereby
joins AGAPE ATP CORPORATION in requesting acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective on September 19, 2023, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated
September 7, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary
Prospectus.

The
undersigned confirm that it has complied and will continue to comply with, and it has been informed or will be informed by participating
dealers that it has complied or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection
with the above-referenced issue.

Very
truly yours,

    Network
    1 Financial Securities, Inc.

    By:
    /s/
    Adam Pasholk

    Name:

    Adam
    Pasholk

    Title:
    Managing
Director Investment Banking

United States securities and exchange commission logo
August 8, 2022
How Kok Choong
Chief Executive Officer
Agape ATP Corporation
1705-1708 Level 17, Tower 2, Faber Towers
Jalan Desa Bahagia, Taman Desa
58100 Kuala Lumpur, Malaysia
Re:Agape ATP Corporation
Form 10-K for fiscal year ended December 31, 2021
Filed March 28, 2022
File No. 333-220144
Dear Dr. Choong:
            We have completed our review of your filing. 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.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
1
filename1.htm

July
5, 2022

    Via
                                            Edgar Transmission

    Ms.
    Ibolya Ignat

    Securities
    and Exchange Commission

    Division
    of Corporation Finance

    Office
    of Life Sciences

    Washington,
    D.C. 20549

    Re:
    Agape
                                            ATP Corp (the “Company”)

    Form
    10-K for fiscal year ended December 31, 2021

    Filed
    March 28, 2022

    File
    No. 333-220144

Dear
Ms. Ignat:

As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated June 29, 2022 from the Securities
and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented
on the above-referenced Form 10-K for fiscal year ended December 31, 2021 (the “Form 10-K”).

For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.

Form
10-K/A for fiscal year ended December 31, 2021

    Item
                                            9A. Controls and Procedures, page 39

    1.
    We
    acknowledge the changes made in Item 9A of your amended Form 10-K and Item 4 of your amended Form 10-Q. However, these amended
    filings only address internal control over financial reporting and continue to omit your assessment and effectiveness conclusions
    for disclosure controls and procedures, as required by Item 307 of Regulation S-K. Accordingly, as originally requested, please
    amend your Form 10-K to include all of the information required by Item 307 of Regulation S-K and confirm that you will also provide
    this information in future Form 10-Q filings.

Response:
We respectfully advise the Staff that we have revised Item 9A of the Form 10-K/A to include our assessment and effectiveness conclusions
for disclosure controls and procedures. In additional, we have also updated Item 4 of the Form 10-Q/A for the nine months
ended September 30, 2021 to include our assessment and effectiveness conclusions for disclosure controls and procedures. We confirm
that we will also provide this information in future Form 10-Q filings.

*
* *

Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick

    Direct
    Dial: +852.3923.1188

    Email:
    lvenick@loeb.com

EXHIBIT
A

Agape
ATP Corporation

1705-1708,
Level 17, Tower 2, Faber Towers

Jalan
Desa Bahagia, Taman Desa

Kuala Lumpur, Malaysia

(Postal
Code: 58100)

+(60)
192230099

July
5, 2022

In
connection with its response to the United States Securities and Exchange Commission’s comment letter, dated June 29, 2022, Agape
ATP Corporation (the “Company”) acknowledges the following:

    ●
    the
    Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff
    comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect
    to the filing; and

    ●
    the
    Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

    AGAPE
    ATP CORPORATION

    By:
    /s/
    How Kok Choong

    How
    Kok Choong

    Chief
                                            Executive Officer,

    Chief
    Operating Officer, Director, Chairman of the Board of Directors and Secretary

    (Principal
    Executive Officer)

United States securities and exchange commission logo
June 29, 2022
How Kok Choong
Chief Executive Officer
Agape ATP Corporation
1705-1708 Level 17, Tower 2, Faber Towers
Jalan Desa Bahagia, Taman Desa
58100 Kuala Lumpur, Malaysia
Re:Agape ATP Corporation
Form 10-K for fiscal year ended December 31, 2021
Filed March 28, 2022
File No. 333-220144
Dear Dr. Choong:
            We have reviewed your May 18, 2022 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to the comment, we may have additional comments.
Form 10-K/A for fiscal year ended December 31, 2021
Item 9A. Controls and Procedures, page 39
1.We acknowledge the changes made in Item 9A of your amended Form 10-K and Item 4 of
your amended Form 10-Q. However, these amended filings only address internal control
over financial reporting and continue to omit your assessment and effectiveness
conclusions for disclosure controls and procedures, as required by Item 307 of Regulation
S-K. Accordingly, as originally requested, please amend your Form 10-K to include all of
the information required by Item 307 of Regulation S-K and confirm that you will also
provide this information in future Form 10-Q filings.

 FirstName LastNameHow Kok Choong
 Comapany NameAgape ATP Corporation
 June 29, 2022 Page 2
 FirstName LastName
How Kok Choong
Agape ATP Corporation
June 29, 2022
Page 2
            You may contact Frank Wyman at 202-551-3660 or Ibolya Ignat at 202-551-3636, if you
have questions regarding the comment.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
1
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May
18, 2022

    Via
                                            Edgar Transmission

    Ms.
    Ibolya Ignat

    Securities
    and Exchange Commission

    Division
    of Corporation Finance

    Office
    of Life Sciences

    Washington,
    D.C. 20549

    Re:
    Agape
                                            ATP Corp (the “Company”)

    Form
    10-K for fiscal year ended December 31, 2021

    Filed
    March 28, 2022

    File
    No. 333-220144

Dear
Ms. Ignat:

As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated May 12, 2022 from the Securities
and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented
on the above-referenced Form 10-K for fiscal year ended December 31, 2021 (the “Form 10-K”).

For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.

Form
10-K for fiscal year ended December 31, 2021

    Item
                                            9A. Controls and Procedures, page 39

    1.
    The
    Item 9A presentation in your Form 10-K for the fiscal year ended December 31, 2021 excluded an assessment and effectiveness conclusion,
    regarding disclosure controls and procedures. Please amend your Form 10-K to include all of the information required by Item 307
    of Regulation S-K. In amending your filing, please also identify the version of the COSO Framework you used in your evaluation of
    the Company’s internal control over financial reporting. In addition, the Item 4 presentation in your Form 10-Q for the nine
    months ended September 30, 2021 also excluded the Item 307 assessment and effectiveness conclusion. Confirm that your future Form
    10-Q filings will include all of the information required by Item 307 and Item 308 of Regulation S-K.

    Response:
                                            We respectfully advise the Staff that we have revised Item 9A of the Form 10-K/A
                                            to include the Item 307 of Regulation S-K assessment and effectiveness conclusion
                                            and the COSO Framework (2013) version used. In addition, we have also revised Item
                                            4 of the Form 10-Q/A for the nine months ended September 30, 2021 to include the Item 307
                                            assessment and effectiveness conclusion.

*
* *

Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick

    Direct
    Dial: +852.3923.1188

    Email:
    lvenick@loeb.com

EXHIBIT
A

Agape
ATP Corporation

1705-1708,
Level 17, Tower 2, Faber Towers

Jalan
Desa Bahagia, Taman Desa

Kuala Lumpur, Malaysia

(Postal
Code: 58100)

+(60)
192230099

May
18, 2022

In
connection with its response to the United States Securities and Exchange Commission’s comment letter, dated May 12, 2022, Agape
ATP Corporation (the “Company”) acknowledges the following:

    ●
    the
    Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff
    comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect
    to the filing; and

    ●
    the
    Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

    AGAPE
    ATP CORPORATION

    By:
    /s/
    How Kok Choong

    How
    Kok Choong

    Chief
                                            Executive Officer,

    Chief
    Operating Officer, Director, Chairman of the Board of Directors and Secretary

    (Principal
    Executive Officer)

United States securities and exchange commission logo
May 12, 2022
How Kok Choong
Chief Executive Officer
Agape ATP Corporation
1705-1708 Level 17, Tower 2, Faber Towers
Jalan Desa Bahagia, Taman Desa
58100 Kuala Lumpur, Malaysia
Re:Agape ATP Corporation
Form 10-K for fiscal year ended December 31, 2021
Filed March 28, 2022
File No. 333-220144
Dear Dr. Choong:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to the comment, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2021
Item 9A. Controls and Procedures, page 39
1.The Item 9A presentation in your Form 10-K for the fiscal year ended December 31, 2021
excluded an assessment and effectiveness conclusion, regarding disclosure controls and
procedures. Please amend your Form 10-K to include all of the information required by
Item 307 of Regulation S-K. In amending your filing, please also identify the version of
the COSO Framework you used in your evaluation of the Company's internal control over
financial reporting.  In addition, the Item 4 presentation in your Form 10-Q for the nine
months ended September 30, 2021 also excluded the Item 307 assessment and
effectiveness conclusion. Confirm that your future Form 10-Q filings will include all of
the information required by Item 307 and Item 308 of Regulation S-K.
            In closing, we remind you that the company and its management are responsible for the

 FirstName LastNameHow Kok Choong
 Comapany NameAgape ATP Corporation
 May 12, 2022 Page 2
 FirstName LastName
How Kok Choong
Agape ATP Corporation
May 12, 2022
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Frank Wyman at 202-551-3660 or Ibolya Ignat at 202-551-3636 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
1
filename1.htm

May
10, 2022

    Via
    Edgar Transmission

    Ms.
    Laura Crotty

    Securities
    and Exchange Commission

    Division
    of Corporation Finance

    Office
    of Life Sciences

    Washington,
    D.C. 20549

    Re:
    Agape
    ATP Corp (the “Company”)

    Amendment
    No. 2 to Registration Statement on Form S-1

    Filed
    April 12, 2022

    File
    No. 333-239951

Dear
Ms. Crotty:

As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated April 27, 2022 from the Securities
and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented
on the above-referenced Registration Statement on Form S-1 (the “Form S-1”).

For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.

Amendment
No. 2 to Registration Statement on Form S-1 filed April 12, 2022

    Resale
    Prospectus Cover Page, page SS-1

    1.
    Please note that Regulation S-K Item 501(b)(3) requires that you disclose the price at which the securities will be sold on the cover page of the prospectus. We also note that your common stock is quoted on the OTC Markets – Pink Sheets. The OTC Pink market is not an established public trading market into which a selling stockholder may offer and sell shares at other than a fixed price. In this regard, we also note your disclosure under the caption “Selling Stockholder Plan of Distribution” on page SS-26 of the resale prospectus that the selling stockholders may sell shares “on any stock exchange, market or trading facility on which shares of our common stock are traded or in private transactions” and “at fixed or negotiated prices.” Please revise your cover page disclosure, and make corresponding changes elsewhere in the prospectus, to disclose a price at which the selling stockholders will offer and sell shares, in compliance with Item 501(b)(3) of Regulation S-K, until your shares are listed on a national securities exchange or quoted on the OTC Bulletin Board, OTCQX, or OTCQB, at which time they may be sold at prevailing market prices.

    Response:
We respectfully advise the Staff that we have revised the cover page of the resale prospectus and the disclosure on SS-26, with
disclosures including that the selling stockholders will offer and sell their shares of common stock being offered under the prospectus
at $6.50 per share on the OTC Markets – Pink Sheets under the symbol “AATP” or in private transactions for the duration
of the offering or until the shares are listed on a national securities exchange at which time the selling stockholders and any of their pledgees, donees, assignees and successors-in-interest may, from time to time,
sell any or all of their shares of common stock being offered under the prospectus on any stock exchange, market or trading facility
on which shares of the common stock are traded or in private transactions.

                                                         In
                                            addition, we have made similar disclosure under the Risk Factor - The offering price of
                                            our shares of common stock offered in the Resale Prospectus Resale is fixed.

*
* *

Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick

    Direct
    Dial: +852.3923.1188

    Email:
    lvenick@loeb.com

EXHIBIT
A

Agape
ATP Corporation

1705-1708,
Level 17, Tower 2, Faber Towers

Jalan
Desa Bahagia, Taman Desa

Kuala Lumpur, Malaysia

(Postal
Code: 58100)

+(60)
192230099

May
10, 2022

In
connection with its response to the United States Securities and Exchange Commission’s comment letter, dated April 27, 2022, Agape
ATP Corporation (the “Company”) acknowledges the following:

    ●
    the
    Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff
    comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect
    to the filing; and

    ●
    the
    Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

    AGAPE
    ATP CORPORATION

    By:
    /s/
    How Kok Choong

    How
    Kok Choong

    Chief
    Executive Officer,

    Chief
    Operating Officer, Director, Chairman of the Board of Directors and Secretary

    (Principal
    Executive Officer)

United States securities and exchange commission logo
April 27, 2022
How Kok Choong
Chief Executive Officer
Agape ATP Corp
1705 – 1708, Level 17, Tower 2, Faber Towers, Jalan Desa Bahagia
Taman Desa, Kuala Lumpur, Malaysia (Postal Code: 58100)
Re:Agape ATP Corp
Amendment No. 2 to Registration Statement on Form S-1
Filed April 12, 2022
File No. 333-239951
Dear Mr. Choong:
            We have reviewed your amended registration statement and have the following
comment.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our 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 comment, we may have additional comments.
Amendment No. 2 to Registration Statement on Form S-1 filed April 12, 2022
Resale Prospectus Cover Page, page SS-1
1.Please note that Regulation S-K Item 501(b)(3) requires that you disclose the price at
which the securities will be sold on the cover page of the prospectus. We also note that
your common stock is quoted on the OTC Markets – Pink Sheets. The OTC Pink market
is not an established public trading market into which a selling stockholder may offer and
sell shares at other than a fixed price. In this regard, we also note your disclosure under
the caption "Selling Stockholder Plan of Distribution" on page SS-26 of the resale
prospectus that the selling stockholders may sell shares "on any stock exchange, market or
trading facility on which shares of our common stock are traded or in private transactions"
and "at fixed or negotiated prices." Please revise your cover page disclosure, and make
corresponding changes elsewhere in the prospectus, to disclose a price at which the selling
stockholders will offer and sell shares, in compliance with Item 501(b)(3) of Regulation

 FirstName LastNameHow Kok Choong
 Comapany NameAgape ATP Corp
 April 27, 2022 Page 2
 FirstName LastName
How Kok Choong
Agape ATP Corp
April 27, 2022
Page 2
S-K, until your shares are listed on a national securities exchange or quoted on the OTC
Bulletin Board, OTCQX, or OTCQB, at which time they may be sold at prevailing market
prices.
            Please contact Conlon Danberg at 202-551-4466 or Laura Crotty at 202-551-7614 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence Venick, Esq.

CORRESP
1
filename1.htm

April
12, 2022

    Via
                                            Edgar Transmission

    Ms.
    Laura Crotty

    Securities
    and Exchange Commission

    Division
    of Corporation Finance

    Office
    of Life Sciences

    Washington,
    D.C. 20549

    Re:
    Agape
                                            ATP Corp (the “Company”)

    Registration
    Statement on Form S-1

    Filed
    July 20, 2020

    File
    No. 333-239951

Dear
Ms. Crotty:

As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated August 3, 2020 from the Securities
and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented
on the above-referenced Registration Statement on Form S-1 (the “Form S-1”).

For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.

Form
S-1 filed July 20, 2020

    Cover
                                            Page

    1.
    Revise
                                            to complete your fee table in the next amendment.

    Response:
                                            We respectfully advise the Staff that we have attached the calculation of filing fee
                                            tables in exhibit 107.

    2.
    Please
    revise the cover page of the registration statement to include the number of shares of common stock to be offered. Refer to Item
    501(b)(2) of Regulation S-K and Securities Act Rules Compliance and Disclosure Interpretations Question 227.02. Additionally, please
    disclose the price of the securities, or the method by which the offering price will be determined, in accordance with Item 501(b)(3).

    Response:
                                            We respectfully advise the Staff that we have revised the cover page to reflect the number
                                            of shares offered and the price of the securities.

    Underwriting,
                                            page 103

    3.

    We
note your disclosure on page 103 that the Underwriting Agreement provides that the obligation of the underwriter to arrange for the offer
and sale of shares is on a best efforts basis. However, the cover page indicates that the offering is to be made on a firm commitment
basis. Please reconcile these statements and revise your disclosure accordingly. In the event the offering is to be on a best efforts
basis, please provide the disclosure required by Item 501(b)(8)(ii) and (iii) of Regulation S-K. In the event the offering is to be on
a firm commitment basis, name the underwriter in the next amendment.

    Response:
                                            We respectfully advise the Staff that we have removed the disclosure on
page 86 under the Underwriting section and reconciled the disclosure on the Cover Page and page 7 to disclose that the offering is to
be on a firm commitment basis. The underwriter has been named as Prime Number Capital, LLC on page 86.

*
* *

Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick

    Direct
    Dial: +852.3923.1188

    Email:
    lvenick@loeb.com

EXHIBIT
A

Agape
ATP Corporation

1705-1708,
Level 17, Tower 2, Faber Towers

Jalan
Desa Bahagia, Taman Desa

Kuala Lumpur, Malaysia

(Postal
Code: 58100)

+(60)
192230099

April
12, 2022

In
connection with its response to the United States Securities and Exchange Commission’s comment letter, dated August 3, 2020, Agape
ATP Corporation (the “Company”) acknowledges the following:

    ●
    the
    Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff
    comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect
    to the filing; and

    ●
    the
    Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

    AGAPE
    ATP CORPORATION

    By:
    /s/
    How Kok Choong

    How
    Kok Choong

    Chief
                                            Executive Officer,

    Chief
    Operating Officer, Director, Chairman of the Board of Directors and Secretary

    (Principal
    Executive Officer)

CORRESP
1
filename1.htm

October
6, 2021

    Re:
    Agape
    ATP Corp

    Registration
    Statement on Form S-1

    Filed
    July 20, 2020

    File
    No. 333-239951

Division
of Corporation Finance

Office
of Life Sciences Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Laura Crotty and Dorrie Yale

Dear
SEC Officers:

On
behalf of Agape ATP Corp (the “Company”), we have set forth below responses to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission contained in its letter dated August 3, 2020 with respect to the Registration Statement on
Form S-1, File No. 333-239951 (“S-1”), filed on July 20, 2020 by the Company. For your convenience, the text of the Staff’s
comments is set forth below in bold, followed in each case by the Company’s responses. Please note that all references to page
numbers in the responses are references to the page numbers in revised Form S-1 (the “Revised S-1”), filed concurrently with
the submission of this letter in response to the Staff’s comments.

Amendment
1 to Registration Statement on Form S-1 filed July 20, 2020

Cover
Page

1.
Revise to complete your fee table in the next amendment.

The
Company will provide the information supplementally.

2.
Please revise the cover page of the registration statement to include the number of shares of common stock to be offered. Refer to Item
501(b)(2) of Regulation S-K and Securities Act Rules Compliance and Disclosure Interpretations Question 227.02. Additionally, please
disclose the price of the securities, or the method by which the offering price will be determined, in accordance with Item 501(b)(3).

The
Company will provide the information supplementally.

Underwriting,
page 103

3.
We note your disclosure on page 103 that the Underwriting Agreement provides that the obligation of the underwriter to arrange for the
offer and sale of shares is on a best efforts basis. However, the cover page indicates that the offering is to be made on a firm commitment
basis. Please reconcile these statements and revise your disclosure accordingly. In the event the offering is to be on a best efforts
basis, please provide the disclosure required by Item 501(b)(8)(ii) and (iii) of Regulation S-K. In the event the offering
is to be on a firm commitment basis, name the underwriter in the next amendment.

In
response to the Staff’s comment, the Company has revised the disclosures in the “Underwriting” section of the Revised
S-1.

Should
you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188.

    Very
    truly yours,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick

ACKNOWLEDGEMENT

In
response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
contained in its letter dated August 3, 2020 with respect to the Registration Statement on Form S-1 filed July 20, 2020, File No. 333-239951,
by the Company, the undersigned hereby acknowledges that in connection with the revised Form S-1 filed concurrently with the submission
of this response, as well as any subsequent amendment thereto filed with the Commission:

    ●
    the
    filing person is responsible for the adequacy and accuracy of the disclosure in the filings;

    ●
    Staff
    comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect
    to the filings; and

    ●
    the
    filing person may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

    Agape ATP Corp

    By:
    /s/
    How Kok Choong

    Name:
    How
    Kok Choong

    Title:
    Chief
    Executive Officer

United States securities and exchange commission logo
September 1, 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
How Kok Choong
Chief Executive Officer
Agape ATP Corp
1705 – 1708, Level 17, Tower 2, Faber Towers, Jalan Desa Bahagia
Taman Desa, Kuala Lumpur, Malaysia (Postal Code: 58100)
Re:Agape ATP Corp
Registration Statement on Form S-1
Filed July 20, 2020
File No. 333-239951
Dear Mr. Choong:
            It has been more than nine months since you filed this registration statement and it is now
out of date.  Within 30 days from the date of this letter, you should either:
•amend it to comply with the applicable requirements of the Securities Act of 1933, the rules
and regulations under the Act, and the requirements of the form; or
•file a request for withdrawal.
             If you requested confidential treatment for portions of any exhibits to your registration
statement and you request withdrawal of that registration statement, please submit a concurrent
request for withdrawal of your application for confidential treatment.
            If you do not amend the registration statement or file a request for withdrawal (or provide
us with a satisfactory explanation of why you have not done either) within 30 days, we may enter
an order declaring the registration statement abandoned under rule 479 of the Act.
            Please contact Laura Crotty at 202-551-7614 with any questions.
Sincerely,
Division of Corporation Finance

 FirstName LastNameHow Kok Choong
 Comapany NameAgape ATP Corp
 September 1, 2021 Page 2
 FirstName LastName
How Kok Choong
Agape ATP Corp
September 1, 2021
Page 2
Office of Life Sciences

United States securities and exchange commission logo
August 3, 2020
How Kok Choong
Chief Executive Officer
Agape ATP Corp
1705 – 1708, Level 17, Tower 2, Faber Towers, Jalan Desa Bahagia
Taman Desa, Kuala Lumpur, Malaysia (Postal Code: 58100)
Re:Agape ATP Corp
Registration Statement on Form S-1
Filed July 20, 2020
File No. 333-239951
Dear Mr. Choong:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Form S-1 filed July 20, 2020
Cover Page
1.Revise to complete your fee table in the next amendment.
2.Please revise the cover page of the registration statement to include the number of shares
of common stock to be offered. Refer to Item 501(b)(2) of Regulation S-K and Securities
Act Rules Compliance and Disclosure Interpretations Question 227.02.  Additionally,
please disclose the price of the securities, or the method by which the offering price will
be determined, in accordance with Item 501(b)(3).
Underwriting, page 103
3.We note your disclosure on page 103 that the Underwriting Agreement provides that the

 FirstName LastNameHow Kok Choong
 Comapany NameAgape ATP Corp
 August 3, 2020 Page 2
 FirstName LastName
How Kok Choong
Agape ATP Corp
August 3, 2020
Page 2
obligation of the underwriter to arrange for the offer and sale of shares is on a best efforts
basis. However, the cover page indicates that the offering is to be made on a firm
commitment basis. Please reconcile these statements and revise your disclosure
accordingly. In the event the offering is to be on a best efforts basis, please provide the
disclosure required by Item 501(b)(8)(ii) and (iii) of Regulation S-K. In the event the
offering is to be on a firm commitment basis, name the underwriter in the next
amendment.
            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 Laura Crotty at (202) 551-7614 or Dorrie Yale at (202) 551-8776 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence Venick

CORRESP
1
filename1.htm

November 7, 2017

VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

Division of Corporations Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Agape ATP Corporation

Form S-1/A

Filed October 26, 2017

File No. 333-220144

To the men and women of the SEC:

Acceleration Request:

We, Agape ATP Corporation,
(the “Registrant”) hereby requests that the Securities and Exchange Commission take appropriate action to declare
the above captioned Registration Statement effective at the requested date of November 9, 2017 at  4 PM Eastern
Standard Time or as soon as practicable thereafter.

In connection with this request, the Company
acknowledges that:

-Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it
does not foreclose the Commission from taking any action with respect to the filing;

-The action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

-The Company may not assert staff comments and the declaration
of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

Date: November 7, 2017

/s/ How Kok Choong

How Kok Choong

Chief Executive Officer

Mail Stop 3561

October 24, 2017

Via E -mail
How Kok Choong
Chief Executive Officer
Agape ATP Corporation
No. 17, 17 -1, 17 -2, 17 -3, Wisma Laxton, Jalan Desa, Taman Desa,
Off Jalan Klang Lama, 58100 Kuala Lumpur, Malaysia

Re: Agape ATP Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed October 12 , 2017
  File No. 333-220144

Dear Mr. How :

We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.  If you  do not believe our comments apply 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 respon se to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our September 20, 2017 letter.

Certain Relationships and Related Transactions, page 26

1. We note your response to comment 13.  As previously requested, please state the names
of your promoters and provide all information required by Item 404(c) of Regulation S -
K.

You may contact James Giugliano  at (202) 551 -3319 or Nasreen Mohammed  at (202)
551-3773 if you have questions reg arding comments on the financial statements and related
matters.  Please contact  Hillary Daniels  at (202) 551 -3959 or Brigitte Lippmann  at (202) 551 -
3713  with any other questions.

How Kok Choong
Agape ATP Corporation
October 24, 2017
Page 2

 Sincerely,

 /s/ Brigitte Lippmann (for)

 John Reynolds
 Assistant Director
Office of Beverages, Apparel, and
Mining

cc:  Jeffrey DeNunzio, President
       V Financial Group, LLC

Mail Stop 3561

September 20, 2017

Via E -mail
How Kok Choong
Chief Executive Officer
Agape ATP Corporation
No. 17, 17 -1, 17 -2, 17 -3, Wisma Laxton, Jalan Desa, Taman Desa,
Off Jalan Klang Lama, 58100 Kuala Lumpur, Malaysi a

Re: Agape ATP Corporation
Registration Statement on Form S-1
Filed August 24, 2017
  File No. 333-220144

Dear Mr. How:

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to prov ide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances o r 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 these  comments, we may have  additional comments.

General

1. Please revise to include the dealer prospectus delivery obligation on the outside back
cover page of the prospectus.  See Item 502(b) of Regulation S -K.

Prospectus Summary, page 2

2. We note your statement  that Mr. How will be selling share s of common stock on behalf
of the company  and simultaneously selling his p ersonal shares of common stock.  Please
indicate what factors the company  anticipate s considering in determining whether Mr.
How sells the company’s share s of common stock or sells his own shares  of common

How Kok Choong
Agape ATP Corporation
September 20, 2017
Page 2

 stock .  Additionally, add a risk factor address ing the risks to investors f rom Mr. How ’s
selling shares for his own account and also selling shares on the company ’s behalf.

Risk Factors, page 5

3. Please include risk factor disclo sure addressing the risks of reselling third -party products.

Description of Business, page 15

4. We note your website, www.agapeatp.com , contains details that appear material to
investors in your o ffering.  It also appears that the  information on your website deviates
substantially from the disclosure contained in your prospectus.  For example, the content
on your website suggests that you have a “ medical research  team” in place ,  a
profes sional marketing team, medical  advisors and that you plan to employ multi -level
marketing for the sale of the products that make up  your ATP Zeta Super Health
Program.  Please revise your prospectus to provide the material information or advise us
as appropriate.

5. Please revise to address the s ources and availability of  the nine products that are part of
your ATP Zeta Super Health Program.

6. Please revise to address the c ompetitive business conditions , the company's competitive
position in the industry  along with the methods of competition .

7. Please provide disclosure regarding  any potential governmental regulation related to your
plan to market and sell  health advisory services based on the nine  products in your ATP
Zeta Super Health Program .  See Item 101(h)(4)(ix) of Regulation S -K.

Use of Proceeds, page 17

8. We note risk factor disclosure on page 12 regarding the company’s broad disc retion in
the allocation of the net proceeds of this offering.  We also note your statement that
“funds may be allocated in differing quantities should the Company decide at a later date
it would be in the Company’s best interests.”  The company may reserv e the right to
change the use of proceeds, provided that such reservation is due to certain contingencies
that are discussed specifically and the alternatives to such use in that event are indicated.
See Instruction 7 to Item 504 of Regulation S -K.  Pleas e revise your disclosure
accordingly.

Dilution, page 18

9. Please revise this section to provide a comparison of the public contribution by investors in
the public offering and the effective ca sh contribution of existing stockholders.   Also include
the percentage of securities held by investors in the public offering and the percentage of
securities held by the existing stockholders.   See Item 506 of Regulation S -K.

How Kok Choong
Agape ATP Corporation
September 20, 2017
Page 3

Plan of Distribution, page 20

10. We note your statement that “the Company’s shares may be sold to purchasers from time
to time directly by and subject to the discretion of the Company.”  Please tell us how you
comply  with Rule 415(a)(ix) of Regulation C or revise as appropriate.

Security Ownership of Certain Beneficial Owners and Management, page 26

11. We note your footnote  to the beneficial ownership table  indicates that HKC Holdings
Sdn. Bhd. is owned and controlled by Mr. How .  It appears that Mr. How controls the
voting and dispositive power over the shares held by HKC Holdings Sdn. Bhd.
Accordingly, it appears that these shares should be included in Mr. How 's beneficial
ownership calculation.  Please revise or advise.  See Item 40 3 of Regulation S -K and
Exchange Act Rule  13d-3.

Certain Relationships and Related Transactions, page 26

12. Please revise disclosure in this section to clearly identify the basis on which the named
person is a related party.  See Item 404(a)(1) of Regulat ion S -K.  Also file as an exhibit
any material contract with any of the directors, officers, promoters, and/or shareholders
named in the filing.

13. Please provide the information  required by Item 404(c) of Regulation S -K.

14. It appears that a number of the noted transactions do not appear to be related party
transactions.  Please revise to only address related party transactions in th is section.

15. Please revise to identify the director of the company who advanced $100 and $25,000 to
the company.

16. We note your statement that the company incurred incorporation fees of $2,200 and
professional fees of $90,000 during the year ended June 30, 2017 and period ended June
30, 2016.  Please provide the information requir ed by Item 404 of Regulation S -K for
these transactions or advise as appropriate.

Par II

Other Expenses of Issuance and Distribution, page 27

17. Please revise to indicate the portion of such expenses to be bo rne by the selling
shareholders.

How Kok Choong
Agape ATP Corporation
September 20, 2017
Page 4

 Recent Sales of Unregistered Securities, page 28

18. Please briefly  state the facts  relied  upon  to make the Section 4(a)(2) exemption available.

Undertakings, page 29

19. Please p rovide the exact undertaking required by Item 512(a)(6)(i) of Regulation S -K.

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 effect ive date of the registration
statement.

You may contact James Giugliano  at (202) 551 -3319 or Nasreen Mohammed  at (202)
551-3773 if you have questions regarding comments on the financial statements and related
matters.  Please contact  Hillary Daniels  at (202) 551 -3959 or David Link  at (202) 551 -3356  with
any other questions.

Sincerely,

 /s/ David Link for

 John Reynolds
 Assistant Director
Office of Beverages, Apparel, and
Mining

cc:  Jeffrey DeNunzio, President
        V Financial Group, LLC