SecProbe.io

CORRESP
 1
 filename1.htm

 Submission Proof - Z:\2023 OPERATIONS\2023 EDGAR\08 August\E I L HOLDINGS LIMITED\08-30-2023\Form DRSLTR\Draft\Production\E I L HOLDINGS LIMITED 08-30-2023 Form DRSLTR.gfp

 May 23, 2025

 Division of Corporate Finance,
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Dear SEC Officers,

 Re:
 Bluemount Holdings Limited

 Submission of Amended DRS Following Share Surrender

 Filed May 23, 2025

 File No. 333-285843

 On behalf of Bluemount Holdings Limited (the “Company”), we hereby submit the amended Draft Registration Statement (DRS) for your review. This amendment reflects the recent surrender of an aggregate of 11,505,152 Class A Ordinary Shares and 12,500,001 Class B Ordinary Shares, which were accepted by the Company for no consideration and subsequently cancelled upon surrender.

 The surrender was primarily driven by valuation considerations, ensuring that the Company maintains a sound capital structure and optimizes shareholder value in alignment with market conditions. In light of this, we have incorporated the relevant updates to the shareholdings and F-pages within the amended DRS, ensuring full transparency and accuracy of the filing.

 Given that the audits will become stale on June 30, 2025, the Company sincerely hopes to receive a "no further comments" confirmation from the SEC and Nasdaq in a timely manner. This will allow our underwriter to proceed with book-building at the earliest opportunity and, ideally, close the project by June 30, 2025.

 Your prompt attention to this matter would be greatly appreciated. Please do not hesitate to reach out if any further clarifications or additional information are required.

 Thank you for your time and consideration.

 Very truly yours,

 /s/ Lawrence S. Venick

 Lawrence S. Venick

CORRESP
 1
 filename1.htm

 Submission Proof - Z:\2023 OPERATIONS\2023 EDGAR\08 August\E I L HOLDINGS LIMITED\08-30-2023\Form DRSLTR\Draft\Production\E I L HOLDINGS LIMITED 08-30-2023 Form DRSLTR.gfp

 May 9, 2025

 Division of Corporation Finance
 Office of Finance
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Dear SEC Officers:

 Re:
 Bluemount Holdings Limited

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

 Filed April 24, 2025

 File No. 333-285843

 On behalf of Bluemount Holdings Limited (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 May 7, 2025 with respect to the Amendment No. 2 to Registration Statement on Form F-1 (File No. 333-285843), filed on April 24, 2025 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.

 Amendment No. 2 to Registration Statement on Form F-1
 Application for Nasdaq Listing, page 197

 1. Based on the disclosure in your financial statements, it appears that your total stockholders' equity was approximately $3.6 million as of December 31, 2024. Please tell us how you plan to comply with Nasdaq Listing Rule 5505(b)(3)(B) that requires companies listing on the Nasdaq Capital Market to have stockholders' equity of at least $4 million. Finally, revise your disclosure here to provide an update on the status of your Nasdaq application.

 Response: The Company respectfully advises the Staff that as disclosed in the Company’s unaudited condensed consolidated statements of financial position included on page 52 of the Form F-1, the Company’s stockholders’ equity increased to HK$33.7 million (approximately US$4.3 million) as of September 30, 2024, therefore complying with Nasdaq Listing Rule 5505(b)(3)(B).

 The Company is working with Nasdaq to clear on-going comments raised by Nasdaq on the listing application. As of the date hereof, the Company’s listing application has not been approved by Nasdaq.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 7, 2025

Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong

 Re: Bluemount Holdings Limited
 Amendment No. 2 to Registration Statement on Form F-1
 Filed April 24, 2025
 File No. 333-285843
Dear Chan Wan Shan Sandra:

 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 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 April 22,
2025 letter.

Amendment No. 2 to Registration Statement on Form F-1
Application for Nasdaq Listing, page 197

1. Based on the disclosure in your financial statements, it appears that
your total
 stockholders' equity was approximately $3.6 million as of December 31,
2024. Please
 tell us how you plan to comply with Nasdaq Listing Rule 5505(b)(3)(B)
that requires
 companies listing on the Nasdaq Capital Market to have stockholders'
equity of at
 least $4 million. Finally, revise your disclosure here to provide an
update on the status
 of your Nasdaq application.
 May 7, 2025
Page 2

 Please contact Michael Henderson at 202-551-3364 or Michael Volley at
202-551-
3437 if you have questions regarding comments on the financial statements and
related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at
202-551-
3601 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Finance
cc: Lawrence Venick, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Submission Proof - Z:\2023 OPERATIONS\2023 EDGAR\08 August\E I L HOLDINGS LIMITED\08-30-2023\Form DRSLTR\Draft\Production\E I L HOLDINGS LIMITED 08-30-2023 Form DRSLTR.gfp

 April 24, 2025

 Division of Corporation Finance
 Office of Finance
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Dear SEC Officers:

 Re:
 Bluemount Holdings Limited

 Amendment No. 1 to Registration Statement on Form F-1

 Filed April 9, 2025

 File No. 333-285843

 On behalf of Bluemount Holdings Limited (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 April 22, 2025 with respect to the Amendment No. 1 to Registration Statement on Form F-1 (File No. 333-285843), filed on April 9, 2025 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 the revised Form F-1 (the “Revised F-1”), filed concurrently with the submission of this letter in response to the Staff’s comments.

 Amendment No. 1 to Registration Statement on Form F-1
 Impairment loss on trade and other receivables, page 89

 1. Please refer to prior comment 3. Please revise to quantify the recovery of certain trade receivables that had been impaired in prior years. Additionally, to the extent that the recovery was not significant, please revise to provide additional detail regarding the key facts and circumstances from your reassessment of the expected credit loss that resulted in the material reversal of the impairment loss on trade and other receivables.

 Response: In response to the Staff’s comment, the Company has revised pages 89-90 of the Revised F-1.

 General

 2. Please revise your filing to include March 31, 2025 audited financial statements required by Item 8.A.4 of Form 20-F. Alternately, please file a representation as an exhibit to your filing that states that you are not required to comply with the 12-month requirement of audited financial statements in any other jurisdiction outside the United States and that complying with the 12-month requirement is impracticable or involves undue hardship. Refer to Instruction 2 of Item 8.A.4 of Form 20-F.

 Response: We advise the Staff that the Item 8.A.4 representation is being filed as exhibit 99.10.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 22, 2025

Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong

 Re: Bluemount Holdings Limited
 Amendment No. 1 to Registration Statement on Form F-1
 Filed April 9, 2025
 File No. 333-285843
Dear Chan Wan Shan Sandra:

 We have reviewed your amended registration statement and have the
following
comments.

 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 March 27,
2025 letter.

Amendment No. 1 to Registration Statement on Form F-1
Impairment loss on trade and other receivables, page 89

1. Please refer to prior comment 3. Please revise to quantify the recovery
of certain trade
 receivables that had been impaired in prior years. Additionally, to the
extent that the
 recovery was not significant, please revise to provide additional detail
regarding
 the key facts and circumstances from your reassessment of the expected
credit loss
 that resulted in the material reversal of the impairment loss on trade
and other
 receivables.
 April 22, 2025
Page 2
General

2. Please revise your filing to include March 31, 2025 audited financial
statements
 required by Item 8.A.4 of Form 20-F. Alternately, please file a
representation as an
 exhibit to your filing that states that you are not required to comply
with the 12-month
 requirement of audited financial statements in any other jurisdiction
outside the
 United States and that complying with the 12-month requirement is
impracticable or
 involves undue hardship. Refer to Instruction 2 of Item 8.A.4 of Form
20-F.

 Please contact Michael Henderson at 202-551-3364 or Michael Volley at
202-551-
3437 if you have questions regarding comments on the financial statements and
related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at
202-551-
3601 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Lawrence Venick, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Submission Proof - Z:\2023 OPERATIONS\2023 EDGAR\08 August\E I L HOLDINGS LIMITED\08-30-2023\Form DRSLTR\Draft\Production\E I L HOLDINGS LIMITED 08-30-2023 Form DRSLTR.gfp

 9 April, 2025

 Division of Corporation Finance
 Office of Finance
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Dear SEC Officers:

 Re:
 Bluemount Holdings Limited

 Registration Statement on Form F-1

 Filed March 17, 2025

 File No. 333-285843

 On behalf of Bluemount Holdings Limited (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 March 27, 2025 with respect to the Registration Statement on Form F-1 (File No. 333-285843), filed on March 17, 2025 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 the revised Form F-1 (the “Revised F-1”), filed concurrently with the submission of this letter in response to the Staff’s comments.

 Registration Statement on Form F-1
 General

 1. Please revise the presentation of your financial statements and other financial data presented in tabular form so that it reads consistently from left to right in the same chronological order throughout the filing. We note MD&A presents the current period first while your financial statements present the prior period first. Refer to SAB Topic 11:E for guidance.

 Response: In response to the Staff’s comment, the Company has amended the presentation of its financial statements and other financial data throughout the Revised F-1.

 Revenues
 Advisory service fee income, page 89

 2. Please expand your disclosure, similar to your disclosure for advisory service income for fiscal year end 2024 and 2023 on page 83, regarding the material increase in advisory service fee income and the upsurge in major projects undertaken during the latter half of the six months ended September 30, 2024. Please include relevant facts about the projects to inform investors about the quality of, and potential variability of this revenue source so that investors can ascertain the likelihood that past performance is indicative of future performance. Specifically, provide details about the number of projects each period, the nature of projects (e.g., ad hoc vs. recurring, etc.), the timeline of major projects including when they are expected to end, and any estimate of revenue that may be recognized in future periods.

 Response: In response to the Staff’s comment, the Company has revised pages 89 of the Revised F-1.

 Impairment loss on trade and other receivables, page 89

 3. Please revise your disclosures to discuss the key facts and circumstances that resulted in the reversal of the impairment loss on trade and other receivables for the current interim period.

 Response: In response to the Staff’s comment, the Company has revised pages 89 of the Revised F-1.

 Trading of timepieces, page 89

 4. Please revise to provide details on the number of timepieces sold in each period and any other factors that impacted the decrease in these revenues.

 Response: In response to the Staff’s comment, the Company has revised pages 89 of the Revised F-1.

 Major customers, page 99

 5. We note the revenue concentration within your customer base, including from Customer B, Customer C, Customer D, and Customer E. Please identify these customers. In addition, revise the second risk factor on page 29 accordingly. Further, if applicable, disclose the terms of any material agreements with these customers and file the agreements as exhibits. Refer to Item 601(b)(10) of Regulation S-K.

 Response: In response to the Staff’s comment, the Company has revised pages 29, 99 to 101
of the Revised F-1 to disclose the names of the customers.

 Additionally, the Company respectfully advises the Staff that it determined that its agreements with these four customers are not material agreements under Item 601(b)(10) of Regulation S-K because (1) the agreements were entered into in the ordinary course of the Company’s business and the forms of agreements constituting the entire customer relationship are ordinary course agreements for the Company and (2) the Company’s business and profitability are not substantially dependent on any of the agreements with these four customers, given that (i) the Company has not signed any long term contract with these customers, and (ii) the loss of any one customer will not materially and adversely affect the Company’s profitability in the long run because of the Company’s ability to attract new customers and to secure new projects from its existing customers, which flexibility is demonstrated by the fact that the Company’s diversified customer base and its proven strategies for acquiring new customers and expanding existing relationships.

 Item 601(b)(10)(ii) of Regulation S-K provides that if a contract ordinarily accompanies the kind of business conducted by the registrant and its subsidiaries, it will be deemed to have been made in the ordinary course of business and need not be filed unless it falls under one of four enumerated exceptions. The Company has reviewed its relationship with the four customers and, based on that review, believes that the agreements with these four customers are the type of arrangement that typically accompanies the kind of business conducted by the Company in the ordinary course. Therefore, the agreements with these four customers do not fall into any of the four enumerated exceptions for contracts entered into in the ordinary course of business.

 Signatures, page II-5

 6. Based on your disclosure on page 163 it appears that your board consists of five members but only two directors have signed the registration statement. Please revise to have the majority of the board of directors sign the registration statement or advise.

 Response: The Company respectfully advises the Staff that the other three directors have not been appointed to the board and will be appointed immediately after effectiveness of the registration statement.

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 27, 2025

Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong

 Re: Bluemount Holdings Limited
 Registration Statement on Form F-1
 Filed March 17, 2025
 File No. 333-285843
Dear Chan Wan Shan Sandra:

 We have reviewed your registration statement and have the following
comments.

 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
General

1. Please revise the presentation of your financial statements and other
financial data
 presented in tabular form so that it reads consistently from left to
right in the
 same chronological order throughout the filing. We note MD&A presents
the
 current period first while your financial statements present the prior
period first. Refer
 to SAB Topic 11:E for guidance.
Revenues
Advisory service fee income, page 89

2. Please expand your disclosure, similar to your disclosure for advisory
service income
 for fiscal year end 2024 and 2023 on page 83, regarding the material
increase in
 advisory service fee income and the upsurge in major projects undertaken
during the
 March 27, 2025
Page 2

 latter half of the six months ended September 30, 2024. Please include
relevant facts
 about the projects to inform investors about the quality of, and
potential variability of
 this revenue source so that investors can ascertain the likelihood that
past performance
 is indicative of future performance. Specifically, provide details about
the number of
 projects each period, the nature of projects (e.g., ad hoc vs.
recurring, etc.), the
 timeline of major projects including when they are expected to end, and
any estimate
 of revenue that may be recognized in future periods.
Impairment loss on trade and other receivables, page 89

3. Please revise your disclosures to discuss the key facts and
circumstances that resulted
 in the reversal of the impairment loss on trade and other receivables
for the current
 interim period.
Trading of timepieces, page 89

4. Please revise to provide details on the number of timepieces sold in
each period and
 any other factors that impacted the decrease in these revenues.
Major customers, page 99

5. We note the revenue concentration within your customer base, including
from
 Customer B, Customer C, Customer D, and Customer E. Please identify
these
 customers. In addition, revise the second risk factor on page 29
accordingly. Further,
 if applicable, disclose the terms of any material agreements with these
customers and
 file the agreements as exhibits. Refer to Item 601(b)(10) of Regulation
S-K.
Signatures, page II-5

6. Based on your disclosure on page 163 it appears that your board consists
of five
 members but only two directors have signed the registration statement.
Please revise
 to have the majority of the board of directors sign the registration
statement or advise.
 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.
 March 27, 2025
Page 3

 Please contact Michael Henderson at 202-551-3364 or Michael Volley at
202-551-
3437 if you have questions regarding comments on the financial statements and
related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at
202-551-
3601 with any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Finance
cc: Lawrence Venick, Esq.
</TEXT>
</DOCUMENT>

December 11, 2024
Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong
Re:Bluemount Holdings Limited
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted December 4, 2024
CIK No. 0002027815
Dear Chan Wan Shan Sandra:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our November 19, 2024 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Business
Overview, page 101
1.We note your response to comment 3. Please revise this subsection to describe how
you are compensated for each of the services provided, such as commissions, flat fees
or otherwise.

December 11, 2024
Page 2
Principal Shareholders, page 155
2.We note your response to comment 5. You disclose the percentage of total
outstanding shares holders of Class A shares will need to maintain to continue to
control the outcome of matters submitted to shareholders for approval. Please disclose
the percentage of outstanding  Class A shares  the holders of Class A ordinary shares
must keep to continue to control the outcome of matters submitted to shareholders for
approval, as opposed to the percentage of total outstanding shares.
            Please contact Michael Henderson at 202-551-3364 or Michael Volley at 202-551-
3437 if you have questions regarding comments on the financial statements and related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-
3601 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Lawrence Venick, Esq.

November 19, 2024
Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong
Re:Bluemount Holdings Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted November 5, 2024
CIK No. 0002027815
Dear Chan Wan Shan Sandra:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our September 30, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
General
1.We note your response to prior comment 2. We also note your reference to your
trading platform on page 29. Please revise your disclosure to further describe your
trading platform and the relevance to your business. In this regard, we note your
disclosure on page 107 that your client may place trading orders (i) by phone; or (ii)
onsite at your office premises by submitting an order ticket, which can be accessed by
mobile device application. If applicable here, describe the trading platform you
reference.

November 19, 2024
Page 2
Prospectus Summary
Overview, page 1
2.We note your response to prior comment 1 and reissue our comment. Please revise
this section to list separately the three types of services you appear to provide: 1)
consulting and advisory services, 2) commodity trading, and 3) financial services. List
them in the order of services that produce the most revenues for your company. In this
regard, we note your response to comment 9 where you stated that "underwriting and
placing services, securities brokerage and dealing services, and asset management
services segments differ from consulting and advisory services segment." You
continue, however, to describe all these types of services under financial services and
combine them together. In addition, given the differences in the total revenue derived
from consulting and advisory services (57.05% and 77.5% for the years ended March
31, 2024 and 2023) compared to the total revenue derived from your other financial
services, such as underwriting and placing services, securities dealing and brokerage
services, and asset management services (in the aggregate, 2.49% and 3.23% for the
same periods, respectively), please revise your disclosure in this section to describe in
more detail your consulting and advisory services as you did in the business section.
Your current disclosure appears to indicate that you have derived over 57% of your
revenues in the most recent fiscal year from what appears to be effectively general
business consulting and advisory services, not financial or underwriting
services. Investors should be able to readily discern from the presentation of your
disclosure your material lines of business.
Business
Overview, page 100
3.We note your response to prior comment 9 and reissue our comment. Please revise
this section to list separately the three types of services you appear to provide: 1)
consulting and advisory services, 2) commodity trading, and 3) financial services. List
them in the order of services that produce the most revenues for your company. In this
regard, we note your response to comment 9 where you stated that "underwriting and
placing services, securities brokerage and dealing services, and asset management
services segments differ from consulting and advisory services segment."
You continue, however, to describe all these types of services under "financial
services" and combine them into one. As such, revise this subsection significantly as
follows:
•describe how you are compensated for each of the services provided, such as
commissions, flat fees or otherwise;
•revise disclosure about your consulting and advisory services segment separately,
as opposed to listing it within the "financial services business segment;" and
•because you derive most of your revenues from business consulting and advisory
services, move the description of this business segment to the beginning of the
business section, as opposed to listing financial services as the first segment
because it only produced less than 4% of your revenues in the last two fiscal
years.

November 19, 2024
Page 3
External Brokers, page 108
4.We note your response to prior comment 10. Please file all material agreements with
Phillip Securities Limited as exhibits or advise.
Principal Shareholders, page 150
5.We note your response to prior comment 12 and your revised disclosure in footnote 6
to the beneficial ownership table. Please revise your disclosure in the section prior to
the table to disclose the percentage of outstanding Class A shares  the holders of Class
A ordinary shares must keep to continue to control the outcome of matters submitted
to shareholders for approval. It appears based on your disclosure that your significant
beneficial owners do not currently hold any Class B ordinary shares.
6.We note your response to prior comment 20 and your revised disclosure in
footnote (2) to the beneficial ownership table. Please further revise your disclosure in
footnote (2) to state that the enumerated natural persons have the voting and
dispositive power over the shares owned by Echo Interntional Holdings Group
Limited or revise to state who has the voting and dispositive power.
Note 26 - Financial Instrument - b.(iii) ECL for trade receivables from contracts with
customers, page F-47
7.We note your response to prior comment 14 and the disclosure of your write-off
policy on page F-20. It appears that your policy of writing-off a receivable when,
"there is no realistic prospect of recovery" may not be consistent with the guidance in
IFRS 9 which indicates an entity should write-off a financial asset when the entity
has "no reasonable expectations of recovering the contractual cash flows" which could
result in you delaying the write-off of certain receivables. It appears that receivables
not on additional payment arrangements, for which you have not received a payment
in a reasonably long time, and for which the customer has not acknowledged the
outstanding debts may meet the "no reasonable expectation" criteria in IFRS 9. Please
ensure you properly assess your receivables to determine when you have no
"reasonable expectations" and write-off your receivables accordingly.  Please revise
the disclosure of your write-off policy as needed.
8.We note your response to prior comment 15. It appears you did not include certain
material information that was included in your proposed revised disclosure
from comment 47 in our letter dated July 19, 2024. Therefore, please include the
following information in the appropriate section of your filing:
•When assessing expected credit losses, defaulted receivables are subject to higher
provisions compared to non-defaulted receivables. This is to account for the
increased credit risk associated with defaults.

November 19, 2024
Page 4
            Please contact Michael Henderson at 202-551-3364 or Michael Volley at 202-551-
3437 if you have questions regarding comments on the financial statements and related
matters. Please contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-
3601 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Lawrence Venick, Esq.

September 30, 2024
Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong
Re:Bluemount Holdings Limited
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted September 16, 2024
CIK No. 0002027815
Dear Chan Wan Shan Sandra:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
July 19, 2024 letter.
Amendment No. 1 to the Draft Registration Statement on Form F-1
General
We note your response to prior comment 1 and your revised disclosure in the summary
and business section. Please further revise as follows:
•in your overview section on page 1, please clarify what percentage of your revenues
was derived in recent fiscal years form your financial services segment and to put it in
perspective with two other business lines that contribute to more than 97% of your
revenues; and
•revise your business section starting on page 99, to clearly identify each of the three
business lines you appear to be engaged in; and1.

September 30, 2024
Page 2
•revise here to give prominence to business lines that are most material to your
business.
2.We note your response to prior comment 28 and reissue in part. You removed references
to online platform in some sections of the registration statement but continue to reference
platforms or online platforms in other sections, for example, refer to your disclosure on
pages 13, 28, and 113. Please explain the relevance of platforms or online platforms to
your business in the summary, business, and risk factors sections or remove all references
to platforms throughout the registration statement.
Overview, page 1
3.We note your response to prior comment 11 and reissue in part.  We also note your
revised disclosure that "[m]ost of the revenue [you] make comes from selling to one
important business partner, Customer A, who is a private company incorporated in Hong
Kong with limited liability" and that your partnership with Customer A "has been strong
since December 2021, helping [you] stay financially secure and showing that they will
probably keep buying from [you]." Because Customer A accounted for a significant
percentage of your revenue in fiscal year 2024, please identify Customer A on pages 1,
24, 69, and 83-84, disclose the terms of any material agreements with Customer A, and
file the agreements as exhibits.
Corporate History and Structure, page 4
4.Please refer to prior comment 9.  Please revise to clarify what the percentages below each
box represent in you corporate structure diagram.
Risk Factors, page 20
5.We note your response to prior comment 3 and that you have removed the definition of
the "controlling shareholders" from the registrations statement. We also note your
disclosure on page F-9 where you state that "[t]he Company, together with its wholly-
owned subsidiaries, is effectively controlled by the same controlling shareholders, i.e.,
ultimately held 27.45% by Mr. Pan, 26.08% by Mr. Yan, 16.47% by Ms. Zhou and
30.00% by Echo International Holdings Group Limited." If you will be controlled by a
small group of shareholders following the initial public offering, please revise throughout
to make that clear and add risk factor disclosure to advise the investors of the
various material risks arising with being a controlled company. In addition, tell us if there
are any voting arrangements or agreements among the above referenced shareholders.
Recent joint statement by the SEC and PCAOB, page 44
6.We note your response to prior comment 14 and your revised disclosure in this risk factor.
Please further revise here to state that the value of the securities you are registering for
sale can significantly decline or become worthless.
Impairment loss on trade and other receivables, page 74
Please refer to prior comment 21. Please revise to provide additional information to allow
an investor to better understand the specific facts about the relevant
receivables/customers and the underlying factors that resulted in the material amount of 7.

September 30, 2024
Page 3
credit impairment recognized in 2023. For example, discuss the number of
receivables/customers the impairment related to, any specific factor that triggered the
recognition related to any material individual amounts, whether you recognized
impairment related to the entire customer balances due or only a portion of balances due,
etc.
Industry, page 91
8.We note that you refer to various industry sources in this section. Please revise throughout
this section to address the following:
•refer to prior comment 27 and provide URL addresses for each source cited in
footnotes;
•refer to prior comment 24 and provide support for your disclosure in this section that
the "market size of the [consulting services] industry reach[ed] more than one trillion
U.S. dollars in 2022;" and
•tell us if any of the information cited is based on reports commissioned by you and
independently prepared for you in connection with this offering.  If so, refer to Rule
436 and provide consents for each of the reports commissioned by you.
Business
Financial Services Business Segment, page 100
9.We note your response to prior comment 31. Please revise this subsection significantly as
follows:
•provide additional details on the services you offer under the consulting and advisory
business segment;
•describe how you are compensated for each of the services described on pages 101-
102, such as commissions, flat fees or otherwise;
•revise disclosure starting on page 101 and through the end of page 102 to be placed
within consulting and advisory services segment or advise how the description of the
services listed here falls within "financial services;" and
•because you derive most of your revenues from business consulting and advisory
services, move the description of this business line to the beginning of the business
section.
External Brokers, page 113
10.We note your removal of the identity of your external broker for U.S. exchanges. Please
identify the external broker or advise.
Strengthening our placing and underwriting services, page 119
We note your response to prior comment 30 and your revised disclosure that with less
than 2% of your total revenue derived from placing and underwriting services, you
"maintain" that your "placing and underwriting business remain as [y]our core
competence since the management team believes that the Hong Kong capital market will
rebound as investor confidence returns, aided by potential market reforms and economic
recovery efforts." Please revise this sentence to state as belief of management or remove 11.

September 30, 2024
Page 4
this disclosure.
Principal Shareholders, page 151
12.We note your response to prior comment 35 and reissue in part.  Please disclose the
percentage of outstanding shares that holders of Class A ordinary shares must keep to
continue to control the outcome of matters submitted to shareholders for approval. It also
appears that a small group of shareholders will be able to control the company after the
initial public offering. If applicable, please explain the controlling shareholders' ability to
control matters requiring shareholder approval, including the election of directors,
amendments of organizational documents, and approval of major corporate transactions,
such as a change in control, merger, consolidation, or sale of assets.
Note 14. Trade Receivables, page F-31
13.Please refer to prior comment 43. Please include the proposed disclosure included in your
response.
Note 26 - Financial Instrument - b.(iii) ECL for trade receivables from contracts with customers,
page F-46
14.We note you have never recorded a write-off of a receivable based on your response to
prior comment 47.  Please tell us the amount of receivables past due for more than
one year as of March 31, 2024 that are not on additional payment arrangements or that
you have not collected a payment on in the last 12 months.  For these receivables, please
tell us why you believe you have a reasonable expectation of recovering the contractual
cash flows due and the receivable should not be written-off.  Refer to IFRS 9.B3.2.16(r)
for guidance.
15.Please refer to prior comment 47. Please include the proposed disclosure included in your
response.
16.We note your response to prior comment 48. In your response you disclose that you have
entered into additional payment arrangements with customers who have overdue balances
and that repayment plans provide a reasonable basis for expecting recovery. For all
material receivable balances past due more than 90 days, please provide us with all the
key details of these repayment plans that you rely upon as a basis for expecting recovery
including:
•details of when each agreement was put in place,
•details of new payment terms,
•collections to date,
•information related to modified amounts that have not been collected, and
•any other information material to your collectability assessment.
In this regard we note increases in your unimpaired trade receivables past due 1 year or
more and a material amount of unimpaired trade receivables from a related party past due
2-5 years as indicated in your response to comment 43. Lastly, please revise MD&A to
include appropriate detailed information related to your additional payment arrangements
to allow an investor to better understand the timing of credit impairments and the reasons
for not recognizing credit impairment on material trade receivables that are past due.

September 30, 2024
Page 5
17.We note your response to prior comment 49. Revise your disclosures to discuss
the additional payment agreements (terms, principal impacts, etc.) and how in details the
agreements impacted your assessment of credit risk, the recognition and measurement of
expected credit losses, and your write-offs.
Note 29. Subsequent Events, page F-50
18.Please refer to prior comment 51. Please include the proposed disclosure included in your
response.
Item 7. Recent Sales of Unregistered Securities, page II-2
19.We note your response to prior comment 52 and reissue in part. For each transaction listed
in this section, please state the aggregate offering price. If some of the transactions listed
in the table represent an exchange of one type of security for another type and there was
no additional consideration, please clarify that the transaction involved an exchange of
one type of share for another. As to any securities sold otherwise than for cash, state the
nature of the transaction and the nature and aggregate amount of consideration received
by you. Refer to Item 701(c) of Regulation S-K.
20.We note your response to prior comment 37 and your revised disclosure in footnote 2 to
the beneficial ownership table on page 152. In footnote 2 you state that "[t]he board of
directors of Echo International Holdings Gorup Limited holds the voting and dispositive
power over the Class A Ordinary Shares held by Echo Interntional Holdings Group
Limited." Please revise to disclose further natural persons who hold the voting and
dispositive power as described above.
            Please contact Michael Henderson at 202-551-3364 or Michael Volley at 202-551-3437 if
you have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Lawrence Venick, Esq.

July 19, 2024
Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong
Re:Bluemount Holdings Limited
Draft Registration Statement on Form F-1
Submitted June 25, 2024
CIK No. 0002027815
Dear Chan Wan Shan Sandra:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1
General
1.We note your disclosure that approximately 57% and 78% of your revenues in the last
two fiscal years were attributable to consulting and advisory services, and 40% and 19%
of your revenues were attributable to the trading of luxury timepieces. Please revise your
prospectus significantly in the (a) prospectus summary, (b) risk factors, (c) industry, (d)
business and (e) management's discussion and analysis of financial condition and results
of operations sections to discuss these two revenue-producing segments in the beginning
of each of the respective sections of the prospectus. In this regard, we note that currently
you prominently discuss underwriting and placing services, securities dealing and
brokerage services, and asset management services in each of the sections, even though
less than 3% and 4% of your revenues were derived from these types of services in fiscal
years 2024 and 2023, respectively.

July 19, 2024
Page 2
2.Please revise your cover page, summary, and risk factors sections to disclose your
multiple class share structure (Class A ordinary shares and Class B ordinary shares) and
explain the nature of the disparate voting rights, including the number of votes per share
to which each class of common stock is entitled, and the risks the structure presents to
investors, including the risk that future issuances of high-vote shares may be dilutive to
the shareholders of Class B shares.
3.Please define "Controlling Shareholders" the first time you refer to this group of
shareholders in the filing or advise.
4.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications. Please contact Madeleine Mateo at (202) 551-3465 to discuss how to
submit the materials, if any, to us for our review.
5.We note that in several risk factors you refer to your or the group's "retail shops," but in
the facilities section starting on page 109 you only describe a 3,000 square foot office
space you lease. Please revise for consistency or advise.
6.We note that throughout the prospectus you often describe the industry using compound
annual growth rate ("CAGR"). Because CAGR only represents two discrete snapshots in
time, but does not show trends or events during the period represented, please balance
your disclosure by also including the annual rates for the periods represented.
7.Please include compensation of your executive officers in the most recent fiscal year.
Refer to Item 6.B. of Form 20-F.
Overview, page 1
8.Please revise here and in other key disclosures where you discuss your business model
related to selling luxury timepieces to provide additional key details. For example, discuss
your distribution strategies, the type and amount of marketing you perform, the
percentage of revenue from on-line vs. off-line sales, the percentage of corporate vs. retail
customers, the type and number of storefronts you have, etc. Additionally, based on
disclosure on pages 77 and 103, it appears that you have generated substantially all of
your revenue from sales to one customer. If true, please more prominently disclose this
fact.
Corporate History and Structure, page 3
9.Please revise the corporate structure diagram here and elsewhere in the filing to clearly
disclose the percentage of voting rights and economic rights by class of share.
Prospectus Summary, page 12
Please revise the first paragraph in this section to disclose that trading in your securities
may be prohibited under the Holding Foreign Companies Accountable Act, as amended
by the Consolidated Appropriations Act, 2023, and related regulations if the PCAOB
determines that it cannot inspect or investigate completely your auditor for a period of two
consecutive years, and that as a result an exchange may determine to delist your 10.

July 19, 2024
Page 3
securities. In this regard we note that your disclosure currently refers to "three consecutive
years."
Risk Factors, page 17
11.We note the significant revenue concentration within your customer base. In this regard,
we note that Customer A from your trading of timepiece segment accounted for 40.45%
of your revenue for the year ended March 31, 2024, Customer B from your consulting and
advisory segment accounted for 66.54%, and Customer C from your trading of timepiece
segment accounted for 18.52% of your revenue for the year ended March 31, 2023. Please
identify Customer A, Customer B and Customer C and include a risk factor highlighting
the risks associated with dependence on a limited number of customers. Further, if
applicable, disclose the terms of any material agreements with these customers and file
the agreements as exhibits. Refer to Item 601(b)(10) of Regulation S-K.
Risks Related to Our Business, page 17
12.Please refer to industry challenges described on pages 88 and 89 and revise this section to
describe material risks to investors related to the industry of trading luxury watches.
Reliance on products of certain brands under the Commodity Trading Business Segment, page 29
13.Please revise to disclose the top three brands of timepieces that comprise 100% of your
inventory.
Recent joint statements by the SEC and PCAOB, page 40
14.We note your disclosure about the Holding Foreign Companies Accountable Act. Please
update your disclosure to describe the potential consequences to you if the PRC adopts
positions at any time in the future that would prevent the PCAOB from continuing to
inspect or investigate completely accounting firms headquartered in mainland China or
Hong Kong.
Use of Proceeds, page 56
15.We note that you plan to use approximately 30% of the net proceeds of this offering for
acquisition of financial and investment related companies. Please provide a brief
description of the businesses you are seeking to acquire and, to the extent you have
identified any particular business, include information on the status of the
acquisition. Refer to Item 3.C.3. of Form 20-F.
16.Please give the net amount of the proceeds to be used for each of the uses specified. Refer
to Item 3.C.1. of Form 20-F.
Reorganization, page 61
17.We note the depiction of Bluemount Capital Limited in the diagram illustrating your
corporate structure immediately after this offering, as well as your disclosure on pages F-7
and F-35, that this company was incorporated in Hong Kong. However, your disclosure
on page 62 states that Bluemount Capital Limited was formed as the foreign company's
Taiwan branch, Republic of China. Please disclose consistently if the company is
incorporated under the laws of Taiwan or Hong Kong.

July 19, 2024
Page 4
Competition in the financial services industry in Hong Kong, page 67
18.Please tell us why you disclose that securities dealing is your primary business and has
traditionally been a significant part of your operations considering the immaterial impact
of this business on your financial results. Alternatively, please revise your disclosure as
needed.
Advisory service fee income, page 73
19.Please revise your disclosure to provide details of the amount of revenue recognized each
year and the year over year changes in your advisory service fee income. For example,
disclose the number of projects/transactions closed each year, average fee per
projects/agreement and discuss the underlying reasons for any material trends.
Trading of timepiece, page 73
20.Please revise your disclosure to provide details of the amount of revenue recognized each
year and the year over year change in your trading of timepieces revenue. For example,
disclose the number of timepieces sold in each period, the average sales price per
timepiece and discuss the underlying reasons for any material trends.
Impairment loss on trade and other receivables, page 73
21.Please revise your disclosures to discuss the key facts and circumstances that resulted in
the 2023 impairment loss. Please discuss the likelihood that the underlying reasons for the
impairment loss are indicative of the need for future impairments.
Results of Operations - Income tax expense, page 74
22.Please revise to disclose the effective tax rate for each period presented and describe the
underlying reasons for the material difference. Please discuss the extent that the reason for
the large effective tax rate in 2023 is expected to impact future taxes so that investors can
ascertain the likelihood that past tax rates are indicative of future tax rates.
Industry Background of Financial Services Business Segment, page 80
23.Please reconcile your disclosure that as of March 31, 2024, the equity market in Hong
Kong ranked the seventh largest stock market in the world with the table below your
disclosure showing the worldwide ranking of the Hong Kong Stock Exchange as eighth in
the world.
Industry Background of the Consulting and Advisory Services Business Segment, page 83
24.Please provide support for your disclosure in the first paragraph of this section that the
"market size of the [consulting services] industry reach[ed] more than one trillion U.S.
dollars in 2022."
25.We note that your business operates exclusively in Hong Kong. Please revise your
disclosure in the third full paragraph on page 84 to describe Hong Kong's management
consulting market. In this regard, we note that you currently discuss the size of China's
management consulting market but you do not appear to have any operations in Mainland
China. Make corresponding changes in the first paragraph on page 88 where you discuss
the size of China's luxury timepieces market.

July 19, 2024
Page 5
Industry Background of the Luxury Branded Timepieces Business Segment, page 86
26.Please explain what you mean by your reference to "Incredible" in the first paragraph on
page 87.
27.Please revise your disclosure here and throughout this prospectus to cite specific sources
for the market and industry data you present.
28.Please either explain why in the fifth paragraph on page 87 you describe the online sector
and online platforms and their relevance to your business or remove this paragraph.
Synergies among our different lines of services which generate diversified and stable sources of
revenue, page 93
29.We note your disclosure on pages 91 and 93 related to the benefits created by synergies
between your businesses and other disclosure in your filing discussing how your
businesses “complement one another.” Noting that 57% of your revenue for the year
ended March 31, 2024 related to your consulting and advisory business and 40% of your
revenue related to selling watches, please revise your disclosure throughout your filing to
clarify how these apparently disparate businesses create synergies and the types of
synergies created. Alternatively, and if appropriate, please remove disclosure related to
synergies.
Strengthening our placing and underwriting services, page 93
30.Please balance your disclosure that your placing and underwriting business is your core
competence with a discussion of the historical revenue generated from the placing and
underwriting business and your engagement in these services subsequent to March 31,
2024, up to the date of the prospectus. In this regard, we note your disclosure on page 63
that you generated 0% and 1.32% of your total revenues from the underwriting and
placing services for the years ended March 31, 2024, and 2023, respectively.
Consulting and Advisory Business Segment, page 100
31.Please revise this subsection significantly to provide additional details on the services
offered by you in the consulting and advisory business segment. Explain what specific
services you provide under each corporate finance and strategic communications
"segments" and describe how you are compensated for such services, such as
commissions, flat fees or otherwise.
Consulting and Advisory Business Segment, page 105
32.Where you highlight the extensive business and financial knowledge possessed by your
staff, please balance your disclosure by also discussing that your operating subsidiaries
employed only nine employees as of March 31, 2024.

July 19, 2024
Page 6
Sales and Marketing - Commodity Trading Business Segment, page 105
33.Your disclosure here implies that you have a broad, active and loyal customer base.
However, based on disclosure on pages 77 and 103, it appears that you have generated
substantially all of your revenue from sales to one customer. If true, please revise your
disclosure here and elsewhere in the filing to ensure that the characterization of your
customer base is consistent with the fact that you have one customer.
Employment Agreements with Executive Officers, page 135
34.Please describe the material terms of the employment contracts with your executive
officers. Refer to Item 10.C. of Form 20-F.
Principal Shareholders, page 136
35.We note your reference to controlling shareholders on page 152. Please disclose what
percentage of the voting power will be held by the controlling shareholders after this
offering and the percentage of outstanding shares that holders of Class A ordinary shares
must keep to continue to control the outcome of matters submitted to shareholders for
approval. Explain the controlling shareholders' ability to control matters requiring
shareholder approval, including the election of directors, amendments of organizational
documents, and approval of major corporate transactions, such as a change in control,
merger, consolidation, or sale of assets.
36.You disclose that upon the closing of the offering, none of your shareholders will have
different voting rights from other shareholders. Please tell us how this disclosure is
consistent with disclosure on pages 141 and F-38 that Class A shareholders have 20 votes
and Class B shareholders have one vote per share. Alternatively, please revise as
appropriate.
37.Please disclose the natural person or persons who have voting and dispositive control over
the shares held by Echo International Holdings Group Limited.
38.Please tell us why the ownership percentages in the table on page 137 differ from
percentages disclosed on page F-9. If necessary, revise your disclosure for consistency or
advise.
Certain Relationships and Related-Party Transactions
Transactions with Certain Related Parties, page 138
39.Please revise the second paragraph in this section to state that you are required to disclose
related party transactions since the beginning of your three preceding fiscal years. Refer to
Item 7.B. of Form 20-F. In addition, revise the tables in this section to explain the related
party relationship for each of the entities or individuals included in this section.
Description of Share Capital
Calls on Ordinary Shares and Forfeiture of Ordinary Shares, page 142
We note your disclosure in this section that "directors may