SecProbe.io

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 American Trust Investment Services, Inc.

 1244 119 th Street

 Whiting, IN 46394

 April 8, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance Office of Technology

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:

 Mr. Matthew Derby
 Mr. Edwin S. Kim

 Re:
 Tianci International, Inc.

 Registration Statement on Form S-1

 File No. 333-280089 (the "Registration Statement")

 Dear Mr. Matthew Derby and Mr. Edwin S. Kim:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, (the "Act"), we hereby join the Company's
request for acceleration of the above- referenced Registration Statement, requesting effectiveness for 4:00 p.m., Eastern Time on April
9, 2025, or as soon thereafter as practicable.

 Pursuant to Rule 460 under
the Act, we wish to advise you that the underwriters have distributed as many copies of the Preliminary Prospectus dated March 14, 2025
to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

 The undersigned, as the representative
of the several underwriters, represents that the several underwriters have and will comply with the requirements of Rule 15c2-8 under
the Securities Exchange Act of 1934, as amended.

 Please contact Ye & Associates,
P.C., counsel of the representative of the underwriters, at 929-300-7489 to provide notice of effectiveness, or if you have any questions
or concerns regarding the foregoing. We appreciate your assistance in this matter.

 [ Signature page follows ]

   1

 Very truly yours,

 As representative of the underwriters

 American Trust Investment Services, Inc.

 By:
 /s/ Ian E. Lippy

 Name:
 Ian E. Lippy

 Title:
 Chief Operating Officer

   2

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 Tianci International, Inc.

 April 8, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:

 Mr. Matthew Derby
 Mr. Edwin S. Kim

 Re:
 Tianci International, Inc.

 Registration Statement on Form S-1

 Initially Filed on June 10, 2024

 File No. 333-280089

 Ladies and Gentlemen:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Tianci International, Inc. hereby requests that
the effectiveness of the above-referenced Registration Statement on Form S-1, as amended, be accelerated to and that the Registration
Statement become effective at 4:00 p.m., Eastern Time, on April 9, 2025, or as soon thereafter as practicable.

 Very truly yours,

 Tianci International, Inc.

 By:
 /s/ Shufang Gao

 Name:
 Shufang Gao

 Title:
 Chief Executive Officer

CORRESP
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TIANCI INTERNATIONAL, INC.

Unit B,10/F., Ritz Plaza, No.122 Austin Road, Tsim
Sha Tsui, Kowloon, Hong Kong 999077

September 27, 2024

Mr. Matthew Derby

Office of Technology

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4631

100 F Street, N.E.

Washington, D.C. 20549-4631

    Re:
    Tianci International, Inc.

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

    Filed September 5, 2024

    File No. 333-280089

Dear Mr. Derby,

This letter is in response to the letter dated
September 19, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Tianci International, Inc. (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Staff’s comments in this response and numbered them accordingly. An amended registration statement on Form S-1
(the “Amendment No. 3”) is being filed to accompany this letter.

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

Risk Factors

While we believe that we and our subsidiaries are currently not
required to obtain permissions or

approvals from Mainland China..., page 34

    1.

    Please revise to clarify that although
certain risks specific to variable interest entities may not be applicable to you, the issues and risks identified in the Division of
Corporation Finance's November 23, 2020 "Disclosure Considerations for China-Based Issuers" related to China-based operating
companies registering securities with the SEC do still apply, and that the PRC government has oversight authority notwithstanding the
fact that your operations are based in Hong Kong.

      1

Response: In response to the
Staff’s comment, the Company respectfully proposes to include the referenced disclosure in the risk factors on pages 34 to
37 of Amendment No. 3, subject to updates and adjustments to be made in connection with any material development of the subject matter
being disclosed.

    2.

    We note your disclosure that you do not
believe you are required "to obtain any permissions or approvals from the Mainland China authorities, including but not limited
to the China Securities Regulatory Commission (“CSRC”) and the Cyberspace Administration of China (“CAC”), to
operate Roshing’s business or to list our securities on the U.S. exchanges and offer securities, including but not limited to issuing
our common stock to foreign investors; and (ii) we and our subsidiaries have not applied for or been denied of any such permissions or
approvals from the Mainland China authorities." Please tell us whether you relied upon an opinion of counsel with respect to such
conclusions and if not, revise in to state as much and explain why such an opinion was not obtained. Additionally, revise your disclosure
to clarify whether you or your subsidiaries are required to obtain any permissions or approvals from Hong Kong to operate your business
and revise your risk factors as appropriate. To the extent that you are subject to any permission or approval requirements, state affirmatively
whether you have received all requisite permissions or approvals and whether any permissions or approvals have been denied. Please also
describe the consequences to you and your investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals,
(ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and you are required to obtain such permissions or approvals in the future.

Response: Based on their understanding
of the current PRC laws and regulations, our PRC legal counsel, Jiangsu Junjin Law Firm, have advised that we are not required to obtain
any obtain any permissions or approvals from the Mainland China authorities for consummating this offering, including but not limited
to the CSRC and CAC, to operate Roshing’s business or to list our securities on the U.S. exchanges and offer securities, including
but not limited to issuing our common stock to foreign investors, given that: (i) we are a Nevada company and our only operating subsidiary,
Roshing, is a Hong Kong company and is headquartered in Hong Kong; neither entity has operations in Mainland China; (ii) we do not, directly
or indirectly, own or control any entity or subsidiary in Mainland China, nor are we controlled by any Mainland Chinese company or individual
directly or indirectly; (iii) we currently do not have or intend to set up any subsidiary or enter into any contractual arrangements to
establish a VIE structure with any entity in Mainland China; (iv) only few of Roshing’s customers are Mainland China residents,
which contributed 5.2% and 0.4% of our revenue for the year ended July 31, 2023 and the nine months ended April 30, 2024, respectively;
(v) the majority of our senior managers in charge of the Company’s business operation and management are Hong Kong nationals and
domiciled in Hong Kong; and (vi) all of Roshing’s employees are Hong Kong residents. In addition, our PRC legal counsel, Jiangsu
Junjin Law Firm, has advised that the offering of our securities is neither subject to the mandatory cybersecurity review under the Cybersecurity
Review Measures nor the filing requirements under the Trial Measures.

In response to the Staff’s comments,
we further revised the disclosure on pages iii and 28 of Amendment No. 3 in relation to the permissions or approvals from Hong Kong to
operate our business.

Thank you in advance for your assistance in reviewing
this response and the Amended Registration Statement. Should you have any questions with respect to the above responses, please contact
me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/ Shufang Gao

    Shufang Gao

      2

September 19, 2024
Shufang Gao
Chief Executive Officer
Tianci International, Inc.
Unit B,10/F., Ritz Plaza, No.122 Austin Road, Tsim Sha Tsui
Kowloon, Hong Kong 999077
Re:Tianci International, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed September 5, 2024
File No. 333-280089
Dear Shufang Gao:
            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.
Amendment No. 2 to Registration Statement on Form S-1
Risk Factors
While we believe that we and our subsidiaries are currently not required to obtain permissions or
approvals from Mainland China..., page 34
1.Please revise to clarify that although certain risks specific to variable interest entities may
not be applicable to you, the issues and risks identified in the Division of Corporation
Finance's November 23, 2020 "Disclosure Considerations for China-Based
Issuers" related to China-based operating companies registering securities with the SEC
do still apply, and that the PRC government has oversight authority notwithstanding the
fact that your operations are based in Hong Kong.

September 19, 2024
Page 2
General
2.We note your disclosure that you do not believe you are required "to obtain any
permissions or approvals from the Mainland China authorities, including but not limited
to the China Securities Regulatory Commission (“CSRC”) and the Cyberspace
Administration of China (“CAC”), to operate Roshing’s business or to list our securities
on the U.S. exchanges and offer securities, including but not limited to issuing our
common stock to foreign investors; and (ii) we and our subsidiaries have not applied for
or been denied of any such permissions or approvals from the Mainland China
authorities." Please tell us whether you relied upon an opinion of counsel with respect to
such conclusions and if not, revise in to state as much and explain why such an opinion
was not obtained. Additionally, revise your disclosure to clarify whether you or your
subsidiaries are required to obtain any permissions or approvals from Hong Kong
to operate your business and revise your risk factors as appropriate. To the extent that you
are subject to any permission or approval requirements, state affirmatively whether you
have received all requisite permissions or approvals and whether any permissions or
approvals have been denied. Please also describe the consequences to you and your
investors if you or your subsidiaries: (i) do not receive or maintain such permissions or
approvals, (ii) inadvertently conclude that such permissions or approvals are not required,
or (iii) applicable laws, regulations, or interpretations change and you are required to
obtain such permissions or approvals in the future.
            Please contact Matthew Derby at 202-551-3334 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

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TIANCI INTERNATIONAL, INC.

Unit B,10/F., Ritz Plaza, No.122 Austin Road, Tsim
Sha Tsui, Kowloon, Hong Kong 999077

July 16, 2024

Mr. Matthew Derby

Office of Technology

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4631

100 F Street, N.E.

Washington, D.C. 20549-4631

    Re:
    Tianci International, Inc.

    Registration Statement on Form S-1 Filed June 10, 2024

    File No. 333-280089

Dear Mr. Derby,

This letter is in response to the letter dated
June 20, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Tianci International, Inc. (the “Company,” “we,” and “our”). For ease of reference, we have recited
the Staff’s comments in this response and numbered them accordingly. An amended registration statement on Form S-1 (the “Amended
Registration Statement”) is being filed to accompany this letter.

Registration Statement on Form S-1

Prospectus Summary, page 1

    1.
    Disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors. State whether you or your subsidiaries are covered by permissions requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency, and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors if you or your subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

Response: In response to the Staff’s
comments, we revised the disclosure in the Amended Registration Statement on the cover page and pages iii and 13 of the Amended Registration
Statement to clarify that we and our subsidiaries are currently not required to obtain permission from any of the mainland China authorities
to operate and issue our common stock to foreign investors because we are a Nevada company and our only operating subsidiary is a Hong
Kong company, neither entity has operations in mainland China.

In addition, we and our subsidiaries
are not required to obtain permission or approval from the PRC authorities including CSRC and the CAC, for our operation. Additionally,
we and subsidiaries have not applied for, or been denial of any such permissions or approvals from the authorities of mainland China.
We also clarified that (i) We are a Nevada company and our only operating subsidiary, Roshing, is headquartered in Hong Kong, with no
operations in mainland China; (ii) only few of Roshing’s customers are mainland China residents, which contributed to 5.2% and 0.4%
of our revenue for the year ended July 31, 2023 and the nine months ended April 30, 2024, respectively; and (iii) all of Roshing’s
employees are Hong Kong residents, we and our subsidiaries are not subject to Mainland China laws and regulations, such as those relating
to data and cyberspace security.

We have also revised the disclosure
in the Amended Registration Statement page 34 to describe the consequences if we or our subsidiaries: (i) do not receive or maintain such
permissions or approvals, should such permissions or approvals be required in the future by the PRC government due to changes in Mainland
China laws and regulations or the interpretation thereof; or (ii) incorrectly conclude that such permissions or approvals are not required.

      1

Risk Factors

Risks Related to Doing Business in Hong Kong, page 29

    2.
    We note your cover page disclosure indicating that you and your subsidiaries "should not become subject to certain laws...such as those relating to data and cyberspace security." However, in light of recent events indicating greater oversight by the Cyberspace Administration of China (CAC) over data security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure to explain how this oversight impacts your business and your offering and to what extent you believe that you are compliant with the regulations or policies that have been issued by the CAC to date.

Response: In response to the Staff’s
comments, we revised the disclosure in the Amended Registration Statement on the cover page and pages 34 of the Amended Registration
Statement to clarify that the oversight by the CAC over data security does not have any impact on our business and our offering, because
we are a Nevada company and our only operating subsidiary is a Hong Kong company, neither entity has operations in mainland China.

Thank you in advance for your assistance in reviewing
this response and the Amended Registration Statement. Should you have any questions with respect to the above responses, please contact
me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/ Shufang Gao

    Shufang Gao

      2

United States securities and exchange commission logo
June 20, 2024
Shufang Gao
Chief Executive Officer
Tianci International, Inc.
Unit B,10/F., Ritz Plaza, No.122 Austin Road, Tsim Sha Tsui
Kowloon, Hong Kong 999077
Re:Tianci International, Inc.
Registration Statement on Form S-1
Filed June 10, 2024
File No. 333-280089
Dear Shufang Gao:
            We have conducted a limited review of 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 S-1
Prospectus Summary, page 1
1.Disclose each permission or approval that you or your subsidiaries are required to obtain
from Chinese authorities to operate your business and to offer the securities being
registered to foreign investors. State whether you or your subsidiaries are covered by
permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency, and state
affirmatively whether you have received all requisite permissions or approvals and
whether any permissions or approvals have been denied. Please also describe the
consequences to you and your investors if you or your subsidiaries: (i) do not receive or
maintain such permissions or approvals, (ii) inadvertently conclude that such permissions
or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and you are required to obtain such permissions or approvals in the future.

 FirstName LastNameShufang Gao
 Comapany NameTianci International, Inc.
 June 20, 2024 Page 2
 FirstName LastName
Shufang Gao
Tianci International, Inc.
June 20, 2024
Page 2
Risk Factors
Risks Related to Doing Business in Hong Kong, page 29
2.We note your cover page disclosure indicating that you nd your subsidiaries "should not
become subject to certain laws...such as those relating to data and cyberspace security."
However, in light of recent events indicating greater oversight by the Cyberspace
Administration of China (CAC) over data security, particularly for companies seeking to
list on a foreign exchange, please revise your disclosure to explain how this oversight
impacts your business and your offering and to what extent you believe that you are
compliant with the regulations or policies that have been issued by the CAC to date.
            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 Kyle Wiley at 202-344-5791 or Matthew Derby at 202-551-3334 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                                          FREEDOM PETROLEUM INC.
                                            6025 South Quebec Street, Suite 100,
                                                            Centennial, CO 80111

December 5, 2012

VIA EDGAR

Securities and Exchange Commission
100 F. Street, NE
Washington, D.C. 20549-7410

Dear Sirs:

     Re:  Freedom Petroleum Inc. (the "Company")
          Registration Statement on Form S-1
          File No. 333-184061

In  connection  with the Company's  Form S-1  Registration  Statement  (file no.
333-184061),  the Company hereby requests  acceleration of the effective date of
the  Registration  Statement to 10:00 a.m. (EST) Friday,  December 7, 2012 or as
soon thereafter as possible, in accordance with Rule 461(a) of Regulation C.

     We acknowledge that

     (i)  should the Securities and Exchange Commission (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,

     (ii) 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

     (iii) the Company may not assert 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.

We trust you will find the  foregoing to be in order.  Please do not hesitate to
contact the undersigned should you have any questions in this regard.

                                          Yours truly,

                                          FREEDOM PETROLEUM INC.

                                          Per: /s/ Thomas Hynes
                                               ---------------------------------
                                               Thomas Hynes, President
</TEXT>
</DOCUMENT>

October  25, 2012

Via Facsimile
Mr. Thomas Hynes
President, Treasure r, Chief Executive Officer,
Principal Financial Officer and Director
Freedom Petroleum Inc.
6025 South Quebec Street, Suite 100
Centennial, Colorado 80111

 Re: Freedom Petroleum Inc.
  Registration Statement on Form S -1
  Filed September 24, 2012
  File No. 333-184061

Dear Mr . Hynes :

We have reviewed your 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 providi ng 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 th e information you
provide in response to these comments, we may have additional comments.

Form S -1

Prospectus summary, page 3

Emerging Growth Company,  page 5

1. We note your disclosure in this section.  Please also consider describing the extent to
which any of these exemptions are available to you as a Smaller Reporting Company.

Additionally, please supplementally provide us with 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 , present to potential investors in reliance on Section
5(d) of the Securities Act, whether or not they retain copies of the
communications.   Similarly, please supplementally provide us with any research reports

Mr. Thomas Hynes
Freedom Petroleum Inc.
October 25, 2012
Page 2

 about you that are published or distributed in reliance upon Section 2(a)(3) of the
Securities Act of 1933 added by Section 105(a) of the Jumpstart Our Business Startups
Act by any broker or dealer that is participating or will participate in your offerin g.

Use of Proceeds, page 15

2. Please explain your divergent G&A expenses, which we note vary considerably in your
proposed expenditures assuming you sell 25%, 50%, 75% or 100% of the securities
offered for sale in this offering.   It is not  clear , for ins tance, why your G&A expenses
will be lower if you sell 75% of your shares than if you sell 25% or 50%.

3. We note your disclosure that even if you are able to sell all of the securities being offered,
you will still require approximately $52,500 to cover you r anticipated expenses over the
next 12 months.  You then refer the reader to your discussion in “Management’s
Discussion and Analysis of Financial  Condition and Results of Operations .”  In this
regard, on page 28 you estimate your expenses over the next 1 2 months will be $253,500.
Please reconcile these divergent disclosures of your expenses over the next 12 months.
As part of this, please clarify the minimum amount of capital that you will require to
cover your offering expenses and your legal, accountin g, and general and administrative
expenses as a public company over the next 12 months; separate from the capital required
to complete the first phase of your exploration, and last, your second phase of
exploration.

Dilution of the Price You Pay for Y our Shares, page 16

Existing Stockholders If All Of The Shares Are Sold, page 16

4. Please provide the details of your calculation of “Net tangible book value per share
before offering” of $0.00085 .

Management’s Discussion and Analysis of Financial Conditi on an d Results of Operations,
page 28

5. Please expand Management’s Discussion and Analysis  to address the requirements of
Item 303(a) of Regulation S -K in terms of your financial condition, changes in your
financial condition, and results of operations.

6. Please explain the $30,000 in expenses to acquire additional properties over the next 12
months.

Management, page 32

7. Please provide the business experience during the pa st five years for your officer Nina
Bijedic.  See Item 401(e) of Regulation S -K.

Mr. Thomas Hynes
Freedom Petroleum Inc.
October 25, 2012
Page 3

 Exhibits

Exhibit 5.1

8. Please have counsel revise his opinion to opine that the shares “will be, when sold”
legally (or) validly issued, fully paid and non -assessable.  See Section II.B.1.a of Staff
Legal Bulletin No. 19, available at http://www.sec.gov/interps/legal/cfslb19.htm .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securit ies Act of 1933 and
all applicable Securities Act rules require. Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging 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 effectiv e, 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 the 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.

Please refer to Rules 460 and 461 regarding requests for acceleration.  We will consider a
written request for acceleration of the effective date of the registration stat ement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities sp ecified in the above registration statement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Mr. Thomas Hynes
Freedom Petroleum Inc.
October 25, 2012
Page 4

 You may contact Jenifer O’Brien  at (202) 551 -3721  or Ethan Horowitz, Accounting
Branch Chief,  at (202) 551 -3311  if you have questions regarding comments on the financial
statements and related matters .  Please contact Kevin Dougherty at (202) 551 -3271, or in his
absence, the undersigned at (202) 551 -3745  with any questions.

        Sincerely,

        /s/H. Roger Schwall

H. Roger Schwall
Assistant Director

cc: Via Facsimile
 Scott Olson, Esq.