SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 12, 2025

Lixin Cai
Chief Executive Officer
CXJ Group Co., Ltd
Room 401, 4th Floor, East Block Building 5
Xintiandi Business Center, No. 7 Anqiaogang Road
Gongshu District, Hangzhou City
Zhejiang Province, China 310017

 Re: CXJ Group Co., Ltd
 Form 10-K for the fiscal year ended May 31, 2024
 Filed November 8, 2024
 Form 10-Q for the quarter ended November 30, 2024
 Filed January 8, 2025
 File No. 000-56425
Dear Lixin Cai:

 We issued comments on the above captioned filings on March 26, 2025. On
May 1,
2025, we issued a follow-up letter informing you that comments remained
outstanding and
unresolved, and absent a substantive response, we would act consistent with our
obligations
under the federal securities laws.

 As you have not provided a substantive response, we are terminating our
review and
will take further steps as we deem appropriate. These steps include releasing
publicly,
through the agency's EDGAR system, all correspondence, including this letter,
relating to the
review of your filings, consistent with the staff's decision to publicly
release comment and
response letters relating to disclosure filings it has reviewed.

 Please contact Stephany Yang at 202-551-3167 or Kevin Woody at
202-551-3629
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 1, 2025

Lixin Cai
Chief Executive Officer
CXJ Group Co., Ltd
Room 401, 4th Floor, East Block Building 5
Xintiandi Business Center, No. 7 Anqiaogang Road
Gongshu District, Hangzhou City
Zhejiang Province, China 310017

 Re: CXJ Group Co., Ltd
 Form 10-K for the fiscal year ended May 31, 2024
 Filed November 8, 2024
 Form 10-Q for the quarter ended November 30, 2024
 Filed January 8, 2025
 File No. 000-56425
Dear Lixin Cai:

 We issued comments to you on the above captioned filings on March 26,
2025. As of
the date of this letter, these comments remain outstanding and unresolved. We
expect you to
provide a complete, substantive response to these comments by May 15, 2025.

 If you do not respond, we will, consistent with our obligations under
the federal
securities laws, decide how we will seek to resolve material outstanding
comments and
complete our review of your filings and your disclosure. Among other things, we
may decide
to release publicly, through the agency's EDGAR system, all correspondence,
including this
letter, relating to the review of your filings, consistent with the staff's
decision to publicly
release comment and response letters relating to disclosure filings it has
reviewed.

 Please contact Stephany Yang at 202-551-3167 or Kevin Woody at
202-551-3629
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 26, 2025

Lixin Cai
Chief Executive Officer
CXJ Group Co., Ltd
Room 401, 4th Floor, East Block Building 5
Xintiandi Business Center, No. 7 Anqiaogang Road
Gongshu District, Hangzhou City
Zhejiang Province, China 310017

 Re: CXJ Group Co., Ltd
 Form 10-K for the fiscal year ended May 31, 2024
 Filed November 8, 2024
 Form 10-Q for the quarter ended November 30, 2024
 Filed January 8, 2025
 File No. 000-56425
Dear Lixin Cai:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended May 31, 2024
Report of Independent Registered Public Accounting Firm, page F-1

1. We note your auditors' report indicates the financial statements for the
year ended
 May 31, 2023 has been restated. We also note elsewhere throughout the
filing that
 fiscal 2023 amounts have been labeled restated. However, we were unable
to find any
 information in the filing relating to the restatement itself. In this
regard, please explain
 to us in detail the nature of the restatement for the year ended May 31,
2023 and
 whether the restatement was the result of a correction of an error.
Additionally, revise
 your notes to the consolidated financial statements to include all
required disclosures
 in accordance with ASC 250-10-50. We may have further comment on the
matter
 based upon on your response.
 March 26, 2025
Page 2

Notes to the Consolidated Financial Statements
Note 2 Summary of Significant Accounting Policies
Basis of consolidation, page F-12

2. We note from your disclosures in the last paragraph of Note 1 that ECXJ,
through
 its wholly owned subsidiary, CXJ and its subsidiaries and the VIE own
and operate an
 active automobiles products trading and services business in the People
 s Republic of
 China. We further note in the table on page 12 you list VIEs that you
consolidate and
 have 100% equity interest. In this regard, please revise your financial
statements to
 explicitly state whether you are the primary beneficiary of the VIEs and
revise to
 include all disclosures required by ASC 810-10-50. If you are not the
VIEs primary
 beneficiary, please explain why and provide the disclosures in ASC
810-10-50-4.
General

3. Please revise your filing, as applicable, to provide more specific and
prominent
 disclosures about the legal and operational risks associated with
China-based
 companies. For additional guidance, please see the Division of
Corporation Finance's
 Sample Letters to China-Based Companies issued by the Staff in July 2023
and
 December 2021.
Form 10-Q for the quarter ended November 30, 2024
Item 4 Controls and Procedures
Management's Evaluation of Disclosure Controls and Procedures, page 33

4. We note in both Form 10-Qs for the quarters ended November 30, 2024 and
August
 31, 2024, you disclose management's evaluation of disclosures controls
and
 procedures were effective as of the end of each respective period
covered by the
 report. However, your disclosure of management's evaluation of
disclosure controls
 and procedures contained in your Form 10-K for the year ended May 31,
2024 you
 conclude your disclosure controls and procedures were not effective as
of May 31,
 2024 and additionally, you cite various material weaknesses in your
internal controls
 and procedures which lead you to conclude your internal controls over
financial
 reporting were also not effective of as May 31, 2024. In this regard, we
note no
 discussion of remediation efforts in either of your Form 10-Qs which
lead you to
 conclude the material weaknesses had been remediate and that your
disclosure
 controls and procedures at November 30, 2024 and August 31, 2024 were
thus
 effective. Please advise or alternatively revise disclosures in your
filings to correct
 the inconsistency.
 In closing, 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 Stephany Yang at 202-551-3167 or Kevin Woody at
202-551-3629
with any questions.
 March 26, 2025
Page 3

 Sincerely,

 Division of Corporation Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

    CXJ
        GROUP CO., LTD.

    Room
        1903-1, No.1 building, Xizi

        International
        center

        Jianggan
        District, Hangzhou City,

        Zhejiang
        Province, China

March
8, 2021

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

    Attention:
    Melissa
    Gilmore

    Martin
    James

    Sherry
    Haywood

    Asia
    Timmons-Pierre

    Re:

    CXJ
    Group Co., Ltd

    Amendment
    No.4 to Registration Statement on Form S-1

    Filed
    February 24, 2021

    File
    No. 333-248779

Dear
Messrs.:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, CXJ Group Co., Ltd. (the “Registrant”) hereby
requests acceleration of the effective date of its Registration Statement on Form S-1 (File No.333-248779), as amended (the “Registration
Statement”), so that it may become effective at 4:00 p.m. Eastern Daylight Time on March 10, 2021, or as soon as practicable
thereafter.

The
Registrant hereby authorizes Matthew McMurdo, Esq. to orally modify or withdraw this request for acceleration.

The
Registrant hereby acknowledges that:

(i)
Should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the
Registration Statement;

(ii)
The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
Statement; and

(iii)
The Registrant may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration
Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United
States.

We
request that we be notified of such effectiveness by a telephone call to Matthew McMurdo at (917) 318-2865. We also respectfully
request that a copy of the written order from the Commission verifying the effective time and date of such Registration Statement
be sent to Matthew McMurdo at matt@nannaronelaw.com.

    Very
    truly yours,

    /s/
    Lixin Cai

    Lixin
    Cai

cc:	Matthew
McMurdo, Esq.

CORRESP
1
filename1.htm

    CXJ
    GROUP CO., LTD.
    Room
        1903-1, No.1 building, Xizi

                                                                     International
center

        Jianggan
District, Hangzhou City,

        Zhejiang
        Province, China

February
24, 2021

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

    Attention:
    Melissa
    Gilmore

    Martin
    James

    Sherry
    Haywood

    Asia
    Timmons-Pierre

    Re:

    CXJ
    Group Co., Ltd

    Amendment
    No.3 to Registration Statement on Form S-1

    Filed
    January 19, 2021

    File
    No. 333-248779

Dear
Sir or Madam:

CXJ
Group Co., Ltd. (the “Company”) is filing amendment number 4 (the “Amendment”) to the Statement on Form
S-1/A (the “Registration Statement”) in response to your recent review letter addressed to Lixin Cai, Chief Executive
Officer of the Company, dated February 3, 2021 (the “SEC Letter”). This response letter, along with the amended Registration
Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in the
SEC Letter.

Amendment
No. 3 to Registration Statement on Form S-1

Financial
Statements, page F-18

1.
Please update the filing to provide financial statements that comply with Rule 8-08 of Regulation S-X and revise Management's
Discussion and Analysis and other sections to provide updated financial information. In addition, file an updated consent from
your auditors.

We
have update the Registration Statement and the MD&A to include the latest financial statements.

    Very
    truly yours,

    /s/
    Lixin Cai

    Lixin
    Cai

United States securities and exchange commission logo
February 3, 2021
Lixin Cai
Chairman and Chief Executive Officer
CXJ Group Co., Ltd.
Room 1903-1, No.1 building, Xizi International Center
Jianggan District, Hangzhou City,
Zhejiang Province, China
Re:CXJ Group Co., Ltd
Amendment No. 3 to Registration Statement on Form S-1
Filed January 19, 2021
File No. 333-248779
Dear Mr. Cai:
            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 response to these comments, we may have additional comments.
Amendment No. 3 to Registration Statement on Form S-1
Financial Statements, page F-18
1.Please update the filing to provide financial statements that comply with Rule 8-08
of Regulation S-X and revise Management's Discussion and Analysis and other sections to
provide updated financial information. In addition, file an updated consent from your
auditors.

 FirstName LastNameLixin  Cai
 Comapany NameCXJ Group Co., Ltd.
 February 3, 2021 Page 2
 FirstName LastName
Lixin  Cai
CXJ Group Co., Ltd.
February 3, 2021
Page 2
            You may contact Melissa Gilmore, Staff Accountant at (202) 551-3777 or Martin James,
Senior Advisor at (202) 551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sherry Haywood, Staff Attorney at (202) 551-
3345 or Asia Timmons-Pierce, Special Counsel at (202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    CXJ
        GROUP CO., LTD.

    Room
        1903-1, No.1 building, Xizi

        International
        center

        Jianggan
        District, Hangzhou City,

        Zhejiang
        Province, China

January
19, 2021

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

    Attention:
    Melissa
    Gilmore

    Martin
    James

    Sherry
    Haywood

    Asia
    Timmons-Pierre

    Re:

    CXJ
    Group Co., Ltd

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

    Filed
    December 28, 2020

    File
    No. 333-248779

Dear
Sir or Madam:

CXJ
Group Co., Ltd. (the “Company”) is filing amendment number 3 (the “Amendment”) to the Statement on Form
S-1/A (the “Registration Statement”) in response to your recent review letter addressed to Lixin Cai, Chief Executive
Officer of the Company, dated January 15, 2021 (the “SEC Letter”). This response letter, along with the amended Registration
Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in the
SEC Letter.

Amendment
No. 2 to Form S-1 filed on December 28, 2020

Prospectus
Summary, page 5

1.
You disclose here that your fiscal year end is December 31st and on page 46 that your year end is May 31st.
Please revise to make your disclosure consistent.

We
have revised in the Amendment so that the disclosure is consistent.

Please
direct your correspondence regarding this matter to the undersigned.

    Very
    truly yours,

    /s/
    Lixin Cai

    Lixin
    Cai

United States securities and exchange commission logo
January 15, 2021
Lixin Cai
Chairman and Chief Executive Officer
CXJ Group Co., Ltd.
Room 1903-1, No.1 building, Xizi International Center
Jianggan District, Hangzhou City,
Zhejiang Province, China
Re:CXJ Group Co., Ltd
Amendment No. 2 to Registration Statement on Form S-1
Filed December 28, 2020
File No. 333-248779
Dear Mr. Cai:
            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 response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our November 13, 2020 letter.
Amendment No. 2 to Form S-1 filed December 28, 2020
Prospectus Summary, page 5
1.You disclose here that your fiscal year end is December 31st and on page 46 that your
year end is May 31st. Please revise to make your disclosure consistent.
            You may contact Melissa Gilmore, Staff Accountant at (202) 551-3777 or Martin James,
Senior Advisor at (202) 551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sherry Haywood, Staff Attorney at (202) 551-
3345 or Asia Timmons-Pierce, Special Counsel at (202) 551-3754 with any other questions.

 FirstName LastNameLixin  Cai
 Comapany NameCXJ Group Co., Ltd.
 January 15, 2021 Page 2
 FirstName LastName
Lixin  Cai
CXJ Group Co., Ltd.
January 15, 2021
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    CXJ
        GROUP CO., LTD.

    Room
        1903-1, No.1 building, Xizi

                                                                     International center

        Jianggan
        District, Hangzhou City,

        Zhejiang
        Province, China

December
28, 2020

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

    Attention:
    Melissa
    Gilmore

    Martin
    James

    Sherry
    Haywood

    Asia
    Timmons-Pierre

    Re:

    CXJ
    Group Co., Ltd

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

    Filed
    October 30, 2020

    File
    No. 333-248779

Dear
Sir or Madam:

CXJ
Group Co., Ltd. (the “Company”) is filing amendment number 2 (the “Amendment”) to the Statement on Form
S-1/A (the “Registration Statement”) in response to your recent review letter addressed to Lixin Cai, Chief Executive
Officer of the Company, dated November 13, 2020 (the “SEC Letter”). This response letter, along with the amended Registration
Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in the
SEC Letter.

Amendment
No. 1 to Form S-1 filed on October 30, 2020

Prospectus
Summary, page 5

1.
We note your response to prior comment 5. Please include your telephone number in this section. See Item 503(b) of Regulation
S-K.

We
have included the telephone number in the Prospectus Summary.

2.
We note your response to comment 8, and your revised disclosure that the company was dormant from 2001-2019. It appears that you
may have intended to include 2011 instead of 2001, if so please revise.

Yes,
we intended to state 2011, not 2001. We have edited where necessary.

We
may require additional capital to support growth, page 11

3.
We note your response to prior comment 14. We note your disclosure that you may require additional funds beyond
those generated by this offering. This disclosure is inappropriate given that the company will not receive any of the proceeds
raised in this offering. Please revise accordingly.

We
have removed this disclosure.

There
is limited market for our common stock, page 15

4.
We note your response to prior comment 13. You disclose here that your common stock trades on OTC Markets. Please revise to clarify
here that your stock trades on the OTC Pink.

We
have revised the Amendment to state OTC Pink.

Directors
and Executive Officers and Corporate Governance

Officer
Biographies, page 35

5.
We note your response to prior comment 17. Please include the names and ages of all of your officers and directors in the Officer
Biographies table including Xinrui Wang, Wenbin Mao and Baiwan Nui. Please also describe the work experience for the past five
years of directors Wenbin Mao and Baiwan Nui in this section. Please refer to Items 401(a), (b) and (e) of Regulation S-K.

We
have included the information required by Items 401(a), (b), and (e) of Regulation S-K.

Financial
Statements, page F-1

6.
Please update the filing to provide financial statements that comply with Rule 8-08 of Regulation S-X. In addition, revise Management’s
Discussion and Analysis and other sections to provide updated financial information.

We
have updated our financial statements and footnotes.

Exhibit
23.1, page X-1

7.
Please file an updated auditor’s consent with your next amendment.

We
have included an updated auditor’s consent in the Amendment.

Please
direct your correspondence regarding this matter to the undersigned.

    Very
    truly yours,

    /s/
    Lixin Cai

    Lixin
    Cai

United States securities and exchange commission logo
November 13, 2020
Lixin Cai
Chairman and Chief Executive Officer
CXJ Group Co., Ltd.
Room 1903-1, No.1 building, Xizi International Center
Jianggan District, Hangzhou City,
Zhejiang Province, China
Re:CXJ Group Co., Ltd
Amendment No. 1 to Registration Statement on Form S-1
Filed October 30, 2020
File No. 333-248779
Dear Mr. Cai:
            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 response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 11, 2020 letter.
Amendment No. 1 to Form S-1 filed on October 30, 2020
Prospectus Summary, page 5
1.We note your response to prior comment 5. Please include your telephone number in this
section. See Item 503(b) of Regulation S-K.
2.We note your response to comment 8, and your revised disclosure that the company was
dormant from 2001-2019. It appears that you may have intended to include 2011 instead
of 2001, if so please revise.

 FirstName LastNameLixin  Cai
 Comapany NameCXJ Group Co., Ltd.
 November 13, 2020 Page 2
 FirstName LastName
Lixin  Cai
CXJ Group Co., Ltd.
November 13, 2020
Page 2
We may require additional capital to support growth, page 11
3.We note your response to prior comment 14. We note your disclosure that you may
require additional funds beyond those generated by this offering. This disclosure is
inappropriate given that the company will not receive any of the proceeds raised in this
offering. Please revise accordingly.

There is limited market for our common stock, page 15
4.We note your response to prior comment 13. You disclose here that your common stock
trades on OTC Markets. Please revise to clarify here that your stock trades on the OTC
Pink.
Directors and Executive Officers and Corporate Governance
Officer Biographies, page 35
5.We note your response to prior comment 17. Please include the names and ages of all of
your officers and directors in the Officer Biographies table including Xinrui Wang,
Wenbin Mao and Baiwan Nui. Please also describe the work experience for the past five
years of directors Wenbin Mao and Baiwan Nui in this section. Please refer to Items
401(a), (b) and (e) of Regulation S-K.
Financial Statements, page F-1
6.Please update the filing to provide financial statements that comply with Rule 8-08 of
Regulation S-X. In addition, revise Management's Discussion and Analysis and other
sections to provide updated financial information.
Exhibit 23.1, page X-1
7.Please file an updated auditor's consent with your next amendment.
            You may contact Melissa Gilmore, Staff Accountant at (202) 551-3777 or Martin James,
Senior Advisor at (202) 551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sherry Haywood, Staff Attorney at (202) 551-
3345 or Asia Timmons-Pierce, Special Counsel at (202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    CXJ
    GROUP CO., LTD.
    Room
    1903-1, No.1 building, Xizi

    International
    center

    Jianggan
    District, Hangzhou City,

    Zhejiang
    Province, China

October
30, 2020

Via
Edgar

United
State Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
DC 20549

    Attention:
    Melissa
    Gilmore

    Martin
    James

    Sherry
    Haywood

    Asia
    Timmons-Pierre

    Re:

    CXJ
    Group Co., Ltd

    Registration
    Statement on Form S-1

    Filed
    September 14, 2020

    File
    No. 333-248779

Dear
Sir or Madam:

CXJ
Group Co., Ltd. (the “Company”) is filing amendment number 1 (the “Amendment”) to the Statement on Form
S-1/A (the “Registration Statement”) in response to your recent review letter addressed to Lixin Cai, Chief Executive
Officer of the Company, dated October 11, 2020 (the “SEC Letter”). This response letter, along with the amended Registration
Statement, addresses the concerns you have expressed. The following numbered responses correspond to the comment numbers in the
SEC Letter.

Form
S-1 filed September 14, 2020

General

1.
Please update your filing to disclose the impact of the COVID-19 on your company, if material. Refer to CF Disclosure Guidance:
Topic No. 9 and 9A for additional guidance.

We
have updated the Amendment to include the impact of COVID-19 on our business.

2.
We note that page F-12 states that you are an emerging growth company. Please tell us how you determined you are an emerging growth
company as it appears your common equity securities were sold pursuant to registration statements under the Securities Act of
1933 that were declared effective in on February 12, 2004 and June 23, 2006. If you are not an emerging growth company please
revise to reflect your current status clearly.

We
have revised the Registration Statement to reflect our status as a smaller reporting company.

3.
We note that you have obtained a new CIK No. for CXJ. Please disclose where investors can find filings made by Global Entertainment
Corp.

We
have added disclosure showing that investors can find the filings of Global Entertainment Corp. at https://www.sec.gov/cgi-bin/browse-edgar?CIK=885780.

4.
Please disclose the process by which Custodian Ventures LLC became aware of the company and was appointed
custodian of the company.

We
have added disclosure to the Amendment stating that, according to David Lazar, Custodian Ventures LLC became aware of the Company
through its own due diligence. Following such, it appeared to Custodian Ventures LLC that the Company would be a good candidate
for an investment and reconstitution. Thereafter, Custodian Ventures LLC was appointed custodian of the Company via court order
on March 4, 2019. The eight judicial District Court of Nevada appointed Custodian Ventures, LLC as custodian for Global Entertainment
Corporation, proper notice having been given to the officers and directors of Global Entertainment Corporation. There was no opposition.

5.
Please advise whether you have obtained opinion from PRC counsel regarding your compliance with PRC regulations.

The
Company did not employ a PRC counsel for the compliance of PRC regulations. The Company has obtained all necessary licenses and
registered in authorities for the business operations, and can check to the National Enterprise Credit Information Publicity System
for the Company, and no non-compliance records have been noted.

6.
We note that page F-16 states that the company loaned $115,868 loan to Lixin Cai and $51,458 to New Charles Technology Group
Limited, an entity controlled by your director. Please provide your analysis on how you intend to comply with Section
13(k)(1) of the Exchange Act.

(1)
$115,868 loan to the director was recorded as of May 31, 2020. Before May 31, 2020, we have not yet set up a comprehensive internal
control system, and the amount represented the advance payment from the director on behalf of the company for business operation
purpose and we did not clear the amount as at May 31, 2020. From June 1st, 2020, we have set up a comprehensive internal control
system, the director has cleared the balance as at August 31, 2020 and the board of directors will review the financial report
and make sure we meet the latest company internal control policy every quarter.

(2)
$51,458 to New Charles Technology Group Limited mainly represents $50,000 of unpaid authorized share capital, and New Charles
Technology Group Limited will settle the outstanding balance in the coming year. For the remaining $1,458 of the balance, it represents
the registration fee paid on behalf the Company and will be settled before October 31, 2020.

The
management has put the following preventive standard operating procedures in place:

    a)
    Set
    up internal control system for payment process, protocol to identify and disclose all related companies and parties (including
    director). Subsequently, all payments to all related companies and parties (including director) must obtain the approval from
    CFO and company’s compliance officer to ensure the no loan to all related companies and parties (including director)
    and all payments to all related companies and parties (including director) (e.g., disbursement for travel expenses) are in
    compliance with Section 13(k)(1) of the Exchange Act.

    b)
    The
    Company have set up the “Code of Ethics”, the Code applies to all directors, officers, employees and outsourced
    services providers of ECXJ (both inside and outside China) for the duration of their employment and engagement. The Code is
    a guide of principles designed to help professionals conduct business honestly and with integrity, as well as behave ethically
    and incompliance with the Exchange Act. The Code is reviewed and approved by the Board of Directors from time to time.

    c)
    Provide
    internal training to directors, CFO and accounting department staff to ensure they understand Section 13(k)(1) of the Exchange
    Act as well as identify and disclose all related companies and parties (including director).

    d)
    Review
    the financial report every quarter to ensure the Company is in compliance with Section 13(k)(1) of the Exchange Act as well
    as identify and disclose all related companies and parties (including director).

Prospectus
Cover Page, page F-15.

7.
We note that your common stock is traded on the OTC Pink. Please revise your disclosure to state that the selling shareholders
must offer and sell their shares for a fixed price for the duration of the offering and disclose the price at which the selling
shareholders will offer their shares. In this regard, please revise throughout the prospectus to remove any and all indications
that selling shareholders have the ability to sell their shares at market prices, including here and pages 17 and 42.

We
have revised the disclosure throughout the Amendment to reflect that the selling shareholders must sell their shares at the fixed
price.

Corporate
History, page 5

8.
Please disclose the nature of the company’s operations from 2011 to 2019. Please disclose all of the company’s subsidiaries.
Please revise to disclose the name of the entity controlled by Custodian Ventures, LLC that transferred the company to Mr. Xinrui
Wang.

We
have included disclosure that reflects that the Company was dormant and inactive from 2001 to 2019. We have also clarified that
Custodian Ventures, LLC was itself the transferor of control of the Company.

9.
We note your disclosures on page 40. There appears to be a discrepancy in the number of shares owned by the selling shareholders.
In that regard, we note that Mr. Mao and Mr. Niu purchased a total of 1,500,000 shares of preferred stock from Mr. Wang. Is unclear
how Mr. Mao and Mr. Niu currently own 10,500,000 and 4,500,000. Please revise to clarify how many shares your selling shareholders
own and when such shares were obtained.

We
have corrected all discrepancies regarding the selling shareholder shares and disclosed when such shares were obtained.

10.
Please describe the services that Mr. Lazar rendered to the company and explain who requested those services. If Mr. Lazar owned
any other shares of Global Entertainment’s common stock prior to the appointment of Custodian Ventures, LLC as custodian,
please revise to discuss how and when he obtained those shares.

We
have revised the Registration Statement to reflect that, other than reviving the Company and getting it back to good standing,
Mr. Lazar rendered no services to the Company. The request for revival was made by Custodian Ventures, LLC, the custodian of the
Company. Custodian Ventures owned an aggregate of 21,100 shares of pre-split common stock that it purchased on the open market
in January and July of 2019.

11.
It does not appear that CXJ Technology (Hangzhou) Co., Ltd is reflected the organizational chart. Please advise.

We
have revised the organization chart throughout the Amendment.

Prospectus
Summary, page 5

12.
Please include here your telephone number. See Item 503(b) of Regulation S-K.

We
have included the Company’s phone number.

There
is a limited market for our common stock, page 15

13.
Please revise to clarify that your stock trades on the OTC Pink.

The
Amendment clarifies that the Company trades on the OTC Pink.

We
may require additional capital to support growth, page 11

14.
We note your disclosure that you may require additional funds beyond those generated by this offering. This disclosure is inappropriate
given that the company will not receive any of the proceeds raised in this offering. Please revise accordingly.

We
have removed any reference to proceeds being raised by the Company in this offering.

Market
Price For Our Common Equity and Related Stockholder Matters, page 35

15.
Please revise to provide information for each quarterly period within the two most recent fiscal years pursuant to Item 201(a)(iii)
of Regulation S-K. For each quarter in which there is no trading, please indicate that in your responsive disclosure.

We
have included the above information in the Amendment.

Directors
and Executive Officers and Corporate Governance, page 36

16.
Please disclose the name of the company founded by Ms. Luo, and the dates of Mr. Wang’s work experience at Chang Lai Chang
Wang (Hangzhou) E-commerce Co., Ltd. Please refer to Item 401(e) of Regulation S-K.

We
have added the proper information to the bios of the directors.

17.
Please revise to discuss the specific experience, qualifications, attributes or skills that led to the conclusion that Mr. Wang
should serve as a director. Please also include the names of all of your officers and directors in the table. Please refer to
Item 401(e) of Regulation S-K.

We
have added the specific skills and experience that make Mr. Wang qualified. We have also added the names of all of the officers
and directors.

Executive
Compensation, page 38

18.
You disclose that the table sets forth the compensation earned during the past two fiscal years by the person who served as your
principal executive officer at the end of 2020. Please revise to disclose the compensation for your named executive officers for
the last completed fiscal year.

We
have edited the table to reflect the last two fiscal year ends of May 2019 and May of 2020.

Recent
Sales of Unregistered Securities, page 48

19.
Please revise to indicate the section of the Securities Act of 1933 or rule under which exemption from registration is claimed
and state briefly the facts relied upon to make the exemption available. See Item 701(d) of Regulation S-K.

We
have included the exemption and applicable facts.

Note
6: Prepayment, deposits and other receivables, page F-15

20.
Please revise table to disclose the significant components of other receivables, including, for example, the amounts related to
employee receivables, VAT receivables, etc.

We
have added the table to disclose the significant components of other receivables.

Note
8. Advanced received, accrued expenses and other payables, page F-15

21.
We note the significant amount of advance payments recorded at May 31, 2020 relating to brand name management fees and prepaid
purchases of goods by customers. Please revise to disclose the amount related to each item. In addition, revise to provide the
disclosures required by ASC 606-10-50-8 and 50-9 relating to these contract liability balances.

We
have added the table to disclose the significant amount of advance payment recorded at May 31, 2020.

Exhibit
23.1, page X-1

22.
Please have your auditor revise its consent to refer to the correct date of its audit report, which we note is September 4, 2020.
In addition, revise the Expert section on page 46 to correctly indicate that the financial statements have been audited by Total
Asia Associates PLT, and not B F Borgers CPA PC.

Our
auditor has revised their consent. We have also corrected the Expert Section in the Amendment.

Exhibits

23.
Please ensure that the agreements filed as exhibits are complete, dated and executed copies that include all of the terms of the
agreement. For example, we note that Exhibit 10.6 is undated, incomplete and missing.

We
have refiled all Exhibits that were incomplete previously.

Please
direct your correspondence regarding this matter to the undersigned.

    Very
    truly yours,

    /s/
    Lixin Cai

    Lixin
    Cai

United States securities and exchange commission logo
October 11, 2020
Lixin Cai
Chairman and Chief Executive Officer
CXJ Group Co., Ltd.
Room 1903-1, No.1 building, Xizi International center
Jianggan District, Hangzhou City,
Zhejiang Province, China
Re:CXJ Group Co., Ltd
Registration Statement on Form S-1
Filed September 14, 2020
File No. 333-248779
Dear Mr. Cai:
            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 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 September 14, 2020
General
1.Please update your filing to disclose the impact of the COVID-19 on your company, if
material. Refer to CF Disclosure Guidance: Topic No. 9 and 9A for additional guidance.
2.We note that page F-12 states that you are an emerging growth company. Please tell us
how you determined you are an emerging growth company as it appears your common
equity securities were sold pursuant to registration statements under the Securities Act
1933 that were declared effective in on February 12, 2004 and June 23, 2006. If you are
not an emerging growth company please revise to reflect your current status clearly.
3.We note that you have obtained a new CIK No. for CXJ. Please disclose where investors

 FirstName LastNameLixin  Cai
 Comapany NameCXJ Group Co., Ltd.
 October 11, 2020 Page 2
 FirstName LastNameLixin  Cai
CXJ Group Co., Ltd.
October 11, 2020
Page 2
can find filings made by Global Entertainment Corp.
4.Please disclose the process by which Custodian Ventures LLC became aware of the
company and was appointed custodian of the company.
5.Please advise whether you have obtained opinion from PRC counsel regarding your
compliance with PRC regulations.
6.We note that page F-16 states that the company loaned $115,868 loan to Lixin Cai and
$51,458 to New Charles Technology Group Limited, an entity controlled by your
director. Please provide your analysis on how you intend to comply with Section 13(k)(1)
of the Exchange Act.
Prospectus Cover Page, page i
7.We note that your common stock is traded on the OTC Pink. Please revise your disclosure
to state that the selling shareholders must offer and sell their shares for a fixed price for
the duration of the offering and disclose the price at which the selling shareholders will
offer their shares. In this regard, please revise throughout the prospectus to remove any
and all indications that selling shareholders have the ability to sell their shares at market
prices, including here and pages 17 and 42.
Corporate History, page 5
8.Please disclose the nature of  the company's operations from 2011 to 2019. Please disclose
all of the company's subsidiaries. Please revise to disclose the name of the entity
controlled by Custodian Ventures, LLC that transferred the company to Mr. Xinrui
Wang.
9.We note your disclosures on page 40. There appears to be a discrepancy in the number of
shares owned by the selling shareholders. In that regard, we note that Mr. Mao and Mr.
Niu purchased a total of 1,500,000 shares of preferred stock from Mr. Wang. Is unclear
how Mr. Mao and Mr. Niu currently own 10,500,000 and 4,500,000. Please revise to
clarify how many shares your selling shareholders own and when such shares were
obtained.
10.Please describe the services that Mr. Lazar rendered to the company and explain who
requested those services.  If Mr. Lazar owned any other shares of Global Entertainment's
common stock prior to the appointment of Custodian Ventures, LLC as custodian, please
revise to discuss how and when he obtained those shares.
11.It does not appear that CXJ Technology (Hangzhou) Co., Ltd is reflected the
organizational chart. Please advise.
Prospectus Summary, page 5
12.Please include here your telephone number. See Item 503(b) of Regulation S-K.

 FirstName LastNameLixin  Cai
 Comapany NameCXJ Group Co., Ltd.
 October 11, 2020 Page 3
 FirstName LastNameLixin  Cai
CXJ Group Co., Ltd.
October 11, 2020
Page 3
There is a limited market for our common stock, page 15
13.Please revise to clarify that your stock trades on the OTC Pink.
We may require additional capital to support growth, page 11
14.We note your disclosure that you may require additional funds beyond those generated by
this offering. This disclosure is inappropriate given that the company will not receive any
of the proceeds raised in this offering. Please revise accordingly.
Market Price For Our Common Equity and Related Stockholder Matters, page 35
15.Please revise to provide information for each quarterly period within the two most recent
fiscal years pursuant to Item 201(a)(iii) of Regulation S-K.  For each quarter in which
there is no trading, please indicate that in your responsive disclosure.
Directors and Executive Officers and Corporate Governance, page 36
16.Please disclose the name of the company founded by Ms. Luo, and the dates of Mr.
Wang's work experience at Chang Lai Chang Wang (Hangzhou) E-commerce Co., Ltd.
Please refer to Item 401(e) of Regulation S-K.
17.Please revise to discuss the specific experience, qualifications, attributes or skills that led
to the conclusion that Mr. Wang should serve as a director.  Please also include the names
of all of your officers and directors in the table. Please refer to Item 401(e) of Regulation
S-K.
Executive Compensation, page 38
18.You disclose that the table sets forth the compensation earned during the past two fiscal
years by the person who served as your principal executive officer at the end of 2020.
Please revise to disclose the compensation for your named executive officers for the last
completed fiscal year.
Recent Sales of Unregistered Securities, page 48
19.Please revise to indicate the section of the Securities Act of 1933 or rule under which
exemption from registration is claimed and state briefly the facts relied upon to make the
exemption available.  See Item 701(d) of Regulation S-K.
Note 6: Prepayment, deposits and other receivables, page F-15
20.Please revise table to disclose the significant components of other receivables, including,
for example, the amounts related to employee receivables, VAT receivables, etc.
Note 8. Advanced received, accrued expenses and other payables, page F-15
21.We note the significant amount of advance payments recorded at May 31, 2020 relating

 FirstName LastNameLixin  Cai
 Comapany NameCXJ Group Co., Ltd.
 October 11, 2020 Page 4
 FirstName LastName
Lixin  Cai
CXJ Group Co., Ltd.
October 11, 2020
Page 4
to brand name management fees and prepaid purchases of goods by customers. Please
revise to disclose the amount related to each item. In addition, revise to provide the
disclosures required by ASC 606-10-50-8 and 50-9 relating to these contract liability
balances.
Exhibit 23.1, page X-1
22.Please have your auditor revise its consent to refer to the correct date of its audit report,
which we note is September 4, 2020. In addition, revise the Expert section on page 46 to
correctly indicate that the financial statements have been audited by Total Asia Associates
PLT, and not B F Borgers CPA PC.
Exhibits
23.Please ensure that the agreements filed as exhibits are complete, dated and executed
copies that include all of the terms of the agreement. For example, we note that Exhibit
10.6 is undated, incomplete and missing signature information. Please refile complete and
executed copies of your agreements.
            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.
            You may contact Melissa Gilmore, Staff Accountant, at 202-551-3777 or Martin James,
Senior Advisor, at 202-551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sherry Haywood, Staff Attorney, at 202-551-3345
or Asia Timmons-Pierce, Special Counsel, at 202-551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing