SecProbe.io

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 JIADE LIMITED

 August 18, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:

 Nicholas Nalbantian

 Re:
 JIADE LIMITED

 Registration Statement on Form F-1(File No. 333-289601)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, JIADE LIMITED hereby requests that the effectiveness of the above-referenced
Registration Statement on Form F-1 (the "Registration Statement") be accelerated and that the Registration Statement
become effective at 5:00 p.m., Eastern Time, on August 20, 2025, or as soon thereafter as practicable.

 Very truly yours,

 JIADE LIMITED.

 By:
 /s/ Yuan Li

 Name:
 Yuan Li

 Title:
 Co-Chief Executive Officer, President, and Chairman of the Board of Directors

 cc:
 Ying Li, Esq.

 Hunter Taubman Fischer & Li LLC

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 10, 2025

Yuan Li
Co-Chief Executive Officer
JIADE Ltd
18/F, Block D, Huirong Plaza, No. 88, Section 3, Jinhua Road
Jinjiang District, Chengdu City, Sichuan Province
The People s Republic of China, 610000

 Re: JIADE Ltd
 Draft Registration Statement on Form F-1
 Submitted July 3, 2025
 CIK No. 0001976908
Dear Yuan Li:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement at least
two business
days prior to the requested effective date and time. Please refer to Rules 460
and 461
regarding requests for acceleration. We remind you that the company and its
management are
responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review,
comments, action or absence of action by the staff.

 Please contact Nicholas Nalbantian at 202-551-7470 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Ying Li
</TEXT>
</DOCUMENT>

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May 10, 2024

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick
Kuhn

    Joel Parker

    Rucha Pandit

    Lilyanna Peyser

    Re:
    JIADE LIMITED

    Registration Statement on Form F-1, as amended (File No. 333-276283)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Jiade
Limited (the “Company”) for acceleration of the effective date of the above-named Registration Statement so that it becomes
effective at 4:30 p.m., Eastern Time, on May 14, 2024, or as soon thereafter as practicable, or at such other time thereafter as
the Company or its outside counsel, Hunter Taubman Fischer & Li LLC, request by telephone that such Registration Statement be
declared effective.

Pursuant to Rule 460 under the Act, please
be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to underwriters, dealers,
institutions and others, prior to the requested effective time of the Registration Statement.

We, the undersigned, as the representatives of
the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied
and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

    Very truly yours,

    WESTPARK CAPITAL, INC.

    As representatives of the several underwriters listed in Exhibit A
    to the Underwriting Agreement

    JIADE LIMITED

    By:
    /s/ Jason Stern

    Name:
    Jason Stern

    Title:
    Chief Operating Officer

    cc:

    Ying Li, Esq.

    Kanxian Ding, Esq.

    Hunter Taubman Fischer & Li LLC

    Mark Li, Esq.

    Jonathan (Xiaochun).Jiang, Esq.

    Magstone Law LLP

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JIADE LIMITED

May 10, 2024

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick Kuhn

    Joel Parker

    Rucha Pandit

    Lilyanna Peyser

    Re:
    JIADE LIMITED

    Registration Statement on Form F-1, as amended (File No. 333-276283)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of the
General Rules and Regulations under the Securities Act of 1933, as amended, JIADE LIMITED hereby requests that the
effectiveness of the above-referenced Registration Statement on Form F-1 (the “Registration Statement”) be
accelerated and that the Registration Statement become effective at 4:30 p.m., Eastern Time, on May 14, 2024, or as soon
thereafter as practicable.

    Very truly yours,

    JIADE LIMITED

    By:
    /s/ Yuan Li

    Name:
     Yuan Li

    Title:
     Chief Executive Officer

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

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JIADE LIMITED

March 11, 2024

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick
Kuhn

    Joel Parker

    Rucha Pandit

    Lilyanna Peyser

    Re:
    JIADE LIMITED

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

    Filed
February 15, 2024

    File No. 333-276283

Ladies and Gentlemen:

This
letter is in response to the letter dated March 8, 2024, from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) addressed to JIADE LIMITED (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly. An amended Registration
Statement on Form F-1 (the “Amended Registration Statement No. 3”) is being filed to accompany this letter.

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

Rale Prospectus - Selling Shareholder, page 3

1. Please revise to disclose whether Ms. Suetmui
Lee has had a material relationship with the registrant or any of its predecessors or affiliates within three years prior to the fling
of the registration statement. Refer to Item 507 of Regulation S-K. Also revise to disclose when and under what circumstances the selling
shareholder received its shares of the registrant that are intended to be part of the resale transaction, as well as whether the selling
shareholder is a broker-dealer, affiliate of a broker-dealer, or otherwise in the business of underwriting securities.

In
response to the Staff’s comments, we have revised our disclosure on page 3 of the Resale Prospectus of the Amended Registration
Statement No. 3 to confirm that Ms. Suetmui Lee has not had a material relationship with the Company within the past three years.
In addition, we have revised our disclosure on page 3 of the Resale Prospectus of the Amended Registration Statement No. 3 to
disclose that on June 30, 2023, we entered into a share swap agreement with the selling shareholder,
WISMASS INTERNATIONAL HOLDING LIMITED, to acquire 100% of the equity interests in WISMASS HK (as defined in the Public Offering
Prospectus) from WISMASS INTERNATIONAL HOLDING LIMITED in exchange for 4,035,471 newly issued Ordinary Shares of the Company, through
which WISMASS INTERNATIONAL HOLDING LIMITED holds 4,035,471 ordinary shares of the Company as of the date of this response letter. Furthermore,
we have revised our disclosure on page 3 of the Resale Prospectus of the Amended Registration Statement No. 3 to confirm that
the selling shareholder is not a broker-dealer, affiliate of a broker-dealer, or otherwise in the business of underwriting securities.

General

2. Please revise the prospectus cover page of
the primary offering to disclose the number of shares being sold in the resale offering, and disclose on the prospectus cover page of
the resale offering the number of shares being sold in the primary offering.

In response to the Staff’s comments, we
have revised our disclosure on the cover page of the Public Offering Prospectus of the Amended Registration Statement No. 3
to disclose the number of shares being sold in the resale offering. In addition, we have revised our disclosure on the cover page of
the Resale Prospectus of the Amended Registration Statement No. 3 to disclose the number of shares being sold in the primary offering.

Resale Prospectus Cover Page

3. We note the disclosure on the prospectus
cover page of the resale offering that "[i]t is a condition to the closing of this offering that the Ordinary Shares qualify
for listing on a national securities exchange," thereby indicating that sales in the resale offering will not take place until after
the completion of your initial public offering and your listing. Please reconcile this with your disclosure on the prospectus cover page of
the resale offering and in the Selling Shareholder's Plan of Distribution section that the selling shareholder "will sell at the
price at which we sell Ordinary Shares in our public offering," and then sell at prevailing market prices "[o]nce, and if, our
Ordinary Shares are listed on the Nasdaq...and there is an established market," as well as your disclosure on pages 1 and 3
of the resale prospectus that both offerings will take place "concurrently." Make conforming changes throughout the filing,
as appropriate.

In response to the Staff’s comments, we
have revised our disclosure on the cover page of the Resale Prospectus of the Amended Registration Statement No. 3 to clarify
that the selling shareholder will not offer for sale the resale ordinary shares (the “Resale Shares”) covered by the Resale
Prospectus until such time as the Company’s ordinary shares are listed on the Nasdaq Capital Market and the Resale Shares may be
sold at prevailing market prices, prices related to prevailing market prices, or privately negotiated prices. In addition, we have revised
our disclosure on pages 1 and 3 of the Resale Prospectus of the Amended Registration Statement No. 3 to conform to the above
disclosure.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Yuan Li

    Name:
    Yuan Li

    Title:
    Chief Executive Officer

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
March 8, 2024
Yuan Li
Chief Executive Officer
JIADE LIMITED
Unit 2-02, Puningdun Business Plaza
No. 1702 and 1706 Minjiang Road
Jinjiang District, Chengdu City, Sichuan Province
The People’s Republic of China, 610000
Re:JIADE LIMITED
Amendment No. 2 to Registration Statement on Form F-1
Filed February 15, 2024
File No. 333-276283
Dear Yuan Li:
            We have reviewed your amended registration statement and have the following
comment(s).
            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 F-1
Resale Prospectus - Selling Shareholder, page 3
1.Please revise to disclose whether Ms. Suetmui Lee has had a material relationship with the
registrant or any of its predecessors or affiliates within three years prior to the fling of the
registration statement. Refer to Item 507 of Regulation S-K. Also revise to disclose when
and under what circumstances the selling shareholder received its shares of the registrant
that are intended to be part of the resale transaction, as well as whether the selling
shareholder is a broker-dealer, affiliate of a broker-dealer, or otherwise in the business of
underwriting securities.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 March 8, 2024 Page 2
 FirstName LastName
Yuan Li
JIADE LIMITED
March 8, 2024
Page 2
General
2.Please revise the prospectus cover page of the primary offering to disclose the number of
shares being sold in the resale offering, and disclose on the prospectus cover page of the
resale offering the number of shares being sold in the primary offering.
Resale Prospectus Cover Page
3.We note the disclosure on the prospectus cover page of the resale offering that "[i]t is a
condition to the closing of this offering that the Ordinary Shares qualify for listing on a
national securities exchange," thereby indicating that sales in the resale offering will not
take place until after the completion of your initial public offering and your listing. Please
reconcile this with your disclosure on the prospectus cover page of the resale offering
and in the Selling Shareholder's Plan of Distribution section that the selling shareholder
"will sell at the price at which we sell Ordinary Shares in our public offering," and then
sell at prevailing market prices "[o]nce, and if, our Ordinary Shares are listed on the
Nasdaq...and there is an established market," as well as your disclosure on pages 1 and 3
of the resale prospectus that both offerings will take place "concurrently." Make
conforming changes throughout the filing, as appropriate.
            Please contact Patrick Kuhn at 202-551-3308 or Joel Parker at 202-551-3651 if you have
questions regarding comments on the financial statements and related matters. Please contact
Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lisa Forcht

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JIADE LIMITED

February 15, 2024

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick
Kuhn

    Joel Parker

    Rucha Pandit

    Lilyanna Peyser

    Re:
    JIADE LIMITED

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

    Filed January 26, 2024

    File No. 333-276283

Ladies and Gentlemen:

This
letter is in response to the letter dated February 14, 2024, from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) addressed to JIADE LIMITED (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Commission’s comments in this response. An amended Registration Statement on Form F-1
(the “Amended Registration Statement No. 2”) is being filed to accompany this letter.

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

Exhibit 5.1

1. Please revise the legal opinion to cover the shares
being registered for resale by the selling

stockholder.

In
response to the Staff’s comments, we have revised the opinion of Maples and Calder (Hong Kong) LLP, attached as Exhibit 5.1
to the Amended Registration Statement No. 2, to cover the shares being registered for resale by the selling shareholder.

We appreciate the assistance the Staff
has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman
Fischer & Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Yuan Li

    Name:
    Yuan Li

    Title:
    Chief Executive Officer

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
February 14, 2024
Yuan Li
Chief Executive Officer
JIADE LIMITED
Unit 2-02, Puningdun Business Plaza
No. 1702 and 1706 Minjiang Road
Jinjiang District, Chengdu City, Sichuan Province
The People’s Republic of China, 610000
Re:JIADE LIMITED
Amendment No. 1 to Registration Statement on Form F-1
Filed January 26, 2024
File No. 333-276283
Dear Yuan Li:
            We have reviewed your amended registration statement and have the following
comment(s).
            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. 1 to Registration Statement on Form F-1
Exhibit 5.1
1.Please revise the legal opinion to cover the shares being registered for resale by the selling
stockholder.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 February 14, 2024 Page 2
 FirstName LastName
Yuan Li
JIADE LIMITED
February 14, 2024
Page 2
            Please contact Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lisa Forcht

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JIADE LIMITED

January 26, 2024

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
     Patrick Kuhn

    Joel Parker

    Rucha Pandit

    Lilyanna Peyser

    Re:
    JIADE LIMITED

    Registration Statement on Form F-1

    Filed December 27, 2023

    File No. 333-276283

Ladies and Gentlemen:

This letter is in response to the letter dated
January 23, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to JIADE LIMITED (the “Company,” “we,” and “our”). For ease of reference, we have recited
the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement on Form F-1 (the
 “Amended Registration Statement”) is being filed to accompany this letter.

Registration Statement on Form F-1

Resale Prospectus - Prospectus Cover Page,
page A-1

1. Please revise the prospectus cover page of the resale prospectus
to include the disclosure that appears on the prospectus cover page of the Public Offering Prospectus regarding your status as a
China based issuer. Refer to the Sample Letter to China Based Companies for guidance.

In response to the Staff’s comments, we
have revised our disclosure on the cover page of the Resale Prospectus of the Amended Registration Statement to include the disclosure
that appears on the cover page of the Public Offering Prospectus regarding our status as a China based issuer.

General

2. Please update your financial statements, or file as an exhibit
to the filing the necessary representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction
2 thereto.

In response to the Staff’s comments,
we have filed Exhibit 99.8 to request that the Commission waive the requirement of Item 8.A.4 of Form 20-F and confirm that we
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.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Yuan Li

    Name:
    Yuan Li

    Title:
    Chief Executive Officer

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
January 23, 2024
Yuan Li
Chief Executive Officer
JIADE LIMITED
Unit 2-02, Puningdun Business Plaza
No. 1702 and 1706 Minjiang Road
Jinjiang District, Chengdu City, Sichuan Province
The People’s Republic of China, 610000
Re:JIADE LIMITED
Registration Statement on Form F-1
Filed December 27, 2023
File No. 333-276283
Dear Yuan Li:
            We have reviewed your registration statement and have the following comment(s).
            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
Resale Prospectus - Prospectus Cover Page, page A-1
1.Please revise the prospectus cover page of the resale prospectus to include the disclosure
that appears on the prospectus cover page of the Public Offering Prospectus regarding
your status as a China based issuer. Refer to the Sample Letter to China Based
Companies for guidance.
General
2.Please update your financial statements, or file as an exhibit to the filing the necessary
representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F
and Instruction 2 thereto.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 January 23, 2024 Page 2
 FirstName LastName
Yuan Li
JIADE LIMITED
January 23, 2024
Page 2
            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 Patrick Kuhn at 202-551-3308 or Joel Parker at 202-551-3651 if you have
questions regarding comments on the financial statements and related matters. Please contact
Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lisa Forcht

United States securities and exchange commission logo
October 18, 2023
Yuan Li
Chief Executive Officer
JIADE LIMITED
Unit 2-02, Puningdun Business Plaza
No. 1702 and 1706 Minjiang Road
Jinjiang District, Chengdu City, Sichuan Province
The People’s Republic of China, 610000
Re:JIADE LIMITED
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted September 21, 2023
CIK No. 0001976908
Dear Yuan Li:
            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.
Amendment No. 1 to Draft Registration Statement on Form F-1
Cover Page
1.We note your response to comment 4.  It appears that the discussion of the consequences
of your failure to "receive or maintain such approval, or [of] inadvertently
conclud[ing] that such approval is not required, or [of a change in] applicable laws,
regulations, or interpretations" is limited to laws that "PRC regulatory authorities may in
the future promulgate."  Here and on page 2 please revise to clarify that the consequences
also apply with respect to the laws that are currently in effect.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 October 18, 2023 Page 2
 FirstName LastName
Yuan Li
JIADE LIMITED
October 18, 2023
Page 2
Capitalization, page 2
2.Please remove the as adjusted (over-allotment option exercised column) from your
capitalization table.
Risk Factors, page 14
3.We note your response to comment 1 that your "largest shareholder, Mr. Yuan Li, will
hold approximately 47% of the aggregate voting power of [the] issued and outstanding
ordinary shares, assuming no exercise of the underwriters’ over-allotment option."  Please
include a risk factor discussing the influence that Mr. Li will have on the company and
matters to be decided by stockholders, or tell us why such disclosure is inappropriate.
Related Party Transactions, page 105
4.We note your response to comment 20.  It appears that this section speaks as of June 30,
2023; please revise to provide the disclosure as of the date of the prospectus.
Notes to Consolidated Financial Statements
Note 2 - Summary of significant accounting policies
Revenue recognition, page F-12
5.We note your response to prior comment 22.  The transaction price of your
customer contracts appears to depend on the number of students serviced per page 59 and
60.  Please disclose how you determine the transaction price for your contracts and at
what point during the contract you bill your customers.  Refer to ASC 606-10-50-12 and
20.
General
6.We note your response to comment 24 and reissue in part.  Please further revise your
disclosure on page 30 and elsewhere as appropriate to specifically discuss the role of the
board of directors in overseeing cybersecurity threats and managing the related risks,
including in connection with the company's software and data protection.
            Please contact Patrick Kuhn at 202-551-3308 or Joel Parker at 202-551-3651 if you have
questions regarding comments on the financial statements and related matters. Please contact
Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lisa Forcht

United States securities and exchange commission logo
August 31, 2023
Yuan Li
Chief Executive Officer
JIADE LIMITED
Unit 2-02, Puningdun Business Plaza
No. 1702 and 1706 Minjiang Road
Jinjiang District, Chengdu City, Sichuan Province
The People’s Republic of China, 610000
Re:JIADE LIMITED
Draft Registration Statement on Form F-1
Submitted August 3, 2023
CIK No. 0001976908
Dear Yuan Li:
            We have reviewed your draft 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 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 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1
Cover Page
1.We note that you intend to be listed on the Nasdaq Capital Market and that "insiders will
hold a large portion of [y]our listed securities."  Please tell us whether you will be deemed
a “controlled company” as defined by Nasdaq and, if so, whether you intend to rely on
any exemptions as a controlled company.  To the extent applicable, please disclose here
and in the prospectus summary that you are a controlled company, identify the person(s)
who will control the company and their ownership percentages, and include a risk factor
that discusses the effect, risks and uncertainties of being a controlled company.  In

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 August 31, 2023 Page 2
 FirstName LastName
Yuan Li
JIADE LIMITED
August 31, 2023
Page 2
addition, to the extent that a small group of insiders will be able to control all or some of
the matters subject to shareholder approval, please include a risk factor discussing the
associated risks.
2.We note your representation that you are "are an exempted company with limited liability
incorporated in the Cayman Islands with no material operations of [y]our own and are not
a Chinese operating company."  Please revise your disclosure here to explicitly state
that this structure involves unique risks to investors.
3.We note your disclosure here, and similar disclosure elsewhere in your prospectus, that
your ordinary shares may be prohibited from trading if the PCAOB "is unable to inspect
[y]our auditors for three consecutive years."  Please revise this paragraph to refer to the
inspection rules as they are currently in effect.
4.Here and in the prospectus summary you disclose the consequences if you do not
receive/maintain the required approvals to list in the U.S.  Please expand this discussion of
consequences to clarify that it also applies if you do not receive/maintain the
required permissions and approvals to operate your business or offer your securities.
Conventions that Apply to this Prospectus, page ii
5.Please define "adult education institutions" as you use the term in the prospectus.
Permissions or Approval Required from the PRC Authorities for Our Operations and Offering,
page 8
6.Please revise to state here, as you do on the cover page, that your counsel confirmed that
you are not subject to cybersecurity review or network data review by the CAC.  Please
also revise to state, if true, that other than the CSRC review, you are not required
to obtain, nor have you been denied, any other approval, licenses, or permits from PRC
governmental authorities to offer your securities.

Dividends or Distributions Made to Our Company and U.S. Investors and Tax Consequences,
page 9
7.Please revise the disclosure here to provide a cross-reference to the consolidated financial
statements.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 August 31, 2023 Page 3
 FirstName LastName
Yuan Li
JIADE LIMITED
August 31, 2023
Page 3
Risk Factors, page 16
8.We note your disclosure on page F-25 that "[l]oans issued at variable rates and fixed rates
expose [you] to cash flow interest rate risk and fair value interest rate
risk respectively."  To the extent material, please revise your summary risk factors and
risk factors sections to specifically identify such interest rate risks.  In your risk factor
disclosure, please discuss the impact of any rate increases on your operations and how
your business has been affected.  For example, describe whether your borrowing costs
have recently increased or are expected to increase and your ability to pass along your
increased costs to your customers.
9.To the extent applicable, please update your risk factors to disclose how recent
inflationary pressures have materially impacted your business and operations.  For
example, identify the types of inflationary pressures you are facing and how your business
has been affected.
Increases in labor costs in the PRC may adversely affect our PRC subsidiaries' business and
profitability, page 23
10.We note your disclosure that the "average wage level for [y]our PRC subsidiaries’
employees has also increased in recent years."  To the extent material, please quantify the
impact of increased labor costs on your business and explain whether any mitigation
efforts introduce new material risks.
Our PRC subsidiaries may fail to protect their intellectual property, page 23
11.We note your disclosure here that your "PRC subsidiaries have already acquired 23
software copyrights and are anticipating certification for an additional 10 software
copyrights."  However, we also note your disclosure on pages 3, 33, 57, 73, 74, 81, 83 and
89 that your PRC subsidiaries have acquired "31 software copyrights."  Please revise your
disclosure to reconcile this discrepancy.
Our PRC subsidiaries face risks related to natural disasters, health epidemics . . ., page 38
12.We note your disclosure here and on page 58 that "[d]uring the years ended December 31,
2021 and 2022, [y]our PRC subsidiaries’ business was moderately impacted by the
COVID-19 pandemic," including that it "reduced demand for adult education training and
examinations, and disrupted logistics, moderately affected [y]our PRC subsidiaries’
business, financial condition, and results of operations."  Please expand your disclosure
here and elsewhere as appropriate to quantify this impact on your revenue or results of
operations during the years ended 2021 and 2022.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 August 31, 2023 Page 4
 FirstName LastName
Yuan Li
JIADE LIMITED
August 31, 2023
Page 4
Use of Proceeds, page 50
13.We note this is a best efforts offering with a finite offering period.  Please tell us what
consideration you gave to revising the disclosure here to provide use of proceeds
information for varying levels of proceeds raised in this offering.
14.We note that you plan to use approximately 40% of the net proceeds from this offering for
"acquiring vocational education and training institutions . . . and establishing ten to eight
examination centers."  If the proceeds are being used directly or indirectly
to acquire assets, other than in the ordinary course of business, briefly describe the assets
and their cost.  If the assets will be acquired from affiliates of the company or their
associates, disclose the persons from whom they will be acquired and how the cost to the
company will be determined.  Further, if the proceeds may or will be used to finance
acquisitions of other businesses, give a brief description of such businesses and
information on the status of the acquisitions.  Refer to Part I, Item 4.a of Form F-1 and
Part I, Item 3.C of Form 20-F.
Capitalization, page 53
15.Please revise to include indebtedness in your capitalization.  Refer to Item 3B of Form 20-
F.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 59
16.Please provide a more fulsome discussion of your operating results including quantitative
and qualitative description of the reasons underlying material changes.  For example, your
discussion of the 86% increase in selling expenses repeats changes disclosed in the
provided table but does not discuss the factors underlying those increases.  In addition,
for each of your revenue by type presented in the table on page 60 you do not disclose the
reason for the increase in the number of students.  Revise your discussion as appropriate.
Refer to Item 5 of Form 20-F.
Critical Accounting Estimates, page 67
17.You disclose that you have determined there were no critical accounting estimates.  You
also disclose that you make judgments, estimates, and assumptions that affect your
reported amount of assets, liabilities, revenue, costs and expenses and that you believe that
the estimates include useful lives of property and equipment and intangible assets, the
incremental borrowing rate used in operating lease right-of-use assets and lease liabilities,
the valuation of accounts receivable, the recoverability of long-lived assets, contingencies
and realization of deferred tax assets.  This appears to contradict your disclosure that you
have determined there were no critical accounting estimates.  Please explain to us how
you determined that you had no critical accounting estimates.  Refer to Item 5E of Form
20-F.

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 August 31, 2023 Page 5
 FirstName LastNameYuan Li
JIADE LIMITED
August 31, 2023
Page 5
Industry, page 68
18.We note the industry data presented here provides metrics up to and including 2021.
Given that you commissioned the Frost & Sulliven report in February 2023 and your
financial statements include information for the year ended December 31, 2022, please
update your Industry section to include industry data for 2022.  Alternatively, please
explain why presenting industry data through 2021 is meaningful to investors.
Customers, page 76
19.We note your disclosure here and on page 34 that "[f]or the year ended December 31,
2021, the top three customers of [y]our PRC subsidiaries accounted for 59%, 19%, and
11% of [y]our total revenue, respectively.  During the year ended December 31, 2022, the
top three customers of [y]our PRC subsidiaries accounted for 50%, 19%, and 8% of [y]our
total revenue, respectively."  In the interest of enhancing investors' understanding of your
business, please tell us what consideration you gave to identifying these customers on
whom your business materially depends.
Related Party Transactions, page 104
20.Please revise this section through the date of the prospectus.  Refer to Item 7.B of Form
20-F.
Where You Can Find Additional Information, page 139
21.Please update your disclosure to include your internet address.  Refer to Item 4(e) of Form
F-1.
Notes to Consolidated Financial Statements
Note 2 - Summary of significant accounting policies
Revenue recognition, page F-12
22.Please more specifically clarify for us the nature of the underlying services you
provide and who your customer is when you have provided these services.  We note from
your disclosure that these services may include online services offered through the KB
Platform and offline services such as tutoring, exam administration services, and guidance
on graduation thesis preparation.  To help us better understand the nature of such
arrangements, describe for us in detail the significant terms of the contracts.  As part of
your response, please describe for us:
•who your customer(s) is in the arrangement;
•the goods and/or services that are promised to your customer(s);
•whether the goods and/or services represent one or multiple performance obligations;
and
•when the performance obligation(s) is satisfied.
General

 FirstName LastNameYuan Li
 Comapany NameJIADE LIMITED
 August 31, 2023 Page 6
 FirstName LastName
Yuan Li
JIADE LIMITED
August 31, 2023
Page 6
23.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 the staff member associated with the review of this filing
to discuss how to submit the materials, if any, to us for our review.
24.We note your disclosure on page 32 that your business relies on the uninterrupted
functioning of your technology infrastructure which, in turn, "is potentially vulnerable to
damages or interruptions."  In an appropriate place, please describe any processes for
assessing, identifying and managing material risks from cybersecurity threats, as well
as the extent and nature of the role of the board of directors in overseeing cybersecurity
threats and managing the related risks, including in connection with the company's
software and data protection.
            You may contact Patrick Kuhn at (202) 551-3308 or Joel Parker at (202) 551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Rucha Pandit at (202) 551-6022 or Lilyanna Peyser at (202) 551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lisa Forcht