SecProbe.io

CORRESP
 1
 filename1.htm

 K-Tech Solutions Company
Limited

 Unit A, 7 / F, Mai On Industrial
Building
17 - 21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 September 19, 2025

 VIA EDGAR

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street,
NE

 Washington, D.C. 20549

 Attn: Mr. Eranga Dias

 Re:
 K-Tech Solutions Company Limited

 Registration Statement on Form F-1 (File No. 333- 290261)
 Request for Acceleration of Effectiveness

 Dear Sir,

 In accordance
with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, K-Tech Solutions Company Limited hereby
requests that the effectiveness of the above-referenced Registration Statement on Form F-1 be accelerated to and that the
Registration Statement become effective at 4:30 p.m., Eastern Time, on September 22, 2025, or as soon thereafter as practicable.

 Very truly yours,

 K-Tech Solutions Company Limited

 By:
 /s/ Kwok Yiu Keung

 Name:
 Kwok Yiu Keung

 Title:
 Chief Executive Officer and Director

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 September 8, 2025

Kwok Yiu Keung
Chief Executive Officer
K-TECH SOLUTIONS CO LTD
Unit A, 7 / F, Mai On Industrial Building
17 - 21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 Re: K-TECH SOLUTIONS CO LTD
 Draft Registration Statement on Form F-1
 Submitted September 2, 2025
 CIK No. 0002049187
Dear Kwok Yiu Keung:

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

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR 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 Eranga Dias at 202-551-8107 with any questions.

 Sincerely,

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

CORRESP
 1
 filename1.htm

 K-Tech Solutions Company Limited

 Unit A, 7/F, Mai On Industrial Building
17-21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 June 26, 2025

 U.S. Securities & Exchange Commission

 Office of Life Sciences

 Division of Corporation Finance

 100 F Street, NE

 Attn: SiSi Cheng / Andrew Blume / Sarah Sidwell / Evan Ewing

 Re:
 K-Tech Solutions Company Limited

 Registration Statement on Form F-1

 Initially Filed May 19, 2025, as amended

 File No. 333-287391

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, K-Tech Solutions Company Limited. hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4:30 p.m., Eastern Time, on June 30, 2025, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Kwok Yiu Keung

 Kwok Yiu Keung

 Chief Executive Officer

 cc:
 Loeb & Loeb LLP

 DeMint Law, PLLC

CORRESP
 1
 filename1.htm

 June 26 th , 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: K-TECH SOLUTIONS COMPANY LIMITED

 Registration Statement
on Form S-1 (File No. 333-287391) (the "Registration Statement")

 Request for Acceleration
of Effective Date

 Ladies and Gentlemen:

 In accordance with Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended, (the "Act"), American Trust Investment Services, Inc. as representative
of the underwriters of the offering, hereby joins the Company's request for acceleration of the above-referenced Registration Statement,
requesting effectiveness for 4:30 p.m., Eastern Time on June 30 th , 2025, or as soon thereafter as practicable.

 Pursuant to Rule 460 under the Securities Act,
please be advised that the underwriters have distributed as many copies of the preliminary prospectus dated May 19 th , 2025
(the "Preliminary Prospectus") to prospective underwriters and dealers, institutional investors, retail investors and others
as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

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

 If you have any questions regarding this request,
please contact our counsel Anthony DeMint of DEMINT LAW, PLLC, at 702-714-0889 or anthony@demintlaw.com.

 Very truly yours,

 American Trust Investment Services

 By:
 /s/ Kristopher Kessler

 Name:
 Kristopher Kessler

 Title:
 Managing Principal, Investment Banking

CORRESP
 1
 filename1.htm

 June 24, 2025

 Via Edgar Transmission

 Ms. Sisi Cheng / Mr. Andrew Blume

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 Washington, D.C. 20549

 Attn: Sisi Cheng / Andrew Blume / Sarah Sidwell
/ Evan Ewing

 Re:

 K-Tech Solutions Company Limited
 Amendment No. 1 to Registration Statement on Form
 F-1
 Filed on June 5, 2025
 File No. 333-287391

 Dear Sir/Madam,

 As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated June 23, 2025 from the Securities and Exchange Commission
(the " Commission ") in which the staff of the Commission (the " Staff ") commented on the above-referenced
Amendment No. 1 to Registration Statement on Form F-1 (the " Form F-1 ").

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

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

 General

 1. We note your response to prior comment 2. Please also remove the draft line from the opinion.

 Response: We noted the
Staff's comment and, in response hereto, we have removed the draft line from Harneys' opinion letter. Please refer to revised
exhibit 5.1.

 2. We note that your registration statement includes a number of blanks and omitted information. Please
provide all required missing information in your next amendment or tell us when you intend to do so. Please also confirm your understanding
that the staff will need sufficient time to review this information, and we may have additional comments at that time.

 Response: We noted the Staff's
comment and, in response hereto, we have finalized the Form F-1 by removing brackets and filling out missing information.

 Capitalization, page 51

 3. Please revise the "Amount due to related parties" figure on page 51 to agree with the amount
presented on the balance sheet on page F-23.

 Response: We noted the Staff's
comment and, in response hereto, we have revised the disclosure on page 51.

 * * *

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

 Sincerely,

 /s/ Lawrence S. Venick

 Lawrence S. Venick

 Direct Dial: +852.3923.1188

 Email: lvenick@loeb.com

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 June 23, 2025

Kwok Yiu Keung
Chief Executive Officer
K-Tech Solutions Company Limited
Unit A, 7/F, Mai On Industrial Building
17-21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 Re: K-Tech Solutions Company Limited
 Amendment No. 1 to Registration Statement on Form F-1
 Filed on June 5, 2025
 File No. 333-287391
Dear Kwok Yiu Keung:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 28, 2025
letter.

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

1. We note your response to prior comment 2. Please also remove the draft
line from the
 opinion.
2. We note that your registration statement includes a number of blanks and
omitted
 information. Please provide all required missing information in your
next
 amendment or tell us when you intend to do so. Please also confirm your
 understanding that the staff will need sufficient time to review this
information, and
 we may have additional comments at that time.
Capitalization, page 51
 June 23, 2025
Page 2

3. Please revise the "Amount due to related parties" figure on page 51 to
agree with the
 amount presented on the balance sheet on page F-23.
 Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at
202-551-3254 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Sarah Sidwell at 202-551-4733 or Evan Ewing at 202-551-5920 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Lawrence Venick
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 June 5, 2025

 Via Edgar Transmission

 Ms. Sisi Cheng / Mr. Andrew Blume

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 Washington, D.C. 20549

 Re:

 K-Tech Solutions Company Limited
 Registration Statement on Form F-1
 Filed on May 19, 2025
 File No. 333-287391

 Dear Ms. Cheng / Mr. Blume:

 As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated May 28, 2025 from the Securities and Exchange Commission
(the " Commission ") in which the staff of the Commission (the " Staff ") commented on the above-referenced
Registration Statement on Form F-1 (the " Form F-1 ").

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

 Registration Statement on Form F-1 filed May
19, 2025

 General

 1. We note your disclosure on the cover page that the underwriters have a 30 day over-allotment option,
however, we note on page 12 that they have a 45 day over-allotment option. Please revise.

 Response: We noted the
Staff's comment and, in response hereto, we have revised the disclosure on page 12.

 2. Please revise Exhibit 5.1 to cover the over-allotment option, representative warrants, and if applicable,
the shares underlying the representative warrants.

 Response: We noted the
Staff's comment and, in response hereto, we have revised exhibit 5.1.

 Capitalization, page 51

 3. Please revise your capitalization and dilution discussions and tables to reflect the latest balance
sheet date presented in the filing.

 Response: We noted the
Staff's comment and, in response hereto, we have revised the disclosure on page 51.

 Management

 Compensation of Directors and Executive Officers,
page 85

 4. Please update your compensation disclosure to reflect the fiscal year ended March 31, 2025. Refer to
Item 6.B of Form 20-F.

 Response: We noted the
Staff's comment and, in response hereto, we have revised the disclosure on page 85.

 * * *

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

 Sincerely,

 /s/ Lawrence S. Venick

 Lawrence S. Venick

 Direct Dial: +852.3923.1188

 Email: lvenick@loeb.com

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<TEXT>
 May 28, 2025

Kwok Yiu Keung
Chief Executive Officer
K-Tech Solutions Company Limited
Unit A, 7/F, Mai On Industrial Building
17-21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 Re: K-Tech Solutions Company Limited
 Registration Statement on Form F-1
 Filed on May 19, 2025
 File No. 333-287391
Dear Kwok Yiu Keung:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form F-1 filed May 19, 2025
General

1. We note your disclosure on the cover page that the underwriters have a
30 day over-
 allotment option, however, we note on page 12 that they have a 45 day
over-allotment
 option. Please revise.
2. Please revise Exhibit 5.1 to cover the over-allotment option,
representative warrants,
 and if applicable, the shares underlying the representative warrants.
Capitalization, page 51

3. Please revise your capitalization and dilution discussions and tables to
reflect the
 latest balance sheet date presented in the filing.
Management
 May 28, 2025
Page 2

Compensation of Directors and Executive Officers, page 85

4. Please update your compensation disclosure to reflect the fiscal year
ended March 31,
 2025. Refer to Item 6.B of Form 20-F.
 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 SiSi Cheng at 202-551-5004 or Andrew Blume at
202-551-3254 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Sarah Sidwell at 202-551-4733 or Evan Ewing at 202-551-5920 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Lawrence Venick
</TEXT>
</DOCUMENT>

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<TEXT>
 April 1, 2025

Kwok Yiu Keung
Chief Executive Officer
K-Tech Solutions Company Limited
Unit A, 7/F, Mai On Industrial Building
17-21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 Re: K-Tech Solutions Company Limited
 Amendment No. 2 to Draft Registration Statement on Form F-1
 Submitted on March 25, 2025
 CIK 0002049187
Dear Kwok Yiu Keung:

 We have reviewed your amended draft registration statement and have the
following
comment.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our March 21, 2025 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1
Index to Combined Financial Statements, page F-1

1. Pursuant to Item 8.A.4 of Form 20-F, please provide audited financial
statements that
 are no more than twelve months old. Alternatively, to the extent you
meet the 15-
 month criteria outlined in Instruction 2 to Item 8.A.4, file the
necessary
 representations as an exhibit to the registration statement.
 Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at
202-551-3254 if you
have questions regarding comments on the financial statements and related
matters. Please
 April 1, 2025
Page 2

contact Sarah Sidwell at 202-551-4733 or Evan Ewing at 202-551-5920 with any
other
questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
cc: Lawrence Venick
</TEXT>
</DOCUMENT>

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<TEXT>
 March 21, 2025

Kwok Yiu Keung
Chief Executive Officer
K-Tech Solutions Company Limited
Unit A, 7/F, Mai On Industrial Building
17-21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong

 Re: K-Tech Solutions Company Limited
 Amendment No. 1 to Draft Registration Statement on Form F-1
 Submitted on March 7, 2025
 CIK 0002049187
Dear Kwok Yiu Keung:

 We have reviewed your amended draft registration statement and have the
following
comment.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our January 29, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1
Management
Family Relationships, page 86

1. We note your response to our prior comment ten. Please revise to
describe the nature
 of the family relationships among the executive officers and directors.
 Please contact SiSi Cheng at 202-551-5004 or Jean Yu at 202-551-3305 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Sarah Sidwell at 202-551-4733 or Evan Ewing at 202-551-5920 with any other
questions.
 March 21, 2025
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Manufacturing
cc: Lawrence Venick
</TEXT>
</DOCUMENT>

January 29, 2025
Kwok Yiu Keung
Chief Executive Officer
K-Tech Solutions Company Limited
Unit A, 7/F, Mai On Industrial Building
17-21 Kung Yip Street, Kwai Chung
New Territories, Hong Kong
Re:K-Tech Solutions Company Limited
Draft Registration Statement on Form F-1
Submitted on January 2, 2025
CIK 0002049187
Dear Kwok Yiu Keung:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1
General
1.We note throughout your registration statement that you state you do not have
operations in mainland China. However, your website appears to indicate a production
plant in Guang Dong Province, China, and provides the contact information for such
facility next to the information for your main Hong Kong office. Please advise or
revise.
Cover Page
We note that you are issuing Representative Warrants to the Representative. Please
disclose this on the cover page and, if true, state that the warrants and the shares 2.

January 29, 2025
Page 2
underlying the warrants are also being registered in this registration statement.
Summary
The Offering, page 12
3.We note that you state the underwriters will have an option to purchase additional
Class A Shares within 30 days, however, on the cover page you state the underwriters
will have a 45 day overallotment option. Please revise.
We are exposed to risks relating to our suppliers that manufacture our products, and we may
not be able to successfully establish and operat, page 28
4.We note your disclosure on page 28 that you are dependent on Fully Starise Limited, a
third-party supplier, to manufacture and supply your products. Please expand your
disclosure to describe the material terms of your long term supply agreement and file
any material manufacturing agreements as exhibits to the registration
statement. Please also disclose the risks of this reliance and any disruptions you have
experienced due to such reliance.
Use of Proceeds, page 48
5.We note that you intend to use the proceeds from the offering for "potential
investments and/or acquisition of a factory in Vietnam and/or other South East Asian
countries." 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. Refer
to Item 3.C of Form 20-F.
Capitalization, page 50
6.Please revise the indebtedness section of the table to include both your short and long-
term bank loans, as well as amounts due to related parties.

Liquidity and Capital Resources
Cash Flows
Cash Provided by (Used in) Operating Activities, page 58
7.Your current discussion of cash flows from operating activities appears to be a
recitation of the reconciling items identified on the face of your statement of cash
flows. Please revise to discuss the material changes in the underlying drivers that
affected your operating cash flows, particularly in regard to working capital, between
periods. Refer to Section IV.B.1 of SEC Release No. 33-8350.
Business , page 67
8.We note your disclosure on page 26 that the majority of your customers reside in
Hong Kong, however, the disclosure on page 28 states that your customers are mainly
located in North America and Europe. Please revise for this inconsistency throughout
your registration statement. Additionally, please revise to provide the information
required by Item 4.B.2 of Form 20-F.
Please provide the information required by Item 4.B.4 of Form 20-F.9.

January 29, 2025
Page 3

Management
Family Relationships, page 78
10.We note your disclosure on page 78 that there are no family relationships among the
directors and executive officers, however, disclosure on page 3 indicates that Kwok
Yiu Keung and Kwok Yiu Wah are brothers. Please revise or advise as to this
inconsistency, as well as disclose any other family relationships.
Index to Combined Financial Statements, page F-1
11.Please note the financial statement updating requirements provided in Item 8.A.5
of Form 20-F.
Notes to Combined Financial Statements, page F-7
12.Please remove the brackets from all disclosures contained in the notes to the financial
statements. In this regard, we note you have included bracketed information in Note 1
with respect to the date the company acquired K-Mark Technology Limited as part of
the reorganization and in Note 11 relating to ordinary share information.

Resale Prospectus, page Alt-1
13.We note your disclosure indicating that "such sales by the selling shareholder will not
occur until after the Class A shares begin trading on Nasdaq Capital Market." Please
revise to state the price at which the initial public offering shares will be sold prior to
the sale of common stock by the selling shareholders.
14.Please revise to include a table of contents for the resale prospectus.
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page F-11
15.Please revise your revenue recognition policy to fully comply with the disclosure
objective of ASC 606-10-50. In this regard, your footnote should include more
fulsome information for users of financial statements to better understand the nature,
amount, timing, and uncertainty of revenue and cash flows arising from your contracts
with customers. For example, we were unable to find any disclosures surrounding the
nature of your performance commitments as required by ASC 606-10-50-12, in
addition to the disclosures required by ASC 606-10-50-8b and 50-9. Revise your
footnote accordingly.
Segment Reporting , page F-12
16.Please revise your segment footnote to comply with the disclosure requirement
outlined in ASC 280-10-50-21a.
            Please contact SiSi Cheng at 202-551-5004 or Jean Yu at 202-551-3305 if you have
questions regarding comments on the financial statements and related matters. Please contact
Sarah Sidwell at 202-551-4733 or Evan Ewing at 202-551-5920 with any other questions.

January 29, 2025
Page 4
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Lawrence Venick