SecProbe.io

CORRESP
 1
 filename1.htm

 Joseph Stone Capital, LLC

 585 Stewart Avenue, Suite L-60C

 Garden City, New York 11501

 1 (866) 866-1433

 July 2, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Heather Clark
 Hugh West
 Eranga Dias
 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the "Securities Act"), Joseph Stone Capital, LLC, as representative of the several
Underwriters of the offering hereby joins in the request of MaxsMaking Inc. to request acceleration of effectiveness of the above referenced
Registration Statement on Form F-1 so that it will become effective on July 3, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter
as practicable.

 The undersigned has complied
and will comply, and has been informed or will be informed by any participating dealers that they have complied or will comply, with the
requirements of Rule 15e2-8 under the Securities and Exchange Act of 1934, as amended.

 Very truly yours,

 By:
 /s/ Damian Maggio

 Name:
 Damian Maggio

 Title:
 Chief Executive Officer

 cc: Ellenoff Grossman & Schole LLP

CORRESP
 1
 filename1.htm

 MaxsMaking Inc.

 Room 903, Building 2, Kangjian Business Plaza,
No. 1288 Zhennan Road

 Putuo District, Shanghai, China, 200331

 Tel: +86 (21) 62990223

 July 2, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Heather Clark

 Hugh West

 Eranga Dias

 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, MaxsMaking Inc. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form F-1 so that it will become effective on July 3, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter as practicable.

 Very truly yours,

 /s/ Xiaozhong Lin

 Name: Xiaozhong Lin

 Title: Chief Executive Officer

 cc:

 Ellenoff Grossman & Schole LLP
 Davidoff Hutcher & Citron, LLP

CORRESP
 1
 filename1.htm

 Joseph Stone Capital, LLC

 585 Stewart Avenue, Suite L-60C

 Garden City, New York 11501

 1 (866) 866-1433

 July 2, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Heather Clark

 Hugh West

 Eranga Dias

 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Confirming a telephone conversation with Mr. Eranga Dias of the Staff,
on behalf of Joseph Stone Capital, LLC (the "Underwriter"), and with reference to the above-referenced Registration Statement
on Form F-1 (the "Registration Statement") the Underwriter hereby withdraws its acceleration request, dated July 2, 2025 in
which the Underwriter requested acceleration of the effectiveness of the Registration Statement at 5:00p.m., Eastern time, on July 2,
2025, or as soon thereafter as practicable.

 Very truly yours,

 By:
 /s/ Damian Maggio

 Name:
 Damian Maggio

 Title:
 Chief Executive Office

 cc: Ellenoff Grossman & Schole LLP

CORRESP
 1
 filename1.htm

 Joseph Stone Capital, LLC

 585 Stewart Avenue, Suite L-60C

 Garden City, New York 11501

 1 (866) 866-1433

 July 2, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Heather Clark
 Hugh West
 Eranga Dias
 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the "Securities Act"), Joseph Stone Capital, LLC, as representative of the several
Underwriters of the offering hereby joins in the request of MaxsMaking Inc. to request acceleration of effectiveness of the above referenced
Registration Statement on Form F-1 so that it will become effective on July 2, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter
as practicable.

 The undersigned has complied
and will comply, and has been informed or will be informed by any participating dealers that they have complied or will comply, with the
requirements of Rule 15e2-8 under the Securities and Exchange Act of 1934, as amended.

 Very truly yours,

 By:
 /s/ Damian Maggio

 Name:
 Damian Maggio

 Title:
 Chief Executive Officer

 cc: Ellenoff Grossman & Schole LLP

CORRESP
 1
 filename1.htm

 MaxsMaking Inc.

 Room 903, Building 2, Kangjian Business Plaza,
No. 1288 Zhennan Road

 Putuo District, Shanghai, China, 200331

 Tel: +86 (21) 62990223

 July 1, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, NE

 Washington, D.C. 20549

 Attention:
 Heather Clark

 Hugh West

 Eranga Dias

 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen,

 On June 30, 2025,
MaxsMaking Inc. requested acceleration of the effectiveness of the above-referenced Registration Statement on Form F-1 so that it would
become effective on July 1, 2025 at 5:00 p.m. Eastern Time, or as soon thereafter as practicable. We hereby withdraw our request until
further notice.

 Very truly yours,

 /s/ Xiaozhong Lin

 Xiaozhong Lin

 Chief Executive Officer

 cc:
 Ellenoff Grossman & Schole LLP
Davidoff Hutcher & Citron, LLP

CORRESP
 1
 filename1.htm

 Joseph Stone Capital, LLC

 585 Stewart Avenue, Suite L-60C

 Garden City, New York 11501

 1 (866) 866-1433

 July 1, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn:
 Heather Clark

 Hugh West

 Eranga Dias

 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Confirming a telephone conversation
with Mr. Eranga Dias of the Staff, on behalf of Joseph Stone Capital, LLC (the "Underwriter"), and with reference to the above-referenced
Registration Statement on Form F-1 (the "Registration Statement") the Underwriter hereby withdraws its acceleration request,
dated June 30, 2025 in which the Underwriter requested acceleration of the effectiveness of the Registration Statement at 5:00p.m., Eastern
time, on July 1, 2025, or as soon thereafter as practicable.

 Very truly yours,

 By:
 /s/ Damian Maggio

 Name:
 Damian Maggio

 Title:
 Chief Executive Officer

 cc: Ellenoff Grossman & Schole LLP

CORRESP
 1
 filename1.htm

 Joseph Stone Capital, LLC

 585 Stewart Avenue, Suite L-60C

 Garden City, New York 11501

 1 (866) 866-1433

 June 30, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Heather Clark

 Hugh West

 Eranga Dias

 Evan Ewing

 Re:

 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the "Securities Act"), Joseph Stone Capital, LLC, as representative of the several
Underwriters of the offering hereby joins in the request of MaxsMaking Inc. to request acceleration of effectiveness of the above referenced
Registration Statement on Form F-1 so that it will become effective on July 1, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter
as practicable.

 The undersigned has complied
and will comply, and has been informed or will be informed by any participating dealers that they have complied or will comply, with the
requirements of Rule 15e2-8 under the Securities and Exchange Act of 1934, as amended.

 Very truly yours,

 By:
 /s/ Damian Maggio

 Name:
 Damian Maggio

 Title:
 Chief Executive Officer

 cc: Ellenoff Grossman & Schole LLP

CORRESP
 1
 filename1.htm

 MaxsMaking Inc.

 Room 903, Building 2, Kangjian Business Plaza,
No. 1288 Zhennan Road

 Putuo District, Shanghai, China, 200331

 Tel: +86 (21) 62990223

 June 30, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Heather Clark

 Hugh West

 Eranga Dias

 Evan Ewing

 Re:
 MaxsMaking Inc.

 Registration Statement on Form F-1

 Initially filed on November 14, 2024, as amended

 File No. 333-283211

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, MaxsMaking Inc. hereby requests acceleration of effectiveness of the above referenced Registration
Statement on Form F-1 so that it will become effective on July 1, 2025, at 5:00 p.m. Eastern Time, or as soon thereafter as practicable.

 Very truly yours,

 /s/ Xiaozhong Lin

 Name:
 Xiaozhong Lin

 Title:
 Chief Executive Officer

 cc:

 Ellenoff Grossman & Schole LLP
 Davidoff Hutcher & Citron, LLP

CORRESP
1
filename1.htm

MaxsMaking Inc.

Room 903, Building 2, Kangjian Business Plaza

No. 1288 Zhennan Road

Putuo District, Shanghai, China, 200331

VIA EDGAR

December 3, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Heather Clark

    Hugh West

    Eranga Dias

    Evan Ewing

    Re:
    MaxsMaking Inc.

    Registration Statement on Form F-1

    Submitted November 13, 2024

    File No. 333-283211

Ladies and Gentlemen:

MaxsMaking Inc. (the “Company,”
“we,” “our” or “us”) hereby transmits our response to the comment letter received
from the staff (the “Staff”, “you” or “your”) of the U.S. Securities and Exchange
Commission (the “Commission”), dated November 27, 2024, regarding the Registration Statement on Form F-1 filed to the
Commission on November 13, 2024.

For the Staff’s convenience,
we have repeated below the Staff’s comment in bold, and have followed each comment with the Company’s response. In response
to the Staff’s comments, the Company is filing via Edgar the Amendment No.1 to the Registration Statement on Form F-1 (the “Amendment
No.1”) simultaneously with the submission of this response letter.

Registration Statement on Form F-1

Capitalization, page F-60

 1. We
note that the “As Adjusted with full Exercise of Over Allotment Option” column reflects the gross proceeds of $10,350,000
(2,300,000 shares*$4.50 per share). However, the third bullet point above states that it reflects the sale of the shares “after
deducting the underwriting discounts and commissions and estimated offering expense.” Please revise the last column in the table
to deduct these expenses.

Response:

In response to the Staff’s comment,
we have revised our disclosures under “Capitalization” section on page 60 of the Amendment No.1.

Dilution, page 61

 2. Please
tell us how you calculated that a $1.00 increase or decrease will change your as adjusted capitalization by $20,675,434. In this regard,
a $1 change in price for 2 million shares would change the capitalization by $2 million less any additional expenses. Please clarify.

Response

We
respectfully advise the Staff that the amount should be $1,820,000  instead
of $20,675,434. Accordingly, we have revised our disclosures under “Dilution” section on page 61 of the Amendment No.1.

 3. Please
tell us how your post offering as adjusted net tangible book value per share of $0.83 per share was determined.

Response:

We respectfully advise the Staff that tangible assets are calculated as total equity minus intangible assets and deferred offering cost,
amounting to $14,054,099. After dividing this amount by the total number of shares, 17,000,000, the adjusted net tangible assets book
value per share is $0.83. Please see the illustration below for our calculations.

    Adjusted Proforma

    Total equity
      14,791,732

    Intangible assets
      7,963

    Deferred offering cost
      729,670

    Tangible assets
      14,054,099

    Total shares
      17,000,000

    Adjusted net tangible assets book value per share
      0.83

Related Party Transactions, page 123

 4. Please
revise your disclosure in this section to provide information up to a more recent date as required by Item 7.B of Form 20-F

Response:

In response to the Staff’s comment,
we have revised our disclosures under “Related Party Transactions” section on page 123 of the Amendment No.1.

***

    2

We thank the Staff in advance
for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel, Wei Wang,
Esq., of Ellenoff Grossman & Schole LLP, at (212) 370-1300.

    Sincerely,

    By:
    /s/ Xiaozhong Lin

    Name:
    Xiaozhong Lin

    Title:
    Chief Executive Officer

    cc:

    Wei Wang, Esq.

    Ellenoff Grossman & Schole LLP

3

November 27, 2024
Xiaozhong Lin
Chief Executive Officer
MaxsMaking Inc.
Room 903, Building 2, Kangjian Business Plaza
No. 1288 Zhennan Road
Putuo District, Shanghai, China, 200331
Re:MaxsMaking Inc.
Registration Statement on Form F-1
Filed November 13, 2024
File No. 333-283211
Dear Xiaozhong Lin:
            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. Unless we note
otherwise, any references to prior comments are to comments in our October 28, 2024 letter.
Registration Statement on Form F-1
Capitalization, page 60
1.We note that the "As Adjusted with Full Exercise of Over Allotment Option" column
reflects the gross proceeds of $10,350,000 (2,300,000 shares *$4.50 per share).
However, the third bullet point above states that it reflects the sale of the shares "after
deducting the underwriting discounts and commissions and estimated offering
expense."  Please revise the last column in the table to deduct these expenses.
Dilution, page 61
Please tell us how you calculated that a $1.00 increase or decrease will change your as
adjusted capitalization by $20,675,434.  In this regard, a $1 change in price for 2 2.

November 27, 2024
Page 2
million shares would change the capitalization by $2 million less any additional
expenses.  Please clarify.
3.Please tell us how your post offering as adjusted net tangible book value per share of
$0.83 per share was determined.
Related Party Transactions, page 123
4.Please revise your disclosure in this section to provide information up to a more recent
date as required by Item 7.B of Form 20-F.
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Evan Ewing at 202-551-5920 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

MaxsMaking Inc.

Room 903, Building 2, Kangjian Business Plaza

No. 1288 Zhennan Road

Putuo District, Shanghai, China, 200331

VIA EDGAR

November 13, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Heather Clark

    Hugh West

    Eranga Dias

    Evan Ewing

    Re:
    MaxsMaking Inc.

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

    Submitted October 16, 2024

    CIK No. 0002008007

Ladies and Gentlemen:

MaxsMaking Inc. (the “Company,”
“we,” “our” or “us”) hereby transmits our response to the comment letter received
from the staff (the “Staff”, “you” or “your”) of the U.S. Securities and Exchange
Commission (the “Commission”), dated October 28, 2024, regarding the Amendment No. 2 to Draft Registration Statement
on Form F-1 submitted to the Commission on October 16, 2024.

For the Staff’s convenience,
we have repeated below the Staff’s comment in bold, and have followed each comment with the Company’s response. In response
to the Staff’s comment, the Company is filing via Edgar a revised registration statement on Form F-1 (the “Registration
Statement”) simultaneously with the submission of this response letter.

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

Capitalization, page F-60

    1.
    We note your disclosure on page F-24 that you received significant capital contributions subsequent to your balance sheet date. Please revise your disclosure here to include  a separate bullet describing the pro forma impact of those contributions, along with separate pro forma presentation in your table provided.

Response:

In response to the Staff’s comment,
we have revised our disclosures on page 60 of the Registration Statement.

***

We thank the Staff in advance
for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel, Wei Wang,
Esq., of Ellenoff Grossman & Schole LLP, at (212) 370-1300.

    Sincerely,

    By:
    /s/ Xiaozhong Lin

    Name:
    Xiaozhong Ling

    Title:
    Chief Executive Officer

    cc:
    Ellenoff Grossman & Schole LLP

October 28, 2024
Xiaozhong Lin
Chief Executive Officer
MaxsMaking Inc.
Room 903, Building 2, Kangjian Business Plaza
No. 1288 Zhennan Road
Putuo District, Shanghai, China, 200331
Re:MaxsMaking Inc.
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted October 16, 2024
CIK No. 0002008007
Dear Xiaozhong Lin:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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 August 13, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
Capitalization, page F-60
1.We note from your disclosure on page F-24 that you received significant capital
contributions subsequent to your balance sheet date.  Please revise your disclosure
here to include a separate bullet describing the pro forma impact of those
contributions, along with separate pro forma presentation in your table provided.
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you

October 28, 2024
Page 2
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Evan Ewing at 202-551-5920 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

August 13, 2024
Xiaozhong Lin
Chief Executive Officer
MaxsMaking Inc.
Room 903, Building 2, Kangjian Business Plaza
No. 1288 Zhennan Road
Putuo District, Shanghai, China, 200331
Re:MaxsMaking Inc.
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted July 22, 2024
CIK No. 0002008007
Dear Xiaozhong Lin:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            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 5, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Cover Page
1.We note your disclosure that “[a]s of the date of this prospectus, we have completed the
filing for this offering with the CSRC in compliance with the Trial Measures and the
CSRC has concluded the filing procedure and published the filing results on the CSRC
website on July 8, 2024.” If true, please revise to clarify that you have received all
requisite permissions and/or approvals from the CSRC.

August 13, 2024
Page 2
Capitalization, page 60
2.In addition to your short-term debt, revise your debt presentation to also include your
long-term debt.  Please note, total capitalization should be the sum of shareholders' equity
and debt, ensure your computations are correct.
Financial Statements, page F-1
3.Please update the financial statements and related disclosures included in the registration
statement in accordance with Item 8.A.5 of Form 20-F to include at least the six month
period ended April 30, 2024.
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Eranga Dias at 202-551-8107 or Evan Ewing at 202-551-5920 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
March 5, 2024
Xiaozhong Lin
Chief Executive Officer
MaxsMaking Inc.
Room 903, Building 2, Kangjian Business Plaza
No. 1288 Zhennan Road
Putuo District, Shanghai, China, 200331
Re:MaxsMaking Inc.
Draft Registration Statement on Form F-1
Submitted February 7, 2024
CIK No. 0002008007
Dear Xiaozhong Lin:
            We have reviewed your draft registration statement and have the following comment(s).
            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 Filed February 7, 2024
Cover Page
1.Clearly disclose how you will refer to the holding company, subsidiaries, and other
entities when providing the disclosure throughout the document so that it is clear to
investors which entity the disclosure is referencing and which subsidiaries or entities are
conducting the business operations. Refrain from using terms such as “we” or “our” when
describing activities or functions of a subsidiary or other entity. Disclose clearly the entity
(including the domicile) in which investors are purchasing an interest.
Risks Related to Doing Business in China, page 6
2.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or having the majority of the company’s operations in China poses to investors.
In particular, describe the significant regulatory, liquidity, and enforcement risks with

 FirstName LastNameXiaozhong Lin
 Comapany NameMaxsMaking Inc.
 March 5, 2024 Page 2
 FirstName LastName
Xiaozhong Lin
MaxsMaking Inc.
March 5, 2024
Page 2
cross-references to the more detailed discussion of these risks in the prospectus. For
example, specifically discuss risks arising from the legal system in China, including risks
and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of the
securities you are registering for sale. Acknowledge any risks that any actions by the
Chinese government to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.
Risk Factors, page 18
3.Given the Chinese government’s significant oversight and discretion over the conduct and
operations of your business, please revise to describe any material impact that
intervention, influence, or control by the Chinese government has or may have on your
business or on the value of your securities. Highlight separately the risk that the Chinese
government may intervene or influence your operations at any time, which could result in
a material change in your operations and/or the value of your securities. Also, given recent
statements by the Chinese government indicating an intent to exert more oversight and
control over offerings that are conducted overseas and/or foreign investment in China-
based issuers, acknowledge the risk that any such action could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless. We remind you
that, pursuant to federal securities rules, the term “control” (including the terms
“controlling,” “controlled by,” and “under common control with”) means “the possession,
direct or indirect, of the power to direct or cause the direction of the management and
policies of a person, whether through the ownership of voting securities, by contract, or
otherwise.”
Our leased property interests and title to certain land and buildings we own may be defective...,
page 33
4.We note your disclosure that "our lease contract may be deemed invalid because the lessor
does not have the legal title certificate." Please update your disclosure to identify actions
planned or taken, if any, to mitigate this risk.

 FirstName LastNameXiaozhong Lin
 Comapany NameMaxsMaking Inc.
 March 5, 2024 Page 3
 FirstName LastName
Xiaozhong Lin
MaxsMaking Inc.
March 5, 2024
Page 3
We depend on a few major customers..., page 36
5.We note your disclosure that "[f]our major customers, each accounting for more than 10%
of our total revenue individually, contributed to an aggregate of 27.28% of our revenue for
the fiscal year ended October 31, 2023." Please revise or clarify.
Our business is sensitive to economic conditions..., page 37
6.We note your disclosure stating that your business is sensitive to economic conditions,
including inflation. We also note your disclosure on page 70 stating that the decrease in
revenue during your most recent fiscal year is attributed to, among other factors,
inflation. Please update this risk factor if recent inflationary pressures have materially
impacted your operations. In this regard, identify the types of inflationary pressures you
are facing and how your business has been affected. In addition, identify actions planned
or taken, if any, to mitigate inflationary pressures.
Use of Proceeds, page 58
7.We note that you intend to use the proceeds from this offering, among other purposes, for
the construction of production facilities and expansion of your scale of production through
upgrades and purchases of new production equipment. 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. Refer to Item 3.C. of Form 20-F.
Our ability to effectively manage our supply chain, page 69
8.We note your disclosure that "global lockdowns and transport restrictions caused
disruptions in supply chain and logistics during the fiscal year ended October 31, 2023,
which adversely affected our raw material procurement and product sales." Specify
whether these challenges have materially impacted your results of operations or capital
resources and quantify, to the extent possible, how your sales, profits, and/or liquidity
have been impacted.
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Eranga Dias at 202-551-8107 or Evan Ewing at 202-551-5920 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing