SecProbe.io

CORRESP
 1
 filename1.htm

 December
1, 2025

 Via
EDGAR

 Division
of Corporation Finance

 Securities
and Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Matthew M. Derby

 Re:
 3
 E Network Technology Group Limited

 Registration
 Statement on Form F-1
 Filed
 November 25, 2025
 File
 No. 333-291769

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations of the United States Securities and Exchange Commission (the " Commission ")
promulgated under the Securities Act of 1933, as amended, 3 E Network Technology Group Limited (the " Company ") hereby
respectfully requests that the effectiveness of the above-referenced Registration Statement on Form F-1, File No. 333-291769, be accelerated
by the Commission so that it will become effective at 4:00 p.m., Eastern Time, on December 3, 2025, or as soon thereafter as practicable,
unless the Company notifies you otherwise prior to such time.

 Please
contact Richard J. Chang of Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP at +8610 5680 3969 or rchang@gunder.com
with any questions you may have. In addition, please notify Mr. Chang when this request for acceleration has been granted.

 [Signature
page follows ]

 Yours sincerely,

 3 E Network Technology Group Limited

 By:
 /s/
 Tingjun Yang

 Name:
 Tingjun
 Yang

 Title:
 Chief
 Executive Officer

 cc:
 Richard
 J. Chang

 Gunderson
 Dettmer Stough Villeneuve Franklin & Hachigian, LLP

CORRESP
 1
 filename1.htm

 July 3, 2025

 Via EDGAR

 Division of Corporation Finance

 Office of Technology

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Jeff Kauten

 Re:
 3 E Network Technology Group Limited

 Registration Statement on Form F-1
 Filed June 24, 2025
 File No. 333-288294

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the
General Rules and Regulations of the United States Securities and Exchange Commission (the " Commission ") promulgated
under the Securities Act of 1933, as amended, 3 E Network Technology Group Limited (the " Company ") hereby respectfully
requests that the effectiveness of the above-referenced Registration Statement on Form F-1, File No. 333-288294, be accelerated by the
Commission so that it will become effective at 4:00 p.m., Eastern Time, on July 7, 2025, or as soon thereafter as practicable, unless
the Company notifies you otherwise prior to such time.

 Please contact Richard J.
Chang of Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP at +8610 5680 3969 or rchang@gunder.com with any questions
you may have. In addition, please notify Mr. Chang when this request for acceleration has been granted.

 [Signature page follows ]

 Yours sincerely,

 3 E Network Technology Group Limited

 By:
 /s/ Tingjun Yang

 Name:
 Tingjun Yang

 Title:
 Chief Executive Officer

 cc:
 Richard J. Chang

 Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP

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

Tingjun Yang
Chief Executive Officer
3 E Network Technology Group Limited
Unit 1904, 19/F., Podium Plaza, 5 Hanoi Road
Tsim Sha Tsui, Kowloon Hong Kong

 Re: 3 E Network Technology Group Limited
 Registration Statement on Form F-1
 Filed June 24, 2025
 File No. 333-288294
Dear Tingjun Yang:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rule 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 Jeff Kauten at 202-551-3447 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Richard J. Chang, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

December 20, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trades and Services

100 F Street, NE

Washington, D.C., 20549

Attn: Ms. Mariam Mansaray

Re:  3 E Network Technology Group Limited

    Registration Statement on Form F-1, as amended
                                            (File No. 333-276180)

    Request for Acceleration of Effectiveness

Dear Ms. Mansaray:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), we,

the underwriter (the “Underwriter”), hereby join in the request
of 3 E Network Technology Group Limited (the “Registrant”), for the acceleration of the effective date of the Registrant’s
Registration Statement on Form F-1 (File No. 333-276180) (as amended, the “Registration Statement”), relating to a public
offering of Class A ordinary shares of the Registrant, par value $0.0001, so that the Registration Statement may be declared effective
on December 20, 2024, at 4.00 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned, as the Underwriter, confirms that
it is aware of its obligations under the Securities Act.

Pursuant to Rule 460 under the Securities Act, please
be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate in the distribution
of the security, as many copies of the proposed form of preliminary prospectus 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.

    Very truly yours,

    Craft Capital Management LLC

    /s/ Stephen Kiront

    Name: Stephen Kiront
Title: Chief Operating Officer

CORRESP
1
filename1.htm

3 E Network Technology Group Ltd

B046 of Room 801, 11 Sixing Street

Huangge Town, Nansha District

Guangzhou, Guangdong Province, PRC

December 20, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C., 20549

Attn: Ms. Jan Woo

    Re:
    3 E Network Technology Group Ltd

    Registration Statement on Form F-1, as amended (File No. 333-276180)

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, 3 E Network Technology Group Ltd hereby requests an acceleration of the
effectiveness of the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become
effective at 4:30 p.m., Eastern Time, on December 20, 2024, or as soon thereafter as practicable.

The Company understands that the Commission will
consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the Company
is aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the securities specified in
the Registration Statement.

    Very truly yours,

    3 E Network Technology Group Ltd

    By:
    /s/ Tingjun Yang

    Name:
    Tingjun Yang

    Title:
    Co-Chief Executive Officer

CORRESP
1
filename1.htm

Correspondence

VIA EDGAR

December 13, 2024

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

  Attention:
  Chris Dietz

  Mariam Mansaray

  Jan Woo

    Re:
    3 E Network Technology Group Limited

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

    Filed December 4, 2024

    File No. 333-276180

Ladies and Gentlemen,

On behalf of 3 E Network Technology Group Limited
(the “Company”), we are hereby submitting this letter to the Securities and Exchange Commission (the “Commission”)
via EDGAR in response to the comment letter from the staff of the SEC (the “Staff”), dated December 12, 2024 (the
“Comment Letter”), pertaining to the Company’s above-referenced Amendment No. 4 to the Registration Statement
on Form F-1 (“Amendment No. 4”) filed on December 4, 2024. Concurrently with the submission of this letter, the Company
is filing Amendment No. 5 to the Registration Statement on Form F-1 (“Amendment No. 5”) via EDGAR to the Commission.

Set forth below are the Company’s responses
to the Staff’s comments. The responses set forth below are based upon information provided by the Company, which we have not independently
verified. For the convenience of the Staff, the responses contained herein utilize the numbering of the comments and the headings used
in the Comment Letter, and the text of the Staff’s comments is reproduced in italics below. Capitalized terms used but not defined
herein have the meanings set forth in the Form F-1.

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

Dilution

1. We are unable to recalculate the net tangible book value after
                                            the offering. Please reconcile, in your response, the net tangible book value in dollars
                                            before the offering to the net tangible book value after the offering. As part of your response,
                                            please tell us how deferred IPO costs are considered in your calculations.

Response:

The Company acknowledges the Staff’s comment and respectfully submits that, upon recalculation, the Company’s as-adjusted
net tangible book value as of June 30, 2024 was $1,215,543, or $0.12 per Class A Ordinary Share. After giving effect to the sale of 1,200,000
Class A Ordinary Shares in the initial public offering contemplated hereby, its pro forma as adjusted net tangible book value as of June
30, 2024 is $6,281,048, or $0.56 per Class A Ordinary Share, assuming the underwriter does not exercise the option to purchase additional
Class A Ordinary Shares. In determining the net tangible book value before the IPO, the Company excluded deferred IPO costs of $1,520,975.
For the net tangible book value after the IPO, the Company excluded the estimated underwriting discounts and commissions and offering
expenses with totaling $2,455,470.

Accordingly, the Company
has revised the relevant disclosures on pages 59 and 72 of Amendment No. 5.

*****

Please contact the undersigned at +8610-5680-3969
or via email at rchang@gunder.com if you have any questions with respect to the foregoing.

    Very truly yours,

    /s/ Richard J. Chang

    Richard J. Chang, Esq.

    Gunderson Dettmer Stough Villeneuve

Franklin & Hachigian, LLP

cc: Tingjun Yang, Co-Chief Executive Officer, 3 E Network Technology
Group Limited

  Benjamin A. Tan, Esq, Sichenzia
Ross Friedman Ference LLP

December 12, 2024
Ye Tao
Chief Executive Officer
3 E Network Technology Group Limited
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Limited
Amendment No. 4 to Registration Statement on Form F-1
Filed December 4, 2024
File No. 333-276180
Dear Ye Tao:
            We have reviewed your amended registration statement and have the following
comment.
            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. 4 to Registration Statement on Form F-1
Dilution, page 70
1.We are unable to recalculate the net tangible book value after the offering. Please
reconcile, in your response, the net tangible book value in dollars before the
offering to the net tangible book value after the offering. As part of your response,
please tell us how deferred IPO costs are considered in your calculations.

December 12, 2024
Page 2
            Please contact Chris Dietz at 202-551-3408 if you have questions regarding
comments on the financial statements and related matters. Please contact Mariam Mansaray
at 202-551-6356 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Richard J. Chang, Esq.

CORRESP
1
filename1.htm

3 E NETWORK TECHNOLOGY GROUP LTD

B046 of Room 801, 11 Sixing Street

Huangge Town, Nansha District

Guangzhou, Guangdong Province, PRC

August 8, 2024

Mariam Mansaray

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:
    3 E Network Technology Group Ltd

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

    Filed July 1, 2024

    File No. 333-276180

Dear Mr. Chen:

This letter is in response
to the letter dated July 23, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to 3 E Network Technology Group Ltd. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The Third Amendment to the Registration
Statement on Form F-1 (the “Amended Registration Statement”) is being filed to accompany this letter.

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

Capitalization, page 69

 1. Please revise to remove the pro forma presentations as of June 30, 2023. In this regard, pro forma information
should only be as of the most recent balance sheet included in the filing. Refer to Article 11-02(c) of Regulation S-X. Similar concerns
apply to your dilution disclosures on page 70.

Response: In response to the Staff’s comment, we
have removed the pro forma presentations as of June 30, 2023 in capitalization and dilution disclosures on page 69 and 70 of the Amended
Registration Statement, respectively.

General

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

August 8, 2024

Page  2 of 3

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

Response: In response to the Staff’s
comment, we have filed Exhibit 99.7 Request for Waiver and Representation under Item 8.A.4 of Form 20-F to the Amended Registration Statement.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Jinhua (Anna) Wang, Esq.,
of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

August 8, 2024

Page 3 of 3

    By:
    /s/ Ye Tao

    Ye Tao

    Co-Chief Executive Officer

Jinhua (Anna) Wang, Esq.

Robinson & Cole LLP

[signature page to the SEC response letter –
3E Network Technology Group Ltd]

July 23, 2024
Ye Tao
Chief Executive Officer
3 E Network Technology Group Limited
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed July 1, 2024
File No. 333-276180
Dear Ye Tao:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 2 to Registration Statement on Form F-1
Capitalization, page 69
1.Please revise to remove the pro forma presentations as of June 30, 2023. In this regard,
pro forma information should only be as of the most recent balance sheet included in the
filing. Refer to Article 11-02(c) of Regulation S-X. Similar concerns apply to your
dilution disclosures on page 70.
General
2.Please update your financial statements or file the necessary representations as to why
such update is not necessary as an exhibit to this filing. Refer to Item 8.A.4 of Form 20-F
and Instruction 2 thereto.

July 23, 2024
Page 2
            Please contact Chen Chen at 202-551-7351 or Chris Dietz at 202-551-3408 if you have
questions regarding comments on the financial statements and related matters. Please contact
Mariam Mansaray at 202-551-5176 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Anna Wang

CORRESP
1
filename1.htm

3 E NETWORK TECHNOLOGY GROUP LTD

B046 of Room 801, 11 Sixing Street

Huangge Town, Nansha District

Guangzhou, Guangdong Province, PRC

July 1, 2024

Mariam Mansaray

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: 3 E Network Technology Group Ltd

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

Filed January 19, 2024

File No. 333-276180

Dear Ms. Mansaray:

This letter is in response
to the letter dated January 26, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to 3E Network Technology Group Ltd. (the “Company,” “we,” and “our”). The Second Amendment
to the Registration Statement on Form F-1 (the “Registration Statement”) is being filed to accompany this letter.

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

Capitalization, page 68

 1. Please revise to retroactively reflect the split on all share and per share amounts here and throughout
the filing and to remove the “Adjusted (Taking into account of the share split on January 3, 2024)” column. In this regard,
we note that you refer to 1,000 shares outstanding here are on page F-18. We also note that the net tangible book value per share of $416
is based on 1,000 shares outstanding. Refer to SAB Topic 4C.

Response:
In response to the Staff’s comment, we respectfully advise that we have revised to retroactively reflect the split on
all share and per share amounts throughout the filing and removed the “Adjusted (Taking into account of the share split on January
3, 2024)” column on page 69. Relevant revisions have been made on pages 69, 70, 71, 117, and F-38.

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

July 1, 2024

Page 2 of 3

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Jinhua (Anna) Wang, Esq.,
of Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

July 1, 2024

Page 3 of 3

    By:
    /s/ Ye Tao

    Ye Tao

    Chief Executive Officer

Jinhua (Anna) Wang, Esq.

Robinson & Cole LLP

[signature page to the SEC response letter –
3E Network Technology Group Ltd]

United States securities and exchange commission logo
January 26, 2024
Ye Tao
Chief Executive Officer
3 E Network Technology Group Ltd
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed January 19, 2024
File No. 333-276180
Dear Ye Tao:
            We have reviewed your amended registration statement and have the following comment.
            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
Capitalization, page 68
1.Please revise to retroactively reflect the split on all share and per share amounts here and
throughout the filing and to remove the "Adjusted (Taking into account of the share split
on January 3, 2024)" column. In this regard, we note that you refer to 1,000 shares
outstanding here are on page F-18. We also note that the net tangible book value per
share of $416 is based on 1,000 shares outstanding. Refer to SAB Topic 4C.

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 January 26, 2024 Page 2
 FirstName LastName
Ye Tao
3 E Network Technology Group Ltd
January 26, 2024
Page 2
            Please contact Chen Chen at 202-551-7351 or Chris Dietz at 202-551-3408 if you have
questions regarding comments on the financial statements and related matters. Please contact
Mariam Mansaray at 202-551-6356 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anna Wang

CORRESP
1
filename1.htm

3 E NETWORK TECHNOLOGY GROUP LTD

B046 of Room 801, 11 Sixing Street

Huangge Town, Nansha District

Guangzhou, Guangdong Province, PRC

December 20, 2023

Marion Graham

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: 3 E Network Technology Group Ltd

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

Submitted December 7, 2023

CIK No. 0001993097

Dear Ms. Graham:

This letter is in response
to the letter dated December 12, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to 3E Network Technology Group Ltd. (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The Registration Statement on Form F-1
(the “Registration Statement”) is being filed to accompany this letter.

Form DRS/A submitted on December 7, 2023

Cover Page

 1. Please disclose on the cover page that you have a dual class share structure and that holders of Class
A ordinary shares and holders of Class B ordinary shares will have different voting rights. Discuss the voting rights of each class.

Response: In response to the Staff’s comment, we
respectfully advise that we have revised the cover page of the Registration Statement.

 2. You state that as of the date of this prospectus, you “have not received any formal inquiry, notice,
warning, sanction, or any regulatory objection from the CSRC with respect to this offering.” Please disclose whether you believe
that you are required to complete filing procedures with the CSRC pursuant to the requirements of the Trial Measures. If not, disclose
whether you obtained the opinion of counsel in making your determination.

Response: In response to the Staff’s
comment, we respectfully advise that we have revised cover page, page 5, and page 16 of the Registration Statement.

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

December 20, 2023

Page  2 of 3

Capitalization, page 68.

 3. We note the revisions here and in the dilution section to reflect the forward split as pro forma. Please
tell us when you expect the split to occur. If the split will occur before the effective date of the registration statement, please confirm
that all disclosures throughout the filing will retroactively reflect the impact of the split on all share and per share amounts. Refer
to SAB Topic 4C.

Response: In response to the Staff’s
comment, we respectively advise that the split has not yet occurred and we expect it to occur on or about December 29, 2023, which will
be before the effective date of the registration statement. We will revise the disclosures throughout the filing in the next amendment
to the Registration Statement to retroactively reflect the impact of the split on all share and per share amounts.

Description of Share Capital

Voting Rights, page 114

 4. You state that holders of your Class A Ordinary Shares and Class B Ordinary Shares vote together as a
single class on all matters submitted to a vote of our shareholders, “except as may otherwise be required by law.” Please
discuss the circumstances in which the two classes vote together the circumstances that they will be entitled to separate class vote under
the law  and under your charter.

Response: In response to the Staff’s
comment, we respectively advise that the discussion is covered in page 122 of the Registration: “Under our Amended and Restated
Articles, if at any time our shares are divided into different classes of shares, the rights attached to any class may only be varied,
whether or not our company is in liquidation, with the consent in writing of or by a resolution passed at a meeting by a majority of the
votes cast by those entitled to vote at a meeting of the holders of the issued shares in that class.” We have been advised by our
BVI counsel that under BVI law the rights attaching to a class of shares is determined by the constitutional documents of a BVI company.
BVI law requires that the memorandum of association set out the classes of shares that a company is authorised to issue, and if the company
is authorised to issue two or more classes of shares, the rights, privileges, restrictions and conditions attaching to each class of shares.
As the Company has created two classes of shares, they vote together as one class unless otherwise set out in the memorandum and articles
of association.

We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Anna J. Wang, Esq., of
Robinson & Cole LLP, at (212) 451-2942.

Very truly yours,

[Signature Page Follows]

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

December 20, 2023

Page 3 of 3

    By:
    /s/ Ye Tao

    Ye Tao

    Co-Chief Executive Officer

    cc:
    Jinhua (Anna) Wang, Esq.

    Robinson & Cole LLP

[signature page to the SEC response letter –
3E Network Technology Group Ltd]

United States securities and exchange commission logo
December 12, 2023
Ye Tao
Chief Executive Officer
3 E Network Technology Group Ltd
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted December 7, 2023
CIK No. 0001993097
Dear Ye Tao:
            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.
Unless we note otherwise, any references to prior comments are to comments in our November
20, 2023 letter.
Form DRS/A submitted on December 7, 2023
Cover Page
1.Please disclose on the cover page that you have a dual class share structure and that
holders of Class A ordinary shares and holders of Class B ordinary shares will have
different voting rights.  Discuss the voting rights of each class.
2.You state that as of the date of this prospectus, you "have not received any formal inquiry,
notice, warning, sanction, or any regulatory objection from the CSRC with respect to this
offering."  Please disclose whether you believe that you are required to complete filing
procedures with the CSRC pursuant to the requirements of the Trial Measures. If not,

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 December 12, 2023 Page 2
 FirstName LastName
Ye Tao
3 E Network Technology Group Ltd
December 12, 2023
Page 2
disclose whether you obtained the opinion of counsel in making your determination.
Capitalization, page 68
3.We note the revisions here and in the dilution section to reflect the forward split as pro
forma. Please tell us when you expect the split to occur. If the split will occur before the
effective date of the registration statement, please confirm that all disclosures throughout
the filing will retroactively reflect the impact of the split on all share and per share
amounts. Refer to SAB Topic 4C.
Description of Share Capital
Voting Rights, page 114
4.You state that holders of your Class A Ordinary Shares and Class B Ordinary Shares vote
together as a single class on all matters submitted to a vote of our shareholders, "except as
may otherwise be required by law."  Please discuss the circumstances in which the two
classes vote together the circumstances that they will be entitled to separate class vote
under the law and under your charter.
            Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters. Please
contact Marion Graham at 202-551-6521 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anna Wang

United States securities and exchange commission logo
November 20, 2023
Ye Tao
Chief Executive Officer
3 E Network Technology Group Ltd
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted November 7, 2023
CIK No. 0001993097
Dear Ye Tao:
            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 our 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
Prospectus Summary, page 1
1.Please refer to prior comments 3 and 6.  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,

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 November 20, 2023 Page 2
 FirstName LastName
Ye Tao
3 E Network Technology Group Ltd
November 20, 2023
Page 2
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.”
            Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters. Please
contact Marion Graham at 202-551-6521 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anna Wang

United States securities and exchange commission logo
October 25, 2023
Ye Tao
Chief Executive Officer
3 E Network Technology Group Ltd
B046 of Room 801, 11 Sixing Street
Huangge Town, Nansha District
Guangzhou, Guangdong Province, PRC
Re:3 E Network Technology Group Ltd
Draft Registration Statement on Form F-1
Submitted September 27, 2023
CIK No. 0001993097
Dear Ye Tao:
            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
Cover Page
1.We note that Joseph Shu Sang Law, your Chairman, controls a majority of the voting
power of your outstanding ordinary shares.  To the extent that you will continue to be a
controlled company after the offering, please disclose on the cover page and include a risk
factor that Mr. Law will be able to influence your management and affairs and all matters
requiring shareholder approval.
Commonly Used Defined Terms, page iii
2.We note from your disclosure on page iii that you exclude Hong Kong and Macau from
your definition of “PRC” or “China.” Please revise to remove the exclusion of Hong Kong
and Macau from such definition. Clarify that all the legal and operational risks associated
with having operations in the People’s Republic of China (PRC) also apply to operations

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 October 25, 2023 Page 2
 FirstName LastNameYe Tao
3 E Network Technology Group Ltd
October 25, 2023
Page 2
in Hong Kong and Macau. In this regard, ensure that your disclosure does not narrow risks
related to operating in the PRC to mainland China only. Where appropriate, you may
describe PRC law and then explain how law in Hong Kong and Macau differs from PRC
law and describe any risks and consequences to the company associated with those laws.
Prospectus Summary, page 1
3.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
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.
4.You state that Mr. Ye Tai's service as a senior executive for Times China Holdings
Limited provides you with unique insight on developing and tailoring your product
offerings to property management companies.  Please clarify, if true, that Mr. Ye Tai no
longer serves as a senior executive for Times China Holdings Limited.
Notes on Prospectus Presentation, page 18
5.You state that you relied on statistics provided by a variety of publicly available sources
regarding expectations of growth of Hong Kong and China. We note that you cite the
Statistics from the Operation Monitoring and Coordination Bureau of the PRC Ministry of
Industry and Information Technology in the prospectus. If your statistics are derived from
sources other than MIIT, please disclose the sources.
Risk Factors, page 21
6.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to 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 the securities you are registering. 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

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 October 25, 2023 Page 3
 FirstName LastNameYe Tao
3 E Network Technology Group Ltd
October 25, 2023
Page 3
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.
A significant portion of our income is generated, and will in the future continue to be generated,
on a project basis with a fixed price..., page 27
7.You disclose that a significant portion of your income is generated from fees you receive
for projects with a fixed price.  Please disclose the percentage of your revenues that are
generated on a fixed price basis for each period presented.
Dilution, page 67
8.Please provide us with your calculation of net tangible book value as of June 30, 2023.
Also, tell us how you considered deferred IPO costs in your calculation. To the extent you
did not consider such assets to be intangible assets, please explain or revise your
calculations as necessary.
Business
Business Overview, page 84
9.We note that your property management system uses a Chinese mobile social messaging
app, WeChat, which is developed by Tencent Inc. Please clarify whether your system can
be accessed in any other way besides WeChat mini programs (e.g., personal computers,
mobile web pages, mobile apps). In addition, please tell us more about your relationship
with Tencent and describe any arrangements in place that allow your program to run on
the WeChat platform. Please include key terms and conditions of such arrangements and
provide corresponding risk factor disclosure related to reliance on a third-party platform.
Related Party Transactions, page 107
10.We note that you have loans due from related parties, including your Chief Executive
Officer and Chief Technical Officer, as of June 30, 2023.  Exchange Act Section 13(k)(1)
prohibits public companies from extending or maintaining credit in the form of personal
loans to or for any director or executive officer. Please disclose the business purpose of
the loan and tell us how you intend to comply with Section 13(k) of the Securities
Exchange Act of 1934 with respect to this loan.
Consolidated Financial Statements of 3 E Network Technology Group Limited
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies, page F-7
11.Revise to disclose that you are an emerging growth company, have elected to use the
extended transition period, and that your financial statements may not be comparable to
companies that comply with public company effective dates.
Note. 15 Subsequent Events, page F-21

 FirstName LastNameYe Tao
 Comapany Name3 E Network Technology Group Ltd
 October 25, 2023 Page 4
 FirstName LastName
Ye Tao
3 E Network Technology Group Ltd
October 25, 2023
Page 4
12.Revise to disclose the date through which subsequent events were evaluated. Refer to
ASC 855-10-50-1(a).
General
13.Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.
            Please contact Chen Chen at (202) 551-7351 or Christine Dietz at (202) 551-3408 if you
have questions regarding comments on the financial statements and related matters. Please
contact Marion Graham at (202) 551-6521 or Jan Woo at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anna Wang