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Mint
Incorporation Limited

17/F, Wing Kwok Centre, No.182 Woosung Street

Jordan, Kowloon, Hong Kong

June 1, 2026

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C., 20549

    Attn:
    Scott Anderegg

    Re:
    Mint Incorporation Limited

    Registration Statement on Form F-3, as amended (File No. 333-296027)

    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, Mint Incorporation Limited hereby requests an acceleration of the effectiveness
of the above-referenced Registration Statement on Form F-3, as amended, so that such Registration Statement will become effective at 4:00
p.m., Eastern Time, on June 3, 2026, 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,

MINT INCORPORATION LIMITED

    By:
    /s/ Hoi Lung Chan

    Name:
    Hoi Lung Chan

    Title:
    Chief Executive Officer and

Chairman of the Board of Directors

May 29, 2026
Hoi Lung Chan
Chief Executive Officer
Mint Inc Ltd
17/F, Wing Kwok Centre, No.182 Woosung Street
Jordan, Kowloon, Hong Kong
Re: Mint Inc Ltd
Registration Statement on Form F-1
Filed May 19, 2026
File No. 333-296027
Dear Hoi Lung Chan:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            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 Scott Anderegg at 202-551-3342 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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Mint Incorporation Limited

503 Park Tower, 15 Austin Road,

Tsim Sha Tsui, Kowloon, Hong Kong

December 20, 2024

VIA EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: Mint Incorporation Limited

Registration Statement on Form F-1, as
amended (File No. 333-281922)

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, Mint Incorporation Limited hereby requests 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 5:00 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,

    Mint Incorporation Limited

    By:
    /s/ Hoi Lung CHAN

    Name:
    Hoi Lung CHAN

    Title:
    Chief Executive Officer and Director

    cc:
    Mengyi “Jason” Ye, Esq.

    Ortoli Rosenstadt LLP

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Benjamin Securities, Inc.

3 West Garden Street

Suite 407

Pensacola, FL 32502

December 20, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

 Re: Mint Incorporation Limited

Registration Statement on Form F-1, as
amended (File No. 333-281922)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and
the other underwriters, hereby join in the request of Mint Incorporation Limited that the effective date of the above-referenced registration
statement be accelerated so as to permit it to become effective at 5:00 p.m., Eastern Time, on December 20, 2024 or as soon thereafter
as practicable.

Pursuant to 460 under the
Act, we wish to advise you that the underwriters will distribute as many copies of the preliminary prospectus dated November 18, 2024
to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such preliminary prospectus.

The undersigned advises
that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    Benjamin Securities, Inc.

    By:
    /s/ Michael Coyne

    Name:
    Michael Coyne

    Title:
    Principal

August 1, 2024
Hoi Lung Chan
Chief Executive Officer
Mint Inc Ltd
503 Park Tower, 15 Austin Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:Mint Inc Ltd
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted July 22, 2024
CIK No. 0001998560
Dear Hoi Lung Chan:
            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
July 16, 2024 letter.
Draft Registration Statement on Form F-1 submitted July 22, 2024
Cover Page
1.We note your revised disclosure pursuant to comment 1 and reissue in part. The
disclosure here should not be qualified by materiality. Please make appropriate revisions
here, in the prospectus summary, and elsewhere as applicable.

August 1, 2024
Page 2
            Please contact Abe Friedman at 202-551-8298 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenna Hough at 202-551-3063 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jason Ye

July 16, 2024
Hoi Lung Chan
Chief Executive Officer
Mint Inc Ltd
503 Park Tower, 15 Austin Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:Mint Inc Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted June 27, 2024
CIK No. 0001998560
Dear Hoi Lung Chan:
            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 1, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted June 27, 2024
Cover Page
1.We note your revised disclosure pursuant to comment 2 and reissue in part. Please
affirmatively state here and throughout the filing as appropriate, including on the resale
prospectus cover page, if there are restrictions or limitations on the ability of you or your
subsidiaries by the PRC government to transfer cash or assets. If so, please disclose what
such restrictions are.

July 16, 2024
Page 2
            Please contact Abe Friedman at 202-551-8298 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenna Hough at 202-551-3063 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jason Ye

United States securities and exchange commission logo
March 1, 2024
Hoi Lung Chan
Chief Executive Officer
Mint Inc Ltd
503 Park Tower, 15 Austin Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:Mint Inc Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted February 6, 2024
File No. 377-07022
Dear Hoi Lung Chan:
            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
January 23, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Cover Page
1.We note your revised disclosure pursuant to comment 10 that no dividends or distributions
were made by your subsidiaries or by Mint. Please further revise to disclose whether any
payments (including transfers, capital contributions and loans) have been made by the
holding company to the operating subsidiary and/or your subsidiaries, or by the operating
subsidiary to the holding company and/or your subsidiaries. If so, quantify such payments.
Also revise to state, if true, that the operating subsidiary's payment of dividends to
shareholders was conducted through CKL and Mint (given the process set forth in section
(ii) of the 24th paragraph of the cover page). This comment applies to the cover page,

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 March 1, 2024 Page 2
 FirstName LastName
Hoi Lung Chan
Mint Inc Ltd
March 1, 2024
Page 2
prospectus summary and cover page of the resale prospectus, as appropriate.
2.We note your response to comment 11. Please further revise your disclosure here and
throughout the filing as appropriate, including on the resale prospectus cover page, to
address the fact that, to the extent assets in the business are in Hong Kong or a Hong Kong
entity, the assets may not be available for other use outside of Hong Kong due to
interventions in or the imposition of restrictions and limitations on the ability of you or
your subsidiaries by the PRC government to transfer assets.  On the cover pages, provide
cross-references to these other discussions.
3.We note your disclosure that "the legal and operational risks associated with operating in
Mainland China may also apply to our operations in Hong Kong" (emphasis added). Here,
on pages 13 and 30, and in the accompanying resale prospectus, please revise this
language to state that the legal and operational risks associated with operating in Mainland
China do apply to your operations in Hong Kong.
Index to Consolidated Financial Statements, page F-1
4.Please update your financial statements and corresponding financial information
throughout the filing to comply with Item 8.A.5 of Form 20-F.
            Please contact Abe Friedman at 202-551-8298 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jason Ye

United States securities and exchange commission logo
January 23, 2024
Hoi Lung Chan
Chief Executive Officer
Mint Inc Ltd
503 Park Tower, 15 Austin Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:Mint Inc Ltd
Draft Registration Statement on Form F-1
Submitted December 22, 2023
File No. 377-07022
Dear Hoi Lung Chan:
            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.
Form F-1
Permission required from Hong Kong and PRC authorities, page 12
1.We note your disclosure that you are not required to obtain any permission or approval
from Hong Kong authorities to operate your business, or from Hong Kong or PRC
authorities to conduct this offering or list overseas. Please revise to state, if true, that you
are not required to obtain any permission or approval from PRC authorities to operate
your business. Also revise to clarify whether you relied on the opinion of counsel to come
to this conclusion and, if you did not, please explain why. Finally, please revise the last
sentence of this section so that it applies to all permissions or approvals required by PRC
authorities, as opposed to only permissions or approvals required by the CAC and CSRC.
2.Please state here, as you do on the prospectus cover page, that the legal and operational
risks that arise from operating in Mainland China also apply to businesses operating in
Hong Kong and Macau.

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 January 23, 2024 Page 2
 FirstName LastNameHoi Lung Chan
Mint Inc Ltd
January 23, 2024
Page 2
Risk Factors
There remain some uncertainties as to whether..., page 31
3.We note that you do not appear to have relied upon an opinion of counsel with respect to
your conclusions that you do not believe you will be deemed an “operator of critical
information infrastructure,” and therefore will not be subject to cybersecurity review by
the CAC for this offering. If true, state as much and explain why such an opinion was not
obtained. If you did rely on the opinion of counsel, please revise to name counsel and file
the consent of counsel as an exhibit.
Description of Business
Employees, page 85
4.We note your disclosure of 15 full time employees as of March 31, 2023. Please update to
include the number of employees for each of the last three financial years and the
geographic location of these employees. If applicable, also include any significant change
in the number of employees and information regarding the relationship between
management and labor unions. Refer to Item 6.C of Form 20-F.
Taxation, page 117
5.Please revise to describe the impact on you of China’s Enterprise Income Tax Law and
of the arrangement between Mainland China and the Hong Kong Special Administrative
Region for the Avoidance of Double Taxation.
Alternate Prospectus Cover Page, page A-1
6.Please revise the alternate prospectus cover page of the Resale Prospectus to include the
disclosure requested by comments 1-4 of the Division of Corporation Finance's Sample
Letter to China-Based Companies issued by the Staff in December 2021. Also revise to
state, if true and as you do on the prospectus cover page of the Public Offering Prospectus,
that the resale offering is contingent upon the company's Class A ordinary shares
being listed on the Nasdaq Capital Market.
General
7.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
Prospectus Cover Page
8.Please disclose the individual and aggregate ownership percentages to be held by your two
largest shareholders upon completion of this offering, the names of such shareholders, the
controlling persons of such shareholders, and the fact that, if they act together, they will

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 January 23, 2024 Page 3
 FirstName LastNameHoi Lung Chan
Mint Inc Ltd
January 23, 2024
Page 3
control the management and affairs of the company and most matters requiring
shareholder approval, including the election of directors and approval of significant
corporate transactions. This comment applies to the prospectus cover page of the Resale
Prospectus, as well.
9.Here and in the prospectus summary, please state that Chinese regulatory authorities
could disallow your organizational structure, which would likely result in a material
change in your operations and/or a material change in the value of the securities you are
registering for sale, including that it could cause the value of such securities to
significantly decline or become worthless.
10.We note your disclosure regarding whether payments were made by the holding company
to shareholders, by your subsidiaries to the holding company, between the holding
company and the operating subsidiary, and by the operating subsidiary to shareholders.
Here and in the prospectus summary, please revise to also address whether payments were
made by the holding company to your subsidiaries, by your subsidiaries to investors or the
operating subsidiary, and by the operating subsidiary to your subsidiaries. Also provide on
the cover page a general description of how cash is transferred through your organization,
as you do in the first paragraph on page 3.
11.Please amend your disclosure here and in the summary risk factors and risk factors
sections to state that, to the extent cash or assets in the business is in the PRC/Hong Kong
or a PRC/Hong Kong entity, the funds or assets may not be available to fund operations or
for other use outside of the PRC/Hong Kong due to interventions in or the imposition of
restrictions and limitations on the ability of you or your subsidiaries by the PRC
government to transfer cash or assets.  On the cover page, provide cross-references to
these other discussions.
12.We note your discussion of cash management policies on page 3. Please include this
discussion on the prospectus cover page, as well.
13.Please state here, as you do on page 34, that compliance with Hong Kong's Personal Data
(Privacy) Ordinance and other data privacy laws in Hong Kong may entail epenses and
materially affect your business.

 FirstName LastNameHoi Lung Chan
 Comapany NameMint Inc Ltd
 January 23, 2024 Page 4
 FirstName LastName
Hoi Lung Chan
Mint Inc Ltd
January 23, 2024
Page 4
            Please contact Abe Friedman at 202-551-8298 or Rufus Decker at 202-551-3769 if you
have questions regarding the financial statements and related matters. Please contact Jenna
Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Jason Ye