SecProbe.io

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 Mingteng International Corporation Inc.

 Lvhua Village, Luoshe Town,

 Huishan District, Wuxi,

 Jiangsu Province, China 214189

 June 23, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Manufacturing

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Ms. Erin Donahue

 Re:
 Mingteng International Corporation Inc.

 Registration Statement on Form F-3, as amended
 (File No. 333-287843)
 Request for Acceleration of Effectiveness

 Dear Ms. Donahue,

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Mingteng International Corporation Inc. hereby requests
that the effectiveness of the above-referenced Registration Statement on Form F-3, as amended be accelerated to and that the Registration
Statement become effective at 4:00 p.m., Eastern Time, on June 25, 2025, 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,

 Mingteng International Corporation Inc.

 By:
 /s/ Yingkai Xu

 Name:
 Yingkai Xu

 Title:
 Chief Executive Officer and Chairman

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

Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town,
Huishan District, Wuxi,
Jiangsu Province, China 214189

 Re: Mingteng International Corp Inc.
 Registration Statement on Form F-3
 Filed June 6, 2025
 File No. 333-287843
Dear Yingkai Xu:

 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 Erin Donahue at 202-551-6063 with any questions.

 Sincerely,

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

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Craft
Capital Management LLC

377
Oak St #402

Garden
City, NY 11530

United
States of America

March
28, 2024

VIA
EDGAR CORRESPONDENCE

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Eranga Dias

    Re:
    Mingteng
                                            International Corp Inc.

    Registration
    Statement on Form F-1

    File
    No. 333-270953

    REQUEST
    FOR ACCELERATION OF EFFECTIVENESS

Dear
Mr. Dias:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”),
Craft Capital Management LLC, as representative of the underwriters of the offering, hereby joins the request of Mingteng International
Corp Inc. that the effective date of the above-referenced Registration Statement on Form F-1 be accelerated so that it may become effective
at 4:00 p.m., Eastern Time, on March 29, 2024, or as soon thereafter as practicable.

In
connection with this acceleration request and pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed
to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the securities, as many
copies, as well as “e-red” copies of the 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.

    Best Regards,

    CRAFT CAPITAL MANAGEMENT LLC

    By:
    /s/ Stephen Kiront

    Name:
    Stephen
Kiront

    Title:
    Chief Operating Officer

CORRESP
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Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town,

Huishan District, Wuxi,

Jiangsu Province, China 214189

March 28, 2024

VIA EDGAR

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4720

Attn: Eranga Dias

    Re:
    Mingteng International Corporation Inc.

    Registration Statement on Form F-1, as amended (File No. 333-270953)

    Request for Acceleration of Effectiveness

Dear Mr. Dias:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Mingteng International Corporation Inc. hereby requests
that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended be accelerated to and that the Registration
Statement become effective at 4:00 p.m., Eastern Time, on March 29, 2024, or as soon thereafter as practicable.

    Very truly yours,

    Mingteng International Corporation Inc.

    By:
    /s/ Yingkai Xu

    Name:
    Yingkai Xu

    Title:
    Chief Executive Officer

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Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town

Huishan District, Wuxi

Jiangsu Province, China 214189

January 18, 2024

Division of Corporation
Finance

Office of Manufacturing

U.S. Securities
and Exchange Commission

Washington, D.C. 20549-4720

Attn: Eranga Dias

    Re:
    Mingteng International Corporation Inc.

Amendment No. 7 to Registration Statement on Form F-1

Filed January 12, 2024

File No. 333-270953

Dear Mr. Dias:

This letter is in response to your letter on January
17, 2024, in which you provided a comment to the Registration Statement on Form F-1 (the “Registration Statement”) of
Mingteng International Corporation Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on January
12, 2024. On the date hereof, the Company has submitted Amendment No.8 to the Registration Statement on Form F-1 (“Amendment
No.8”). We set forth below in bold the comment in your letter relating to the F-1 followed by our response to the comment.

Amendment No. 7 to Registration Statement on Form F-1

Executive Compensation, page 115

    1.
    Please update your compensation disclosure to reflect the fiscal year ended December 31, 2023.

RESPONSE: In response to the Staff’s comment,
we have revised the disclosure on page 115 of Amendment No.8 to include executive compensation for the fiscal year ended December 31,
2023.

In responding to your comments, the Company acknowledges
that:

    ●
    the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

    ●
    the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ Yingkai Xu

    Yingkai Xu

    Chief Executive Officer

United States securities and exchange commission logo
January 17, 2024
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment No. 7 to Registration Statement on Form F-1
Filed January 12, 2024
File No. 333-270953
Dear Yingkai Xu:
            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 December 15, 2023 letter.
Amendment No. 7 to Registration Statement on Form F-1
Executive Compensation, page 115
1.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2023.

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 January 17, 2024 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
January 17, 2024
Page 2
            Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 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
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Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town

Huishan District, Wuxi

Jiangsu Province, China 214189

December 15, 2023

Division of Corporation
Finance

Office of Manufacturing

U.S. Securities
and Exchange Commission

Washington, D.C. 20549-4720

Attn: Evan Ewing

    Re:
    Mingteng International Corporation Inc.

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

Filed December 7, 2023

File No. 333-270953

Dear Mr. Ewing:

This letter is in response to your letter on December
15, 2023 in which you provided a comment to the Registration Statement on Form F-1 (the “Registration Statement”) of
Mingteng International Corporation Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on December
7, 2023. On the date hereof, the Company has submitted Amendment No.5 to the Registration Statement on Form F-1 (“Amendment
No.5”). We set forth below in bold the comment in your letter relating to the F-1 followed by our response to the comment.

Amendment No. 4 to Registration Statement

Exhibits

    1.
    We note your response to comment 2. Please have counsel revise Exhibit 5.1 to state that the selling shareholder’s shares are legally issued, fully paid and non-assessable. Refer to Section II.B.2.h of Staff Legal Bulletin No. 19.

RESPONSE: In response to the Staff’s comment,
the Cayman counsel, Mourant Ozannes (Cayman) LLP, to the issuer has revised Section 3.4 of Exhibit 5.1 to recognize that the  selling
shareholder’s shares are legally issued, fully paid and non-assessable.

We hope this response has addressed all of
the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained
herein, please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli
Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ Yingkai Xu

    Yingkai Xu

    Chief Executive Officer

United States securities and exchange commission logo
December 15, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment No. 4 to Registration Statement on Form F-1
Filed December 7, 2023
File No. 333-270953
Dear Yingkai Xu:
            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 December 6, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1
Exhibits
1.We note your response to comment 2. Please have counsel revise Exhibit 5.1 to state that
the selling shareholder's shares are legally issued, fully paid and non-assessable.  Refer to
Section II.B.2.h of Staff Legal Bulletin No. 19.
            Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Evan Ewing at 202-551-5920 with any other questions.
Sincerely,

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 December 15, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
December 15, 2023
Page 2
Division of Corporation Finance
Office of Manufacturing

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Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town

Huishan District, Wuxi

Jiangsu Province, China 214189

December 7, 2023

Division of Corporation
Finance

Office of Manufacturing

U.S. Securities
and Exchange Commission

Washington, D.C. 20549-4720

Attn: Eranga Dias

    Re:

    Mingteng International Corporation Inc.

    Amendment No. 3 to Registration Statement on Form F-1

    Filed November 22, 2023

    File No. 333-270953

Dear Mr. Dias:

This letter is in response to your letter on December
6, 2023 in which you provided a comment to the Registration Statement on Form F-1 (the “Registration Statement”) of Mingteng
International Corporation Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on November 22, 2023.
On the date hereof, the Company has submitted Amendment No.4 to the Registration Statement on Form F-1 (“Amendment No.4”).
We set forth below in bold the comment in your letter relating to the F-1 followed by our response to the comment.

Amendment No. 3 to Registration Statement on Form F-1
filed November 22, 2023

Related Party Transactions, page 116

    1.
    We note your disclosure that “[s]et forth below are the related party transactions of our company that occurred during the past three fiscal years up to the date of this prospectus,” however, it appears that you have only provided related party transaction disclosure for the years ended December 31, 2020, 2021 and 2022 and the six months ended June 30, 2022 and 2023. Item 7.B. of Form 20-F requires that you include information since the beginning of the company’s preceding three financial years up to the date of the document. Please advise or revise.

RESPONSE: In response to the Staff’s comment,
we have revised the disclosure in the “Related Party Transactions” section on page 116 of the Registration Statement to include
applicable transactions since the beginning of the company’s preceding three financial years up to the date of the prospectus.

Exhibits

    2.
    Please have counsel revise Exhibit 5.1 to:

 ● remove assumption 2.11. It is not appropriate for counsel
to assume that the company is not in bankruptcy; and

 ● revise Section 3 to recognize that the shares to be sold
by the selling shareholder are already outstanding and fully paid.

RESPONSE: In response to the Staff’s comment,
the Cayman counsel, Mourant Ozannes (Cayman) LLP, to the issuer (“Counsel”) has revised Section 3.4 of Exhibit 5.1 to recognize
that the shares to be sold by the selling shareholder are already outstanding and fully paid.

With respect to assumption 2.11, the Counsel
respectfully submits that it is necessary and should not be omitted for the following reasons:

 (i) a resolution to wind up the Company may have been passed of which we are not aware, which this is a factual
matter that we cannot independently verify;

 (ii) whether or not the Company is insolvent (but not in liquidation) is a matter of fact that we are not able
to verify;

 (iii) if the Company is insolvent, any transactions entered into by it may be challenged by the liquidator (e.g.,
as an undervalue transaction, unfair preference, or extortionate credit transaction);

 (iv) a recent application for the Company’s insolvent liquidation may have been filed at the Grand Court, which
does not show on the Court Searches, and, if the Company is in liquidation, its directors cease to have the power to deal with its assets
or to cause it to enter into contracts; and

 (v) following the commencement of a voluntary liquidation, any transfer of shares without the sanction of
the liquidator and any alteration in a company’s members is void.

Exhibits

    3.
    We note your response to prior comment 1. We also note that you have not fully restored your disclosure to the existing disclosure as contained in the May 26, 2023 registration statement. Please restore your disclosure wherever applicable. Refer to our prior comment 1 in our letter dated November 15, 2023.

RESPONSE: In response to the Staff’s comment,
we have fully restored:

 (i) disclosures on the cover page, prospectus summary, and risk factor sections relating to legal and operational
risks associated with operating in China and PRC regulations;

 (ii) disclosure relating to the risk that the PRC government may intervene in or influence our operations at
any time, or may exert control over operations of your business, which could result in a material change in our operations and/or the
value of the securities we are registering for sale on the cover page, pages 34, and 37; and

 (iii) disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations
in China can change quickly with little advance notice on the cover page and page 34.

Further, we kept the following revisions since
the amendment that was filed on May 26, 2023:

 (i) to update the progress in connection with the CSRC filing on the cover page, pages 14, 41, and 109; and

    (ii)
    to correct a certain cross reference on the cover page.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ Yingkai Xu

    Yingkai Xu

    Chief Executive Officer

United States securities and exchange commission logo
December 6, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment No. 3 to Registration Statement on Form F-1
Filed November 22, 2023
File No. 333-270953
Dear Yingkai Xu:
            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 November 15, 2023 letter.
Amendment No. 3 to Form F-1 filed November 22, 2023
Related Party Transactions, page 116
1.We note your disclosure that "[s]et forth below are the related party transactions of our
company that occurred during the past three fiscal years up to the date of this prospectus,"
however, it appears that you have only provided related party transaction disclosure for
the years ended December 31, 2020, 2021 and 2022 and the six months ended June 30,
2022 and 2023. Item 7.B. of Form 20-F requires that you include information since the
beginning of the company’s preceding three financial years up to the date of the
document. Please advise or revise.

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 December 6, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
December 6, 2023
Page 2
Exhibits
2.Please have counsel revise Exhibit 5.1 to:
• remove assumption 2.11. It is not appropriate for counsel to assume that the company is
not in bankruptcy; and
• revise Section 3 to recognize that the shares to be sold by the selling shareholder are
already outstanding and fully paid.
General
3.We note your response to prior comment 1. We also note that you have not fully restored
your disclosure to the existing disclosure as contained in the May 26, 2023 registration
statement. Please restore your disclosure wherever applicable. Refer to our prior comment
1 in our letter dated November 15, 2023.
            Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 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
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Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town

Huishan District, Wuxi

Jiangsu Province, China 214189

November 22, 2023

Division of Corporation
Finance

Office of Manufacturing

U.S. Securities
and Exchange Commission

Washington, D.C. 20549-4720

Attn: Eranga Dias

    Re:

    Mingteng International Corporation Inc.

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

    Filed November 1, 2023

    File No.333-270953

Dear Mr. Dias:

This letter is in response to your letter on November
15, 2023 in which you provided a comment to the Registration Statement on Form F-1 (the “Registration Statement”) of
Mingteng International Corporation Inc. (the “Company”) filed with the U.S. Securities and Exchange Commission on November
1, 2023. On the date hereof, the Company has submitted Amendment No. 3 to Registration Statement on Form F-1 (“Amendment
No. 3”). We set forth below in bold the comment in your letter relating to the F-1 followed by our response to the comment.

Amendment No. 2 to Registration Statement on Form F-1
filed November 1, 2023

General

    1.
    We note the changes you made to your disclosures appearing on the cover page, prospectus summary and risk factors sections relating to legal and operational risks associated with operating in China and PRC regulations. It is unclear to us that there have been changes in the regulatory environment in the PRC since the amendment that was filed on May 26, 2023 warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your operations at any time, or may exert control over operations of your business, which could result in a material change in your operations and/or the value of the securities you are registering for sale. We remind you that, pursuant to federal securities rules, the term “control” (including the terms “controlling,” “controlled by,” and “under common control with”) as defined in Securities Act Rule 405 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.” The Sample Letters also sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can change quickly with little advance notice. We do not believe that your revised disclosure conveys the same risk. Please restore your disclosures in these areas to the disclosures as they existed in the registration statement as of May 26, 2023.

RESPONSE: In response to the Staff’s comment,
the Company has fully restored its disclosures on the cover page, Prospectus Summary, and Risk Factor sections relating to legal and operational
risks associated with operating in China and PRC regulations relating to uncertainties regarding the enforcement of laws and that the
rules and regulations in China can change quickly with little advance notice as they existed in the registration statement as of May 26,
2023, on and to the following pages and risk factors:

 ● Page 34: “The Chinese government exerts substantial influence over the manner in which we must
conduct our business activities, which could result in a material change in our operations and/or the value of our Ordinary Shares. The
Chinese government may intervene or influence our operations at any time, which could result in a material change in our operations and
the value of our Ordinary Shares. Additionally, the governmental and regulatory interference could significantly limit or completely hinder
our ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be
worthless.”

 ● Page 36: “Uncertainties with respect to the PRC legal system, including uncertainties regarding
the enforcement of laws, and sudden or unexpected changes in laws and regulations in China could adversely affect us and limit the legal
protections available to you and us.”

 ● Page 40: “The M&A Rules and certain other PRC regulations may make it more difficult for
us to pursue growth through acquisitions.”

 ● Page 42: “The approval, filing, or other procedures of the CSRC or other PRC regulatory authorities
may be required in connection with this offering under PRC laws, regulations, and rules.”

 ● Page 43: “Governmental control of currency conversion may limit our ability to utilize our revenues
effectively and affect the value of your investment.”

 ● Page 44: “Enhanced scrutiny over acquisition transactions by the PRC tax authorities may have
a negative impact on potential acquisitions we may pursue in the future.”

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ Yingkai Xu

    Yingkai Xu

    Chief Executive Officer

United States securities and exchange commission logo
November 15, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment No. 2 to Registration Statement on Form F-1
Filed November 1, 2023
File No. 333-270953
Dear Yingkai Xu:
            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 April 12, 2023 letter.
Amendment No. 2 to Form F-1 filed November 1, 2023
General
1.We note the changes you made to your disclosures appearing on the cover page,
prospectus summary and risk factors sections relating to legal and operational risks
associated with operating in China and PRC regulations.  It is unclear to us that there have
been changes in the regulatory environment in the PRC since the amendment that was
filed on May 26, 2023 warranting revised disclosure to mitigate the challenges you face
and related disclosures.  The Sample Letters to China-Based Companies sought specific
disclosure relating to the risk that the PRC government may intervene in or influence your
operations at any time, or may exert control over operations of your business, which could
result in a material change in your operations and/or the value of the securities you are
registering for sale.  We remind you that, pursuant to federal securities rules, the term

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 November 15, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
November 15, 2023
Page 2
“control” (including the terms “controlling,” “controlled by,” and “under common control
with”) as defined in Securities Act Rule 405 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.”  The
Sample Letters also sought specific disclosures relating to uncertainties regarding the
enforcement of laws and that the rules and regulations in China can change quickly with
little advance notice.  We do not believe that your revised disclosure conveys the same
risk.  Please restore your disclosures in these areas to the disclosures as they existed in the
registration statement as of May 26, 2023.
            Please contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 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

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Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town,

Huishan District, Wuxi,

Jiangsu Province, China 214189

May 26, 2023

Via EDGAR Correspondence

Mr. Eranga Dias

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:

    Mingteng International Corporation Inc.

    Registration Statement on Form F-1

    Submitted March 29, 2023

    CIK No. 0001948099

Dear Mr. Dias,

This letter is in response to the letter
dated April 14, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) addressed to Mingteng International Corporation Inc. (the “Company”, “we”, and
“our”). For ease of reference, we have recited the Commission’s comments in this response and numbered them
accordingly. The amendment No. 1 to the registration statement on Form F-1 (“Amended Registration Statement”) is being
submitted to accompany this letter.

Registration Statement on Form F-1 Filed March
29, 2023

Cover Page

1. We note that the CSRC recently published
Trial Measures that impose certain filing requirements for direct and indirect overseas listings and offerings. Please disclose whether
you and relevant parties to this transaction have complied with your obligations under the Trial Measures and the risks to investors of
non-compliance.

RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that the requested disclosure has been provided on the cover page of the Amended
Registration Statement.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our outside securities counsel William S. Rosenstadt, Esq. or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal or jye@orllp.legal.

    Very truly yours,

    /s/ Yingkai Xu

    Name:
    Yingkai Xu

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
April 12, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Registration Statement on Form F-1
Filed March 29, 2023
File No. 333-270953
Dear Yingkai Xu:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-1 Filed March 29, 2023
Cover Page
1.We note that the CSRC recently published Trial Measures that impose certain filing
requirements for direct and indirect overseas listings and offerings.  Please disclose
whether you and relevant parties to this transaction have complied with your obligations
under the Trial Measures and the risks to investors of non-compliance.
            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.

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 April 12, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
April 12, 2023
Page 2
            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.
            You may contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 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

Mingteng International Corporation Inc.

Lvhua Village, Luoshe Town,

Huishan District, Wuxi,

Jiangsu Province, China 214189

March 29, 2023

Via EDGAR Correspondence

Mr. Eranga Dias

Division of Corporation Finance

Office of Manufacturing

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:

    Mingteng International Corporation Inc.

    Amendment 1 to Draft Registration Statement on Form F-1

    Submitted February 10, 2023

    CIK No. 0001948099

Dear Mr. Dias,

This letter is in response to the letter dated
February 24, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Mingteng International Corporation Inc. (the “Company”, “we”, and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. A registration statement on Form F-1 (“Registration
Statement”) is being submitted to accompany this letter.

Amendment 1 to Draft Registration Statement
on Form F-1 Filed February 10, 2023

Cover Page

1. Please disclose the representative warrants
on the cover page. Additionally, disclose on the cover page the number of ordinary shares underlying the representative warrants that
are being registered in this offering.

RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that the requested disclosure has been provided on the cover page of the Registration
Statement.

Business, page 88

2. We note your revisions to the graphics on
pages 88 and 89. We are still unable to read the notations on those graphics. Please revise to update with clearly legible notations.

RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that clear versions of the notations contained in the graphics have been provided
on pages 88 and 89 of the Registration Statement.

Compensation, page 118

3. Please update your compensation disclosure
to reflect the fiscal year ended December 31, 2022.

RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that no compensation was paid or accrued for the fiscal years ended December 31,
2022, and the requested disclosure has been provided on page 118 of the Registration Statement.

Related Party Transactions, page 118

4. We note your response to comment 12 and
reissue in part. You have provided related party transaction disclosure for the years ended December 31, 2019, 2020 and 2021 and the six
months ended June 30, 2022. Item 7.B. of Form 20-F requires that you include information since the beginning of the company’s preceding
three financial years up to the date of the document. Please revise.

RESPONSE: We note the Staff’s comment,
and in response thereto, respectfully advise the Staff that the requested disclosure has been provided on page 118 of the Registration
Statement.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our outside securities counsel William S. Rosenstadt, Esq. or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal or jye@orllp.legal.

    Very truly yours,

    /s/ Yingkai Xu

    Name:
    Yingkai Xu

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
February 24, 2023
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Amendment 1 to
Draft Registration Statement on Form F-1
Submitted February 10, 2023
CIK No. 0001948099
Dear Yingkai Xu:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment 1 to Draft Registration Statement on Form F-1 Filed February 10, 2023
Cover Page
1.Please disclose the representative warrants on the cover page. Additionally, disclose on
the cover page the number of ordinary shares underlying the representative warrants that
are being registered in this offering.
Business, page 88
2.We note your revisions to the graphics on pages 88 and 89. We are still unable to read
the notations on those graphics. Please revise to update with clearly legible notations.

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 February 24, 2023 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
February 24, 2023
Page 2
Compensation, page 118
3.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2022.
Related Party Transactions, page 118
4.We note your response to comment 12 and reissue in part. You have provided related
party transaction disclosure for the years ended December 31, 2019, 2020 and 2021 and
the six months ended June 30, 2022. Item 7.B. of Form 20-F requires that you
include information since the beginning of the company’s preceding three financial years
up to the date of the document. Please revise.
            You may contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 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
December 7, 2022
Yingkai Xu
Chief Executive Officer
Mingteng International Corp Inc.
Lvhua Village, Luoshe Town
Huishan District, Wuxi
Jiangsu Province, China 214189
Re:Mingteng International Corp Inc.
Draft Registration Statement on Form F-1
Submitted November 10, 2022
CIK No. 0001948099
Dear Yingkai Xu:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Registration Statement on Form F-1
Cover Page
1.We note your disclosure that Yingkai Xu owns 41.82% and Jingzhu Ding, Mr. Yingkai
Xu's spouse, owns 40.18% of your ordinary shares. Please disclose whether you will be a
"controlled company" following this offering under the applicable Nasdaq listing
standards and, if so, whether you will use related exemptions to governance rules under
those standards. If so, please revise the registration statement to describe the exemptions
from corporate governance on which you will be entitled to rely and the related risks to
investors.

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 December 7, 2022 Page 2
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
December 7, 2022
Page 2
2.Please revise the cover page to provide a narrower estimate of the offering price range.
For initial public offerings, a price range in excess of $2 for offerings up to $10 per share
will not be considered bona fide. Please refer to the guidance provided in Question 134.04
in the Regulation S-K Compliance and Disclosure Interpretations.
Risk Factors, page 21
3.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock-run up,
may be unrelated to your actual or expected operating performance and financial
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock.
4.Please disclose whether you are subject to material cybersecurity risks in your supply
chain based on third-party products, software, or services used in your products, services,
or business and how a cybersecurity incident in your supply chain could impact your
business. Discuss the measures you have taken to mitigate these risks.
We have pledges on our intellectual property..., page 27
5.We note your disclosure that you have pledged two patents in connection with short-term
bank loans, however, it appears that your loans with Jiangsu Wuxi Rural Commercial
Bank have been repaid. Please clarify and revise to disclose the terms of any existing
short-term bank loans.
Use of Proceeds, page 59
6.We note that you intend to use the proceeds from this offering to invest in new production
facilities to improve production capacity and purchase high-end production equipment.
We further note that you plan to build an intelligent production workshop
and acquire aluminum alloy product manufactures. 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. If the proceeds may or will be used to
finance acquisitions of other businesses, give a brief description of such businesses and
information on the status of the acquisitions. Refer to Item 3.C of Form 20-F.

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 December 7, 2022 Page 3
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
December 7, 2022
Page 3
Dilution, page 61
7.Expand the disclosure to show how the numbers and percentages would change assuming
the exercise and conversion of all outstanding securities.

Management's Discussion and Analysis of Financial Condition and Results of Operations, page
74
8.We note your disclosure that you "do not believe that inflation has had a material impact
on [y]our financial position or results of operations to date, a high rate of inflation in the
future may have an adverse effect on [y]our ability to maintain current levels of gross
margin and operating expenses if the revenues from [y]our products do not increase with
such increased costs." Please update your disclosure to identify actions planned or taken,
if any, to mitigate inflationary pressures.
9.Please discuss whether supply chain disruptions materially affect your outlook or business
goals. 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.
Business, page 97
10.We are unable to read the notations contained in the graphics on pages 88 and 89. Please
revise.
Related Party Transactions, page 119
11.We note your disclosure on page F-19 that the "company provides personal loans to
individuals, such as employees and friends of managers, anticipating that these individuals
will provide the Company with corresponding services or business conveniences in the
future." Section 402 of the Sarbanes-Oxley Act of 2002 prohibits public companies from
extending or maintaining credit in the form of personal loans to or for any director or
executive officer. To the extent necessary, disclose the action that will be taken to ensure
any applicable arrangements will be extinguished prior to the completion of the initial
public offering.
12.Please revise to provide the information for the period since the beginning of the
company’s preceding three financial years up to the date of the document. Refer to Item
7.B. of Form 20-F. Additionally, please revise the disclosure to update for your current
shareholders, directors and officers. For example, you state that Jingzhu Ding is a current
director.
Principal Shareholders, page 120
13.We note your disclosure that Jingzhu Ding, through Jocelyn Ding Limited, an
intermediate holding company for DJZ Holding Limited, holds 90% shares of Hongze

 FirstName LastNameYingkai Xu
 Comapany NameMingteng International Corp Inc.
 December 7, 2022 Page 4
 FirstName LastName
Yingkai Xu
Mingteng International Corp Inc.
December 7, 2022
Page 4
L.P. and has dipositive power over the shares held by Hongze L.P. Please clarify why it
appears that the 450,000 shares held by Hongze L.P. are not included in the beneficial
ownership of DJZ Holding Limited or YK Xu Holding Limited.
Exhibits
14.We note your disclosure of leased property on page 99. Please file all material lease
agreements or tell us why you are not required to do so.
15.If true, revise the exhibit index to clarify that Exhibits 10.7 and 10.8 are the form of your
purchase and sales contracts. If you have redacted information from Exhibits 10.7 and
10.8 pursuant to Item 601(b)(10)(iv) of Regulation S-K, please mark the exhibit index to
indicate that portions of your exhibits have been omitted, refile to clearly indicate where
information is omitted and include a prominent statement on the first page of each
redacted exhibit that certain identified information has been excluded from the exhibit
because it is both not material and is the type that the company treats as private or
confidential.
General
16.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 legal staff associated with the
review of this filing to discuss how to submit the materials, if any, to us for review.
            You may contact Kevin Stertzel at 202-551-3723 or Kevin Woody at 202-551-3629 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