SecProbe.io

CORRESP
 1
 filename1.htm

 September 29, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-1004

 Re:
 Neo-Concept International Group Holdings Limited

 Registration Statement on Form F-1, as amended

 File No. 333-288993

 Ladies and Gentlemen:

 As the placement agent of
the proposed offering of Neo-Concept International Group Holdings Limited (the "Company"), we hereby join the Company's
request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m., Eastern Time, on September
30, 2025, or as soon thereafter as is practicable.

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

 Very truly yours,

 Revere Securities LLC

 By:
 /s/ Dajiang Guo

 Name:
 Dajiang Guo

 Title:
 CEO, Head of Investment Banking

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 Neo-Concept
International group holdings limited

 VIA EDGAR

 September 29, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Eranga Dias

 Re:
 Neo-Concept International Group Holdings Ltd (CIK No. 0001916331)

 Request for Acceleration

 Registration Statement on Form F-1, as amended (File No. 333-288993)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the
General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the "Securities
Act"), Neo-Concept International Group Holdings Limited (the "Company") hereby requests that the effectiveness of the
above-referenced Registration Statement on Form F-1, as amended (the " Form F-1 Registration Statement ") be accelerated
to, and that the Form F-1 Registration Statement become effective at, 4:00 p.m., Eastern Time on September 30, 2025, or as soon thereafter
as practicable.

 Very truly yours,

 Neo-Concept International Group Holdings Limited

 By:
 /s/ Eva Yuk Yin Siu

 Name:
 Eva Yik Yin Siu

 Title:
 Chairlady of the Board, Director, Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 4, 2025

Eva Yuk Yin Siu
Chief Executive Officer
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No. 139-141 Hoi Bun Road
Kwun Tong, Kowloon , Hong Kong

 Re: Neo-Concept International Group Holdings Ltd
 Registration Statement on Form F-1
 Filed July 28, 2025
 File No. 333-288993
Dear Eva Yuk Yin Siu:

 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 Eranga Dias at 202-551-8107 with any questions.

 Sincerely,

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

CORRESP
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VIA EDGAR

March 29, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, NE

Washington, D.C. 20549

Attn: Alex King and Erin Purnell

    Re:
    Neo-Concept International Group Holdings Limited

    File No. 333-275242

    Registration Statement on Form F-1, as amended

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Revere Securities LLC, acting as representative of the underwriters, hereby joins Neo-Concept International Group Holdings Limited in
requesting acceleration of the effective date of the above-referenced Registration Statement so that it will become effective on April
1, 2024, at 4:00 p.m. Eastern Time, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act,
we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated March 26, 2024, to selected dealers,
institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

The undersigned confirm that it has complied and
will continue to comply with, and it has been informed or will be informed by participating dealers that it has complied 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,

    Revere Securities LLC

    By:
    /s/ Dajiang Guo

    Name:
    Dajiang Guo

    Title:
    Senior Managing Director,

Head of Investment Banking

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Neo-Concept International
Group Holdings Limited

VIA EDGAR

March 29, 2024

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Finance

Washington, D.C. 20549

Attn: Alex King and Erin Purnell

    Re:
    Neo-Concept International Group Holdings Limited

    Registration Statement on Form F-1

    Filed November 1, 2023, as amended

    File No. 333-275242

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Neo-Concept International Group Holdings Limited hereby requests acceleration of effectiveness
of the above referenced Registration Statement so that it will become effective at 4:00 pm, ET on April 1, 2024, or as soon as thereafter
practicable.

    Very truly yours,

    /s/ Eva Yuk

    Eva Yuk Yin Siu

    Chief Executive Officer and Director

    cc:
    Loeb & Loeb LLP

    Hunter Taubman Fischer & Li LLC

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January 4, 2024

Via Edgar Transmission

Mr. Alex King/ Ms. Erin Purnell

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Neo-Concept International Group Holdings Ltd

    Amendment No. 5 to

    Registration Statement on Form F-1

    Filed December 19, 2023

    File No. 333-275242

Dear Mr. King/Ms. Purnell:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated January 3, 2024 from the Securities and Exchange Commission
(the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Registration Statement on Form F-1 (the “Form F-1”).

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

Amendment No. 5 to Registration Statement on
Form F-1

Compensation of Directors and Executive Officers,
page 98

 1. Please update your compensation disclosure to reflect the most recently completed fiscal year. Refer
to Part I, Item 4.a. of Form F-1 and Part I, Item 6.B. of Form 20-F.

Response: We respectfully
advise the Staff that we have revised the disclosures on page 98.

Related Party Transactions, page 99

 2. We reissue comment 2 of our letter dated May 18, 2023. Your disclosure
in this section appears to be current as of June 30, 2023. Please update your disclosure to reflect transactions up to the date of the
document. Please refer to Part I, Item 4.a. of Form F-1 and Part I, Item 7.B. of Form 20-F.

Response: We respectfully
advise the Staff that we have revised the disclosures on pages 99, 100 and 101.

Index to Financial Statements, page F-1

 3. We note that you are a nonpublic company registering its initial public offering of securities and
that the audited financial statements included in the filing are now older than 12 months. To the extent you are relying on the 15-month
requirement for the age of your financial statements, please file the representations outlined in Instruction 2 to Item 8.A.4 of Form
20-F as an exhibit to the registration statement. Otherwise, please update the financial statements and other financial information in
the filing to comply with Item 8.A.4 of Form 20-F.

Response: We respectfully
advise the Staff that we have included the request for waiver and representation under item 8.A.4 of Form 20-F as exhibit 99.8.

* * *

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

Sincerely,

    /s/ Lawrence S. Venick

    Lawrence S. Venick

    Direct Dial: +852.3923.1188

    Email: lvenick@loeb.com

United States securities and exchange commission logo
January 3, 2024
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 5 to
Registration Statement on Form F-1
Filed December 19, 2023
File No. 333-275242
Dear Eva Yuk Yin Siu:
            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 28, 2023 letter.
Amendment No. 5 to Registration Statement on Form F-1
Compensation of Directors and Executive Officers, page 98
1.Please update your compensation disclosure to reflect the most recently completed fiscal
year. Refer to Part I, Item 4.a. of Form F-1 and Part I, Item 6.B. of Form 20-F.
Related Party Transactions, page 99
2.We reissue comment 2 of our letter dated May 18, 2023. Your disclosure in this section
appears to be current as of June 30, 2023. Please update your disclosure to reflect
transactions up to the date of the document. Please refer to Part I, Item 4.a. of Form F-1

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 January 3, 2024 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
January 3, 2024
Page 2
and Part I, Item 7.B. of Form 20-F.
Index to Financial Statements, page F-1
3.We note that you are a nonpublic company registering its initial public offering of
securities and that the audited financial statements included in the filing are now older
than 12 months. To the extent you are relying on the 15-month requirement for the age of
your financial statements, please file the representations outlined in Instruction 2 to Item
8.A.4 of Form 20-F as an exhibit to the registration statement. Otherwise, please update
the financial statements and other financial information in the filing to comply with
Item 8.A.4 of Form 20-F.
            Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Theodore Paraskevas

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SCHLUETER & ASSOCIATES, P.C.

5655 SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD VILLAGE, CO 80111

TELEPHONE: +1-303-292-3883

FACSIMILE: +1-303-648-5663

Email: hfs@schlueterintl.com

November 29, 2023

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mindy Hooker

    Re:

    Neo-Concept International Group Holdings Ltd.

    Amendment No. 1 to

    Registration Statement on Form F-1

    Filed November 16, 2023

    File No. 333-275242

Dear Ms. Hooker:

We represent Neo-Concept
International Group Holdings Ltd. (“Registrant” and “Company”) as U.S. counsel. We are submitting herewith Amendment
No.1 to the Registration Statement on Form F-1 (the “Registration Statement”) which is being filed vis EDGAR simultaneously
with this transmittal letter.

The purpose of this letter
is to respond to the comment letter dated November 28, 2023, from the Division of Corporation Finance, Office of Energy& Transportation
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission” or “SEC”) relating
to the above-referenced Registration Statement (the “Registration Statement”). For your convenience, the comments have been
reproduced below, followed by the Registrant’s response.

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

 1. We note your response to prior comment 1 and reissue. Please revise to reinsert Hong Kong in the definition of China, consistent with
prior comment 1 of our letter dated November 7, 2022, which asked you to revise the definition of the PRC or China to include Hong Kong
and Macau. Noting that Hong Kong should be included in the definition of China, please clarify your statements on the cover page that
the company and its subsidiaries have no material operations in the PRC and that the group has no operations in China. Please make sure
that you use consistent terms throughout the prospectus.

Response:

The disclosure has been revised to clarify that Hong Kong is included in the definition of the PRC or China and to clarify that the company
and its subsidiaries have no operations in Mainland China (defined as the PRC or China, excluding Hong Kong, Macau and Taiwan).

See Cover Page, pages iii, iv, 20, 82 and Resale
Prospectus Cover Page.

On behalf of the Company we appreciate your attention
to this matter. If you have any questions relating to the Registration Statement, please contact Eva Yuk Siu, the Registrant’s Chief
Executive Officer, at her email address eva@neo-concept.com.hk, or Kwok Fai Lau Patrick, the Registrant’s Chief Financial Officer,
at his email address of patrick.lau@neo-concept.com.hk.

Please copy any correspondence
or requests for information to the undersigned and Celia Velletri. The undersigned’s email is set forth above, and Ms. Velletri’s
email is cv@schueterintl.com. If you wish to speak with us, please feel free to call me at 303-868-3382 or Celia Velletri at 303-907-4842.

    Sincerely,

    /s/ Henry F. Schlueter

    cc:
    Neo-Concept International Group Holdings Limited

    Revere Securities LLC

    Hunter Taubman Fischer & Li LLC

CFN Lawyers

    WWC, P.C.

2

United States securities and exchange commission logo
November 28, 2023
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 1 to
Registration Statement on Form F-1
Filed November 16, 2023
File No. 333-275242
Dear Eva Yuk Yin Siu:
            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 14, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1
Cover Page
1.We note your response to prior comment 1 and reissue. Please revise to reinsert Hong
Kong in the definition of China, consistent with prior comment 1 of our letter dated
November 7, 2022, which asked you to revise the definition of the PRC or China to
include Hong Kong and Macau. Noting that Hong Kong should be included in the
definition of China, please clarify your statements on the cover page that the company and
its subsidiaries have no material operations in the PRC and that the group has no
operations in China. Please make sure that you use consistent terms throughout the
prospectus.

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 November 28, 2023 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
November 28, 2023
Page 2
            Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Henry Schlueter

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SCHLUETER & ASSOCIATES, P.C.

5655 SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD VILLAGE, CO 80111

TELEPHONE: +1-303-292-3883

FACSIMILE: +1-303-648-5663

Email: hfs@schlueterintl.com

November 16, 2023

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mindy Hooker

    Re:
    Neo-Concept International Group Holdings Ltd.

    Registration Statement on Form F-1

    Filed November 1, 2023

    File No. 333-275242

Dear Ms. Hooker:

We represent Neo-Concept
International Group Holdings Ltd. (“Registrant” and “Company”) as U.S. counsel. We are submitting herewith Amendment
No.1 to the Registration Statement on Form F-1 (the “Registration Statement”) which is being filed vis EDGAR simultaneously
with this transmittal letter.

The purpose of this letter
is to respond to the comment letter dated November 14, 2023, from the Division of Corporation Finance, Office of Energy& Transportation
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission” or “SEC”) relating
to the above-referenced Registration Statement (the “Registration Statement”). For your convenience, the comments have been
reproduced below, followed by the Registrant’s response.

Form F-1 filed November 1, 2023

Cover Page

1. We note your disclosure in connection with the CSRC Trial Administrative
Measures that the Group has no operations in China. We note also that you earlier define China as including China and Hong Kong. Please
revise or advise. Refer to prior comment 1 of our letter dated November 7, 2022.

Response:

The disclosure has been revised to clarify that
Hong Kong is not included in the definition of China.

See Cover Page, page iv, and Resale Prospectus
Cover Page.

Prospectus Summary

The Offering, page 13

2. Please revise the “Lock-up” section here and on page
116 to highlight the fact that your principal controlling shareholder is seeking to sell shares under the Resale Prospectus.

Response:

The disclosure has been revised to highlight the fact that
the principal controlling shareholder is seeking to sell shares under the Resale Prospectus.

See pages 13, 36 and 116.

Risk Factors

Because our initial public offering price is substantially higher than our pro forma net tangible book value per share..., page 36

3. We note that you removed the specific disclosure regarding dilution
in this section. Please reinsert the disclosure to describe the specific risks to investors. Refer to Item 105(a) of Regulation S-K.

Response:

The disclosure has been revised to disclose the
specific risks to investors.

See page 36.

Shares Eligible for Future Sale, page 116

4. We note your change of underwriter. Please revise the Lock-up Agreements
section to remove the disclosure that certain directors, executive officers, and principal shareholders must seek written consent from
Univest Securities before seeking to avoid the lock-up agreement and transfer or sell shares.

Response:

The disclosure has been revised to clarify that written consent
must be received from Revere Securities LLC.

See page 116.

Resale Prospectus Cover Page, page A-1

5. We note your disclosure that you “anticipate that” the
selling shareholder will sell its ordinary shares at the price at which you sell the shares in the public offering. Please revise to clearly
state that the selling shareholder will sell its ordinary shares at the public offering price, until the ordinary shares are quoted on
the Nasdaq Capital Market. We note also your disclosure that the selling shareholder will not be able to sell its shares unless your ordinary
shares are approved for listing on the Nasdaq Capital Market. Please revise to state clearly that the selling shareholder will not sell
its shares unless the public offering is completed.

Response:

The disclosure has been revised to clearly state that the
selling shareholder will sell its ordinary shares at the public offering price, until the ordinary shares are quoted on the Nasdaq Capital
Market and that no ordinary shares will be sold unless the public offering has been completed.

See Resale Prospectus Cover Page, pages Alt-1 and Alt-4.

    2

On behalf of the Company we appreciate your attention
to this matter. If you have any questions relating to the Registration Statement, please contact Eva Yuk Siu, the Registrant’s Chief
Executive Officer, at her email address eva@neo-concept.com.hk, or Kwok Fai Lau Patrick, the Registrant’s Chief Financial Officer,
at his email address of patrick.lau@neo-concept.com.hk.

Please copy any correspondence
or requests for information to the undersigned and Celia Velletri. The undersigned’s email is set forth above, and Ms. Velletri’s
email is cv@schueterintl.com. If you wish to speak with us, please feel free to call me at 303-868-3382 or Celia Velletri at 303-907-4842.

    Sincerely,

    /s/ Henry F. Schlueter

    cc:
    Neo-Concept International Group Holdings Limited

    Revere Securities LLC

    Hunter Taubman Fischer & Li LLC

CFN Lawyers

    WWC, P.C.

3

United States securities and exchange commission logo
November 14, 2023
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Registration Statement on Form F-1
Filed November 1, 2023
File No. 333-275242
Dear Eva Yuk Yin Siu:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Form F-1 filed November 1, 2023
Cover Page
1.We note your disclosure in connection with the CSRC Trial Administrative Measures that
the Group has no operations in China. We note also that you earlier define China as
including China and Hong Kong. Please revise or advise. Refer to prior comment 1 of our
letter dated November 7, 2022.
Prospectus Summary
The Offering, page 13
2.Please revise the "Lock-up" section here and on page 116 to highlight the fact that your
principal controlling shareholder is seeking to sell shares under the Resale Prospectus.

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 November 14, 2023 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
November 14, 2023
Page 2
Risk Factors
Because our initial public offering price is substantially higher than our pro forma net tangible
book value per share..., page 36
3.We note that you removed the specific disclosure regarding dilution in this section. Please
reinsert the disclosure to describe the specific risks to investors. Refer to Item 105(a) of
Regulation S-K.
Shares Eligible for Future Sale, page 116
4.We note your change of underwriter. Please revise the Lock-up Agreements section to
remove the disclosure that certain directors, executive officers and principal shareholders
must seek written consent from Univest Securities before seeking to avoid the lock-up
agreement and transfer or sell shares.
Resale Prospectus Cover Page, page A-1
5.We note your disclosure that you "anticipate that" the selling shareholder will sell its
ordinary shares at the price at which you sell the shares in the public offering. Please
revise to clearly state that the selling shareholder will sell its ordinary shares at the public
offering price, until the ordinary shares are quoted on the Nasdaq Capital Market. We note
also your disclosure that the selling shareholder will not be able to sell its shares unless
your ordinary shares are approved for listing on the Nasdaq Capital Market. Please revise
to state clearly that the selling shareholder will not sell its shares unless the public offering
is completed.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Henry Schlueter

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SCHLUETER & ASSOCIATES, P.C.

5655 SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD VILLAGE, CO 80111

TELEPHONE: +1-303-292-3883

FACSIMILE: +1-303-648-5663

Email: hfs@schlueterintl.com

November 1, 2023

VIA EDGAR

U.S. Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Neo-Concept International Group Holdings Limited

    Registration Statement on Form F-1

Ladies and Gentlemen:

On
behalf of our client, Neo-Concept International Group Holdings Limited (the “Company”), a foreign private issuer organized
under the laws of the Cayman Islands, we are hereby filing a registration statement on Form F-1 (the “Registration Statement”),
which is being filed via EDGAR simultaneously with this transmittal letter. The Registration Statement relates to the planned initial
public offering of the Company’s ordinary shares, $0.0000625 par value. Certain additional exhibits to the Registration Statement
will be submitted in subsequent filings.

The
Company previously submitted a draft registration statement on a confidential basis in accordance with Section 6(e) of the Securities
Act of 1933, as amended (the “Securities Act”) and has been advised by the Staff that they have no further comments to the
draft registration statement. Attached is a red lined or marked copy of the Registration Statement to show certain revisions that have
been made since the last confidential submission, including a change in the underwriter. The Company confirms that the date on which the
Company first conducts a road show for its proposed initial public offering will occur no sooner than 15 days after this filing.

On behalf of the Company, we appreciate your attention to this matter.
If you have any questions or wish to discuss any matters with respect to this filing, please do not hesitate to contact me at (303) 868-3382
(email: hfs@schlueterintl.com) or my colleague Celia Velletri at (303) 907-4842 (email: cv@schlueterintl.com).

Thanks
in advance for your cooperation in connection with this matter.

    Sincerely,

    /s/ Henry F. Schlueter

    cc:
    Neo-Concept International Group Holdings Limited

    Revere Securities LLC

    Hunter Taubman Fischer & Li LLC

CFN Lawyers

    WWC, P.C.

United States securities and exchange commission logo
May 18, 2023
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 3 to
Draft Registration Statement on Form F-1
Submitted May 8, 2023
CIK Number 0001916331
Dear Eva Yuk Yin Siu:
            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.
Amended Draft Registration Statement
Risk Factors
If the Chinese government chooses to exert more oversight and control over offerings..., page 19
1.We note your disclosure on page 20 that you understand that the Group is not required to
complete filing procedures with the CSRC. Please revise to expand your disclosure here
and on the cover page to provide support for this conclusion. Noting your statement on
page 128 that certain legal matters as to Hong Kong law will be passed upon for you by
CFN Lawyers, please address whether you have reached your conclusion based on

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 May 18, 2023 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
May 18, 2023
Page 2
discussions with counsel. In addition, please have CFN Lawyers file an opinion regarding
Hong Kong legal matters.
Related Party Transactions, page 93
2.We note your response to comment 1 and reissue. Please update your disclosure to reflect
any transactions with related parties up to the date of the prospectus. Refer to Part I, Item
4.a. of Form F-1 and Part I, Item 7.B. of Form 20-F.
            You may contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
February 10, 2023
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted February 1, 2023
CIK Number 0001916331
Dear Eva Yuk Yin Siu:
            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 No. 2 to Draft Registration Statement on Form F-1 submitted February 1, 2023
Related Party Transactions, page 100
1.Please update your disclosure to reflect any transactions with related parties up to the date
of the prospectus.

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 February 10, 2023 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
February 10, 2023
Page 2
Index to Consolidated Financial Statements, page F-1
2.We note from the cover page that this is your initial public offering and that prior to this
offering there has been no public market for your Ordinary Shares. Please tell us how you
considered the guidance in Item 8.A.4 of Form 20-F and the instructions relating to that
Item when updating your financial statements. To the extent you are able to make the
representations outlined in the guidance and intend to comply with the 15-month update
requirement, please file the required representations as an exhibit to the registration
statement.
Schedule 1 - Parent Only Financial Information, page S-1
3.Revise to briefly explain why the condensed parent company only financial information is
expressed in United States dollars. Tell us why the amount presented here for Ordinary
Shares of the parent company is different from the US$1,118 shown on the interim
consolidated balance sheet on page F-29, or revise to resolve the inconsistency.
            You may contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
November 7, 2022
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted October 24, 2022
CIK Number 0001916331
Dear Eva Yuk Yin Siu:
            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.
Amended Draft Registration Statement
Cover Page
1.We note your revisions in response to comment 1. Your references to "China" appear to
exclude Hong Kong and Macau. Revise the definition of the PRC or China to include
Hong Kong and Macau and revise the disclosure throughout your amendment
accordingly.
2.We note your disclosure that the offering is contingent upon listing on the Nasdaq Capital

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 November 7, 2022 Page 2
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
November 7, 2022
Page 2
Market or another national exchange. Please explain the actions you will take if you do
not receive approval to list on Nasdaq. Please ensure the disclosure is consistent with your
underwriting agreement.
3.To the extent you intend to proceed with your offering if your Nasdaq listing is denied,
revise your cover page to indicate that the offering is not contingent on Nasdaq approval
of your listing application and that if the shares are not approved for listing, you may
experience difficulty selling your shares.  Include risk factor disclosures to address the
impact on liquidity and the value of shares.
Risk Factors, page 14
4.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.
            You may contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

United States securities and exchange commission logo
September 26, 2022
Eva Yuk Yin Siu
Chairlady of the Board & CEO
Neo-Concept International Group Holdings Ltd
10/F, Seaview Centre
No.139-141 Hoi Bun Road
Kwun Tong
Kowloon, Hong Kong
Re:Neo-Concept International Group Holdings Ltd
Draft Registration Statement on Form F-1
Submitted August 30, 2022
CIK No. 0001916331
Dear Ms. Siu:
            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.
Form F-1 Submitted August 30, 2022
Prospectus Cover Page, page i
1.Clearly disclose how you will refer to the holding company, subsidiaries, and other
entities when providing the disclosure throughout the document so that it is clear to
investors which entity the disclosure is referencing and which subsidiaries or entities are
conducting the business operations. Refrain from using terms such as “we” or “our” when
describing activities or functions of a subsidiary or other entity. For example, disclose, if
true, that your subsidiaries and/or other entities conduct operations in China, that the other
entity is consolidated for accounting purposes but is not an entity in which you own

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 September 26, 2022 Page 2
 FirstName LastNameEva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
September 26, 2022
Page 2
equity, and that the holding company does not conduct operations. Disclose clearly the
entity (including the domicile) in which investors are purchasing an interest.
Prospectus Summary, page 1
2.Provide a clear description of how cash is transferred through your organization. Disclose
your intentions to distribute earnings or settle amounts owed under your operating
structure. Quantify any cash flows and transfers of other assets by type that have occurred
between the holding company and its subsidiaries, and direction of transfer. Quantify any
dividends or distributions that a subsidiary has made to the holding company and which
entity made such transfer, and their tax consequences. Similarly quantify dividends or
distributions made to U.S. investors, the source, and their tax consequences. Your
disclosure should make clear if no transfers, dividends, or distributions have been made to
date. Describe any restrictions on foreign exchange and your ability to transfer cash
between entities, across borders, and to U.S. investors. Describe any restrictions and
limitations on your ability to distribute earnings from the company, including your
subsidiaries, to the parent company and U.S. investors as well as the ability to settle
amounts owed under applicable agreements.
Risk Factors
Our business is in direct competition with NCH, an affiliated company, page 13
3.Please revise your disclosure to specify the definition of "Neo Concept Group."
We rely on two principal suppliers for supplies of raw materials, manufacturing services and
logistics services, page 25
4.We note your risk factor that your principal suppliers "terms of services [...] may be
susceptible to fluctuations with regard to pricing, timing and quality." Please update this
risk factor if recent inflationary pressures have materially affected your operations. In this
regard, identify the types of inflationary pressures you are facing and how your business
has been affected.
Dilution, page 47
5.You indicate, in the first introductory paragraph, that net tangible book value represents
"total net tangible assets less intangible assets (right-of-use assets and intangible assets)."
The parenthetical reference to right of use assets and intangible assets appears to be
unnecessary since you have no right of use assets at December 31, 2021 and the reference
to intangible assets is repetitive. Please remove the parenthetical disclosure or advise us.
Exclusive Territory and Non-Competition Agreement, page 52
6.We note your disclosure that the Company and the Parent Group have entered into an
Exclusive Territory and Non-Competition Agreement. Please provide additional
disclosure detailing what countries/regions constitute the "Protected Territories," as well

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 September 26, 2022 Page 3
 FirstName LastNameEva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
September 26, 2022
Page 3
as the specific "businesses currently conducted by us through our Operating Subsidiaries
in North America and Europe," that NCH has agreed to not compete with.
Liquidity and Capital Resources
Cash Flow Sufficiency, page 66
7.Please provide more robust disclosure explaining how you intend to meet your cash flow
requirements.  In this regard, discuss your plan to meet your debt obligations and
operating needs as it appears your obligations that will come due in twelve months or
less are greater than cash generated from operations in the periods presented.
Business
Overview, page 68
8.We note your disclosure on page 74 that your customer base in Canada and the U.S.
accounts for over 95% of total revenues, with one Canadian based retailer contributing
approximately 94.5% of revenues.  We note, however, that your disclosure in this section
appears to give equal weight to your European market and the licensed brand in the
UK.  Please therefore revise your disclosure in this section to more specifically explain
your operations in Canada and the U.S.  In addition, given your apparent dependence on
one single Canadian retailer, please revise your disclosure throughout to provide an
accurate and current discussion of the company's market, focus and business operations.
Notes to the Consolidated Financial Statements
Organization and reorganization, page F-7
9.We note your disclosure indicating that the reorganization is considered a recapitalization
of entitles under common control.  Please expand to discuss the nature of this accounting
treatment, including, if true, that the historical carrying values of the relevant entities will
be carried forward with no step up in basis of net assets or recognition of goodwill. Refer
to ASC 805-50-50-3.  Additionally, please disclose how you accounted for the distribution
and disposal of Neo-Concept NY in December 2021.
2. Summary of Significant Accounting Policies and Practices, page F-8
10.Your liquidity discussion on page 63 indicates that you were able to speed up your
collection of accounts receivable by way of factoring to strengthen your cash position and
liquidity management. Please revise the notes to financial statements to describe
your factoring arrangements and how you account for them.
Revenue Recognition, page F-12
11.You disclose that you derive revenue principally from sales of private-labelled apparel
products and sales of own-branded apparel products in your retail stores.  However, your
disclosures on page 1 indicate that you offer a full suite of services in the apparel supply
chain, including market trend analysis, product design and development, raw material

 FirstName LastNameEva Yuk Yin Siu
 Comapany NameNeo-Concept International Group Holdings Ltd
 September 26, 2022 Page 4
 FirstName LastName
Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
September 26, 2022
Page 4
sourcing, production and quality controls and logistics management.  Please revise this
note to disclose how you account for the revenue generated from each of the products
and services you offer to your customers.
12.You disclose here that the transaction price for sales of private-labelled apparel products
does not include variable consideration provisions for right of return as you do not have a
sales return policy and no sales return is offered.  However, on page 75 you also indicate
that where quality issues are concerned, you follow up with your customers on any claims
or requests for product return, payment refund, rectification or price discount. Please
explain to us how these two statements are consistent with each other, or as appropriate,
revise to eliminate the inconsistency.
11. Right-Of-Use Assets and Lease Liabilities, page F-20
13.You disclose that your right-of-use assets and relevant lease liabilities originated from
your rented premises in New York by Neo-Concept NY, and were eliminated upon the
disposal of Neo-Concept NY in December 2021. We note, however, from page 26 that as
of December 31, 2021 you leased three retail store locations in the UK under operating
leases.  Please revise to disclose how you accounted for these UK location leases.  Explain
why no related right-of-use assets and lease liabilities were reflected on your balance sheet
at December 31 2021.
Exhibit 23.1, page X-1
14.Please file an updated consent from your independent registered public accounting firm,
with your first live filing, that also consents to the firm being named in the "Experts"
section of the filing.
General
15.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 Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing