SecProbe.io

CORRESP
 1
 filename1.htm

 August 8, 2025

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance

 Office of Manufacturing

 100 F Street, N.E.
Washington, D.C. 20549

 Attention: Kevin Stertzel, Kevin Woody, Eranga Dias and Jay Ingram

 Re:

 Papa Medical Inc. (CIK No. 0002024283)
 Registration Statement on Form S-1, as amended
 Initially Filed on November 22, 2024
 File No. 333-283405

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
under the Securities Act of 1933, as amended (the "Act"), the undersigned hereby joins in the request of Papa Medical Inc.
that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 10:00
a.m., Eastern Time, on August 12, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel,
Loeb & Loeb LLP, request by telephone that such Registration Statement be declared effective.

 Pursuant to Rule 460 of the General Rules and Regulations of the Securities
and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there will be distributed to each underwriter
or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary
prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

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

 [ Signature Page Follows ]

 Very truly yours,

 US TIGER SECURITIES

 By:
 /s/ Jack Ye

 Name:
 Jack Ye

 Title:
 Managing Director

 [ Signature Page to Underwriter's Acceleration Request Letter ]

CORRESP
 1
 filename1.htm

 Papa Medical Inc.

 August 8, 2025

 Via EDGAR

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:
 Kevin Stertzel, Kevin Woody, Eranga Dias and Jay Ingram

 Re:
 Papa Medical Inc. (CIK No. 0002024283)

 Registration Statement on Form S-1, as amended

 Initially Filed on November 22, 2024

 File No. 333-283405

 Dear Ladies and Gentlemen:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Papa Medical Inc. hereby requests that the effectiveness
of the above-referenced Registration Statement on Form S-1, as amended, be accelerated to and that the Registration Statement become
effective at 10:00 a.m., Eastern Time, on August 12, 2025, or as soon thereafter as practicable.

 Very truly yours,

 Papa Medical Inc.

 By:
 /s/ Jian Hua

 Name:
 Jian Hua

 Title:
 Chief Executive Officer and Director

CORRESP
 1
 filename1.htm

 Erik L. Mengwall

 Partner

 James A. Prestiano

 Senior Counsel

 345 Park Avenue
New York, NY 10154

 Direct 212.407.4050

 212 407 4831
 Main 212.407.4000
 Fax 212.407.4990
emengwall@loeb.com
 jprestiano@loeb.com

 July 14, 2025

 Office of Manufacturing

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Kevin Stertzel, Kevin Woody, Eranga Dias and Jay Ingram

 Re: Papa Medical Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed June 27, 2025
 File No. 333-283405

 Ladies and Gentlemen:

 On behalf of our client, Papa Medical Inc. (the " Company "),
we hereby provide a response to the comments in the letter dated as of July 9, 2025 from the staff (the " Staff ") of
the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the " Staff's Letter ") regarding
the above-referenced Amendment No. 1 to Registration Statement on Form S-1 filed on June 27, 2025.

 Contemporaneously, the Company is submitting an Amendment No. 2 to
the Registration Statement via EDGAR (the " Amended Registration Statement "), which reflects the Company's responses
to the Staff's Letter and updates to the net proceeds and table of fees and expenses. For ease of reference, each comment contained
in the Staff's Letter is printed below and is followed by the Company's response. All page references in the responses set
forth below refer to the page numbers in the Amended Registration Statement.

 Draft Registration Statement
on Form S-1

 General

 1. We note your disclosure on page i stating that this prospectus "contains certain estimates and information concerning [y]our
industry, including market position, market size, and growth rates of the markets in which we participate" and that you "have
not independently verified the accuracy or completeness of the data contained in these industry publications and reports." This statement
appears to imply a disclaimer of responsibility for this information in the prospectus. Please either revise this statement to remove
such implication or specifically state that you are liable for all information in the prospectus.

 Response: In response to the Staff's
comment, the Company has removed relevant disclosure on page i and page 53 of the Amended Registration Statement.

 2. We note from the revisions throughout this amended registration statement that your business has changed from being a "cannabis
dosing solution provider" to "Hemp dosing solution provider." Please expand your disclosure to provide background and reasoning
as to this change. If material, also expand your disclosure in the management's discussion section and other appropriate sections in this
registration statement discussing the reason for this shift as well as consequences, including but not limited to, relaxed/heightened
scrutiny from regulatory bodies, changes to business growth forecasts and/or revenue, expenses incurred as a result of this shift etc.

 Response: The
Company respectfully advises the Staff that it has not changed its business, operations, or any of the products it sells in any material
respect since the date of the Company's original registration statement on Form S-1. During the IPO process, the Company engaged
a special regulatory counsel to review the registration statement and advise the Company as to how to correctly disclose from a U.S.
regulatory perspective that the Company sells products derived from federally legal hemp as permitted under the Agriculture Improvement
Act of 2018 and the laws of various states. 1 The Company determined that the use of the umbrella word "cannabis"
as a lay synonym for "hemp" can be confusing in the evolving legal landscape in which we operate. As a result, the Company
revised the description of its business to clarify and correctly describe its business operations as a "Hemp dosing solution provider."

 The Company notes
that this editorial change does not reflect, nor does it effect, any change in its underlying business, the products it sells, its
regulatory posture, or its risk profile. The Company does not sell products containing cannabis with a concentration of Delta-9 THC
in excess of 0.3% on a dry weight basis. Accordingly, the Company believes that replacing "cannabis" with
"hemp" in describing its business, enhances the accuracy of its disclosures and investor understanding of its business
operations. As neither the Company's business operations nor products have changed, there are no anticipated changes to its business
growth forecasts and/or revenue as a result of this clarification.

 Cover Page

 3. Please revise your cover page to identify the name(s) of the lead or managing underwriter(s). See Item 501(b)(8) of Regulation S-K.

 Response: In response to the
Staff's comment, the Company has amended the cover page of the Amended Registration Statement to identify the lead
underwriter.

 1
 The Agriculture Improvement Act of 2018 (also known as the 2018 Farm Bill) removed hemp from the definition of marijuana as used in the U.S. federal Controlled Substances Act ("CSA"). Hemp and marijuana are both varieties of the cannabis plant. Hemp is defined as "the plant Cannabis sativa L. and any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis." 7 U.S.C. § 1639(o). The cannabis plant and most products produced from that plant remain controlled substances subject to the CSA, unless they meet the statutory definition of hemp.

 2

 Please call me at (212) 407-4050 or my colleague,
James A. Prestiano at (212) 407-4831 if you would like additional information with respect to any of the foregoing. Thank you.

 Sincerely,

 /s/ Erik Mengwall

 Erik Mengwall

 Partner

 cc:
 James A. Prestiano, Loeb & Loeb LLP

 3

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 9, 2025

Jian Hua
Chief Executive Officer
Papa Medical Inc.
202 North California Ave
City of Industry, CA 91744

 Re: Papa Medical Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed June 27, 2025
 File No. 333-283405
Dear Jian Hua:

 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 August 27,
2024 letter.

Amendment No. 1 to Registration Statement on Form S-1 filed June 27, 2025
General

1. We note your disclosure on page i stating that this prospectus "contains
certain
 estimates and information concerning [y]our industry, including market
position,
 market size, and growth rates of the markets in which we participate"
and that you
 "have not independently verified the accuracy or completeness of the
data contained
 in these industry publications and reports." This statement appears to
imply a
 disclaimer of responsibility for this information in the prospectus.
Please either revise
 this statement to remove such implication or specifically state that you
are liable for
 all information in the prospectus.
 July 9, 2025
Page 2
2. We note from the revisions throughout this amended registration
statement that your
 business has changed from being a "cannabis dosing solution provider" to
"Hemp
 dosing solution provider." Please expand your disclosure to provide
background and
 reasoning as to this change. If material, also expand your disclosure in
the
 management's discussion section and other appropriate sections in this
registration
 statement discussing the reason for this shift as well as consequences,
including but
 not limited to, relaxed/heightened scrutiny from regulatory bodies,
changes to
 business growth forecasts and/or revenue, expenses incurred as a result
of this shift
 etc.
Cover Page

3. Please revise your cover page to identify the name(s) of the lead or
managing
 underwriter(s). See Item 501(b)(8) of Regulation S-K.

 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 Jay Ingram at
202-551-3397 with any
other questions.

 Sincerely,

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

August 27, 2024
Jian Hua
Chief Executive Officer
Papa Medical Inc.
202 North California Ave
City of Industry, CA 91744
Re:Papa Medical Inc.
Draft Registration Statement on Form S-1
Submitted July 31, 2024
CIK No. 0002024283
Dear Jian Hua:
            We have reviewed your draft registration statement and have the following comment(s).
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do not believe an
amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form S-1 filed July 31, 2024
Risk Factors, page 7
1.We note your disclosure throughout this registration statement stating that Mr. Jian Hua,
your chief executive officer and director, holds 83.6% of your common stock and
that Papa Medical Inc. or its subsidiaries/operating companies have entered into
agreements with other entities that are either owned by or have an ownership interest in
by Mr. Hua—including rental agreements and supplier relationships etc. Please discuss in
a separate risk factor the risks posed by this arrangement. Specifically discuss whether
other entities without an affiliation with Mr. Hua were considered when considering
potential leased properties and suppliers. Also discuss whether prices paid to entities that
are affiliated with Mr. Hua such as lease rates and inventory/supplies prices are in line
with market rates of other non-affiliated entities.

August 27, 2024
Page 2
Our business may be impacted by supply chain issues..., page 13
2.We note your risk factor that your supply chain may be impacted by port delays. Update
your risks characterized as potential if recent supply chain disruptions that are not limited
to port delays have impacted your operations.
Outbreaks of infectious diseases, epidemics, natural disasters or other events have materially and
adversely affected..., page 13
3.We note your disclosure stating that you "carefully evaluate potential outcomes and work
to mitigate risks" related to inflation and other macroeconomic risks.  Please update your
disclosure to identify actions planned or taken, if any, to mitigate inflationary pressures.
Substantially all of our executive officers and directors are located in mainland China..., page 15
4.We note your disclosure stating that except for your Chief Financial Officer and Chief
Operating Officer, all of your executive officers and directors are located in mainland
China. Please revise your risk factors section to discuss any potential risks related to PRC
government regulations. Specifically, discuss whether you are subject to, or potentially
could be subject to PRC regulations including but not limited to, CSRC's Trial
Administrative Measures. If you believe that you are not subject to these regulations,
provide your analysis as to why.
Certain Relationships and Related Party Transactions
Related Party Transactions with Shenzhen Feellife, page 70
5.We note your disclosure of various agreements with Shenzhen Feellife and Shenzhen
LFS, including a purchase agreement for cannibis and consuming E-vapors.   Please
expand your disclosure to include the purchase amounts paid to these related parties for
every period presented.  Your current disclosure only provides the amount of revenue
generated from your related party transactions.
Financial Statements
General, page F-1
6.In your next amendment, please provide current interim financial information and related
MD&A.   Refer to Rules 8-03 and 8-08 of Regulation S-X for guidance.
            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 Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing