SecProbe.io

CORRESP
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Ping An Biomedical Co., Ltd.

22/F, China United Plaza

1002-1008, Tai Nan West Street

Cheung Sha Wan, Kowloon

Hong Kong

February 24, 2026

VIA EDGAR

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, NE

Washington, D.C. 20549

Attn: Erin Donahue

    Re:
    Ping An Biomedical Co., Ltd.

    Registration Statement on Form F-1

    Filed February 13, 2026

    File No. 333-293481

Dear Ms. Donahue:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended, Ping An Biomedical Co., Ltd. hereby requests acceleration of effectiveness of
the above referenced Registration Statement on Form F-1 (File No. 333-293481) so that it will become effective at 5:00 p.m. ET on Thursday,
February 26, 2026, or as soon as thereafter practicable.

    Very truly yours,

    /s/ Pijun Liu

    Pijun Liu

    Chief Executive Officer

    cc:
    McLaughlin & Stern, LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                           February 20, 2026

Pijun Liu
Chief Executive Officer
Ping An Biomedical Co., Ltd.
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon
Hong Kong

       Re: Ping An Biomedical Co., Ltd.
           Registration Statement on Form F-1
           Filed February 13, 2026
           File No. 333-293481
Dear Pijun Liu:

       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>

CORRESP
 1
 filename1.htm

 June 27, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Majestic Ideal Holdings Ltd

 Registration Statement on Form F-1

 File No. 333- 282499

 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 Majestic Ideal Holdings
Ltd that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 5:00 p.m.
Washington D.C. time on June 30, 2025, or as soon thereafter as practicable.

 Pursuant to Rule 460 of the General Rules and Regulations
under the Act, the undersigned advises that it intends to distribute approximately 350 copies of the Preliminary Prospectus dated April
14, 2025 to prospective underwriters and dealers, institutional investors, retail investors and others.

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

 Very truly yours,

 CRAFT CAPITAL MANAGEMENT LLC

 By:
 / s/ Stephen Kiront

 Name:
 Stephen Kiront

 Title:
 Chief Operating Officer

 WESTPARK CAPITAL, INC.

 By:
 / s/ Jason Stern

 Name:
 Jason Stern

 Title:
 Chief Operating Officer

CORRESP
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 Majestic Ideal Holdings Ltd

 VIA EDGAR

 June 27, 2025

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 Office of Finance

 Washington, D.C. 20549

 Attn: Thomas Jones and Jay Ingram

 Re:
 Majestic Ideal Holdings Ltd

 Registration Statement on Form F-1

 Filed October 4, 2024, as amended

 File No. 333- 282499

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Majestic Ideal Holdings Ltd hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 5:00 pm ET on June 30, 2025, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Yuk Yin Judy Li

 Yuk Yin Judy Li

 Chairperson of the Board of Directors

 cc:
 Loeb & Loeb LLP

 Haneberg Hurlbert PLC

CORRESP
 1
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 April 14, 2025

 Via Edgar Transmission

 Mr. Thomas Jones/ Mr. Jay Ingram

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 Washington, D.C. 20549

 Re:

 Majestic Ideal Holdings Ltd
 Amendment No. 5 to Registration Statement on Form
 F-1
 Filed March 25, 2025
 File No. 333-282499

 Dear Mr. Jones/ Mr. Ingram:

 As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated March 31, 2025 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 filed March 25, 2025

 Selling Shareholders, page 91

 1. Please revise the disclosure on pages 91 and Alt-21 to discuss the details of the transaction(s) in
which the selling shareholders received the shares covered by the amended registration statement.

 Response: We respectfully advise the Staff that we have updated the offering
terms to amend the resale shareholder, and removed the selling shareholder.

 2. Please revise the disclosure on page Alt-21 to discuss, if applicable, the relationship between Action
Holdings Limited and the two resale shareholders.

 Response: We respectfully advise the Staff that we have updated the offering terms to amend the resale shareholder, and removed the selling shareholder.

 Undertakings, page II-1

 3. Please revise to provide the undertakings required by Item 512(a) of Regulation S-K.

 Response: We
respectfully advise the staff that we have updated the disclosure under Part II of the Form F-1.

 Exhibit Index, page II-2

 4. Please ensure that you have filed the underwriting agreement as an exhibit. In this regard, we note
the new disclosure on page 108 that the "Company and the Selling Shareholder will enter into an underwriting agreement with Craft
Capital Management, LLC and WestPark Capital, Inc." However, you indicate in the asterisk footnote on page II-3 that the form of
underwriting agreements was previously filed.

 Response: We respectfully
advise the Staff that we have exhibited an updated underwriting agreement together with this filing.

 * * *

 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

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 31, 2025

Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong

 Re: Majestic Ideal Holdings Ltd
 Amendment No. 5 to Registration Statement on Form F-1
 Filed March 25, 2025
 File No. 333-282499
Dear Suqin Li:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Amendment No. 5 to Registration Statement on Form F-1 filed March 25, 2025
Selling Shareholders, page 91

1. Please revise the disclosure on pages 91 and Alt-21 to discuss the
details of the
 transaction(s) in which the selling shareholders received the shares
covered by the
 amended registration statement.
2. Please revise the disclosure on page Alt-21 to discuss, if applicable,
the relationship
 between Action Holdings Limited and the two resale shareholders.
 March 31, 2025
Page 2
Undertakings, page II-1

3. Please revise to provide the undertakings required by Item 512(a) of
Regulation S-K.

Exhibit Index, page II-2

4. Please ensure that you have filed the underwriting agreement as an
exhibit. In this
 regard, we note the new disclosure on page 108 that the "Company and the
Selling
 Shareholder will enter into an underwriting agreement with Craft Capital
 Management, LLC and WestPark Capital, Inc." However, you indicate in the
asterisk
 footnote on page II-3 that the form of underwriting agreements was
previously filed.

 Please contact Kevin Woody at 202-551-3629 if you have questions
regarding
comments on the financial statements and related matters. Please contact Thomas
Jones at
202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Lawrence S. Venick, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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November 4, 2024

Via Edgar Transmission

Mr. Thomas Jones / Jay Ingram

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Majestic Ideal Holdings Ltd

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

    Filed October 23, 2024

    File No. 333-282499

Dear Mr. Jones / Ms. Ingram:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated November 1, 2024 from the Securities and Exchange Commission
(the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Draft 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. 1 to Registration Statement on Form F-1 filed October
23, 2024

Compensation of Directors and Executive Officers, page 91

1. Please update your compensation disclosure to reflect
the fiscal year ended September 30, 2024. Currently, your disclosure is as of March 31, 2024.

Response:

We respectfully advise the
Staff that we have amended the disclosure on page 91 to reflect the above.

* * *

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

November 1, 2024
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed October 23, 2024
File No. 333-282499
Dear Suqin Li:
            We have reviewed your amended registration statement and have the following
comment.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1 filed October 23, 2024
Compensation of Directors and Executive Officers, page 91
1.Please update your compensation disclosure to reflect the fiscal year ended September
30, 2024. Currently, your disclosure is as of March 31, 2024.

November 1, 2024
Page 2
            Please contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related
matters. Please contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Lawrence S. Venick, Esq.

CORRESP
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October 23, 2024

Via Edgar Transmission

Mr. Thomas Jones / Jay Ingram

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Majestic Ideal Holdings Ltd

    Registration Statement on Form F-1

    Filed October 4, 2024

    File No. 333-282499

Dear Mr. Jones / Mr. Ingram:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated October 22, 2024 from the Securities and Exchange Commission
(the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Draft 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.

Registration Statement on Form F-1 filed October 4, 2024

Certain Relationships and Related Party Transactions, page 98

 1. Please update your disclosure so that it reflects the related
party transactions as of the date of the prospectus. Refer to Item 7.B of Form 20-F. Currently, your disclosure is as of March 31, 2024.

Response: We respectfully advise
the Staff that we have revised the disclosure on page 98 to address the above.

General

 2. We note your disclosure in the Resale Prospectus Shareholders Plan of Distribution section that your
selling shareholders may sell their securities through use of a broker-dealer. Please confirm your understanding that the retention by
a selling shareholder of an underwriter would constitute a material change to your plan of distribution requiring a post-effective amendment.
Please also revise to provide all required undertakings specified in Item 512 of Regulation S-K, including, but not limited to, Item 512(a)(1)(iii)
of Regulation S-K.

Response: We respectfully
advise the Staff that we have revised the disclosure on page Alt -23 to address the above. The Company confirms its understanding that
the retention by a selling shareholder of an underwriter would constitute material change to the plan of distribution requiring a post-effective
amendment.

* * *

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

October 22, 2024
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Registration Statement on Form F-1
Filed October 4, 2024
File No. 333-282499
Dear Suqin Li:
            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.
Registration Statement on Form F-1 filed October 4, 2024
Certain Relationships and Related Party Transactions, page 98
1.Please update your disclosure so that it reflects the related party transactions as of the
date of the prospectus. Refer to Item 7.B of Form 20-F. Currently, your disclosure is
as of March 31, 2024.
General
We note your disclosure in the Resale Prospectus Shareholders Plan of Distribution
section that your selling shareholders may sell their securities through use of a broker-
dealer. Please confirm your understanding that the retention by a selling shareholder
of an underwriter would constitute a material change to your plan of distribution
requiring a post-effective amendment. Please also revise to provide all required
undertakings specified in Item 512 of Regulation S-K, including, but not limited to, 2.

October 22, 2024
Page 2
Item 512(a)(1)(iii) of Regulation S-K.
            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 Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related
matters. Please contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Lawrence S. Venick, Esq.

CORRESP
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June 28, 2024

Via Edgar Transmission

Mr. Thomas Jones

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

 Re: Majestic Ideal Holdings Ltd

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

Filed June 18, 2024

File No. 333-271502

Dear Mr. Jones:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the verbal comments on June 28, 2024 from the Securities and Exchange
Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented on the
above-referenced Draft Registration Statement on Form F-1 (the “Form F-1”).

The Company respectfully advises
the Staff that with regards to the Selling Shareholders Plan of Distribution on page Alt-23 of the Form F-1, the Company understands and
confirms that should there be purchases by a broker-dealer as principal and resales by the broker-dealer for its account, that would constitute a material
change and a post-effective amendment would be required.

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

CORRESP
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June 26, 2024

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Majestic Ideal Holdings Ltd

Registration Statement on Form F-1

File No. 333-271502

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 Intelligent that
the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 5:00 p.m.
Washington D.C. time on June 28, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations
under the Act, the undersigned advises that it intends to distribute approximately 350 copies of the Preliminary Prospectus dated January
10, 2024 to prospective underwriters and dealers, institutional investors, retail investors and others.

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

    Very truly yours,

    WESTPARK CAPITAL, INC.

    By:
    /s/ Jason Stern

    Name:
     Jason Stern

    Title:
     Chief Operating Officer

CORRESP
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Majestic Ideal
Holdings Ltd

VIA EDGAR

June 26, 2024

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Finance

Washington, D.C. 20549

Attn: Thomas Jones and Jay Ingram

    Re:
    Majestic Ideal Holdings Ltd

    Registration Statement on Form F-1

    Filed April 28, 2023, as amended

    File No. 333-271502

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Majestic Ideal Holdings Ltd hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 5:00 pm ET on June 28, 2024, or as soon as thereafter practicable.

    Very truly yours,

    /s/ Yuk Yin Judy Li

    Yuk Yin Judy Li

    Chairperson of the Board of Directors

    cc:
    Loeb & Loeb LLP

    Haneberg Hurlbert PLC

CORRESP
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November 16, 2023

Via Edgar Transmission

Mr. Thomas Jones/ Mr. Jay Ingram

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Majestic Ideal Holdings Ltd

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

    Filed October 31, 2023

    File No. 333-271502

Dear Mr. Jones/ Mr. Ingram:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated November 9, 2023 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. 4 to Registration Statement on
Form F-1 filed October 31, 2023

General

 1. We note the disclosure on page 5 and elsewhere in your amendment that “On May 11, 2023, the Company
submitted the filing materials to the CSRC, and the Company subsequently obtained approval from the CSRC on July 24, 2023. However, the
Company may need to update the filing materials if any of the aforementioned material matters occurs.” Please confirm in writing
that you will notify us promptly of any changes to your disclosure regarding or requested by the CSRC.

Response:

We respectfully advise the Staff that we have further updated filing materials to CSRC on November 15, 2023, as disclosed on pages 5,
17 and Alt-9. The Company confirms that it will notify the Staff promptly of any further changes that are made to our disclosure regarding
or requested by the CSRC.

* * *

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
November 9, 2023
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 4 to Registration Statement on Form F-1
Filed October 31, 2023
File No. 333-271502
Dear Suqin Li:
            We have reviewed your amended registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our October 26, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1 filed October 31, 2023
General
1.We note the disclosure on page 5 and elsewhere in your amendment that "On May 11,
2023, the Company submitted the filing materials to the CSRC, and the Company
subsequently obtained approval from the CSRC on July 24, 2023. However, the Company
may need to update the filing materials if any of the aforementioned material matters
occurs." Please confirm in writing that you will notify us promptly of any changes to your
disclosure regarding or requested by the CSRC.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 November 9, 2023 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
November 9, 2023
Page 2
            Please contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

CORRESP
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October 31, 2023

Via Edgar Transmission

Mr. Thomas Jones

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Majestic Ideal Holdings Ltd

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

    Filed October 20, 2023

    File No. 333-271502

Dear Mr. Jones:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated October 26, 2023 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. 3 to Registration Statement on
Form F-1 filed October 20, 2023

General

 1. We note your response to prior comment 1 and we reissue the comment. Please amend to provide the information summarized
and requested in the prior comment.

Response: We respectfully
advise the Staff that we have updated the disclosure appearing on the cover page, Summary and Risk Factor sections to restore relevant
risk disclosures in relation to legal and operational risks associated with operating in China and PRC regulations.

Dilution, page 44

 2. Your revised disclosures in response to prior comment 2 indicate that your intangible assets include
deferred IPO costs, right-of-use assets and deferred tax assets and are therefore excluded from net tangible book value. It appears as
though your net tangible book value as currently presented does not exclude your right-of-use assets of RMB712,011. Please revise.

Response: We respectfully
advise the Staff that we have revised the disclosures on page 44

 3. In a related matter, your current presentation lists your net tangible book value in USD with the $,
however, your calculated value is actually from your March 31, 2023 balance sheet in RMB. In addition, your net tangible book value per
share is presented according to the USD figures. Please revise to present your net tangible book value in U.S. Dollars to align with your
net tangible book value per share.

Response: We respectfully
advise the Staff that we have revised the disclosures on page 44

Compensation of Directors and Executive Officers,
page 93

 4. Please update the disclosure in this section to include compensation information for the most recently
completed fiscal year.

Response: We
respectfully advise the Staff that we have updated the compensation disclosure on page 93 for the fiscal year ended September 30,
2023.

Financial Statements, page F-1

 5. We note this registration statement is your initial public offering. In this regard, your audited financial
statements must be no more than 12 months old at the time of filing and upon the effectiveness of the registration statement unless you
are able to represent the you are not required to comply with the 12 month requirement in any other jurisdiction outside the United States
and that complying with the 12 month requirement is impracticable or involves undue hardship in which case the last year of audited financial
statements may not be older than 15 months at the time of offering. If applicable, your representation should be filed as an exhibit to
the registration statements. Refer to the Instructions to Item 8.A.4 of Form 20-F.

Response: We respectfully advise
the Staff that we have included with the registration statement a request for waiver filed as exhibit 99.6.

* * *

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
October 26, 2023
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 3 to Registration Statement on Form F-1
Filed October 20, 2023
File No. 333-271502
Dear Suqin Li:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our October 13, 2023 letter.
Amendment No. 3 to Registration Statement on Form F-1 filed October 20, 2023
General
1.We note your response to prior comment 1 and we reissue the comment.   Please amend to
provide the information summarized and requested in the prior comment.

Dilution, page 44
2.Your revised disclosures in response to prior comment 2 indicate that your intangible
assets include deferred IPO costs, right-of-use assets and deferred tax assets and are
therefore excluded from net tangible book value.  It appears as though your net tangible
book value as currently presented does not exclude your right-of-use assets of RMB
712,011.  Please revise.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 26, 2023 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 26, 2023
Page 2
3.In a related matter, your current presentation lists your net tangible book value in USD
with the $, however, your calculated value is actually from your March 31, 2023 balance
sheet in RMB.  In addition, your net tangible book value per share is presented according
to the USD figures.  Please revise to present your net tangible book value in U.S. Dollars
to align with your net tangible book value per share.
Compensation of Directors and Executive Officers, page 93
4.Please update the disclosure in this section to include compensation information for the
most recently completed fiscal year.
Financial Statements, page F-1
5.We note this registration statement is your initial public offering.  In this regard, your
audited financial statements must be no more than 12 months old at the time of filing and
upon the effectiveness of the registration statement unless you are able to represent the
you are not required to comply with the 12 month requirement in any other jurisdiction
outside the United States and that complying with the 12 month requirement is
impracticable or involves undue hardship in which case the last year of audited financial
statements may not be older than 15 months at the time of offering.  If applicable, your
representation should be filed as an exhibit to the registration statements.  Refer to the
Instructions to Item 8.A.4 of Form 20-F.
            Please contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

CORRESP
1
filename1.htm

October
20, 2023

Via
Edgar Transmission

Mr.
Thomas Jones

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

Washington,
D.C. 20549

    Re:
    Majestic
                                            Ideal Holdings Ltd

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

    Filed
    September 18, 2023

    File
    No. 333-271502

Dear
Mr. Jones:

As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated October 13, 2023 from the Securities
and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”) commented
on the above-referenced Draft 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. 2 to Registration Statement on Form F-1 filed September 18, 2023

General

 1. We
                                            note the changes you made to your disclosure appearing on the cover page, Summary and Risk
                                            Factor 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 16, 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 referencing the PRC government’s intent to strengthen its regulatory oversight
                                            conveys the same risk. Please restore your disclosures in these areas to the disclosures
                                            as they existed in the amendment that was filed on May 16, 2023.

Response: We respectfully
advise the Staff that on May 11, 2023, the Company’s PRC Counsel, Commerce
& Finance Law Offices, submitted a draft of the filing materials including a draft Form F-1 to the CSRC,
and the Company subsequently updated the disclosures appearing on the cover page, Summary and Risk Factor sections relating to the legal
and operational risks associated with operating in China and PRC regulations in reference to the Trial Administrative Measures of Overseas
Securities Offering and Listing by Domestic Companies and the CSRC’s comments regarding such disclosures. The Company was advised
by Commerce & Finance Law Offices, that based on discussions with the CSRC, it is a compliance obligation and requirement of the Company
to amend the relevant descriptions of the Prospectus to conform to the actual legal policies, business environment and judicial situation
in the PRC.

Dilution,
page 44

 2. Please
                                            tell us how your $(10,719,688) and $(0.09) net tangible book value and net tangible book
                                            value per share were calculated.

Response: We
respectfully advise the Staff that we have revised the disclosures on page 44.

September
30, 2022 Annual Financial Statements

Consolidated
Statements of Income and Comprehensive Income, page F-4

 3. Your
                                            note at the bottom of page F-4 indicates that your basic and diluted earnings per share were
                                            retroactively adjusted for the July 2023 stock split, however, we note no change to the earnings
                                            per share amount for each period presented. Please revise to include the correct amounts
                                            for earnings per share using the weighted average number of ordinary shares after the stock
                                            split of 18 million.

Response: We
respectfully advise the Staff that we have revised the disclosures on page F-4.

Consolidated
Statements of Changes of Shareholders’ (Deficit) Equity, page F-5

 4. It
                                            appears as the No. of Shares column has not been retroactively adjusted for the July 2023
                                            stock split. Please revise. Your March 31, 2023 interim shareholders’ equity statement should
                                            be similarly revised.

Response: We
respectfully advise the Staff that we have revised the disclosures on page F-5 and F-29.

March
31, 2023 Interim Financial Statements

Unaudited
Condensed Statements of Income and Comprehensive Income, page F-28

 5. Your
                                            calculation of earnings (loss) per share appears to be calculated using comprehensive income
                                            rather than net income. Please revise both your interim and annual statements of income to
                                            calculate earnings per share using net income.

Response: We
respectfully advise the Staff that we have revised the disclosures on page F-28.

Notes
to the Consolidated Financial Statements

10.
Leases, page F-44

 6. Please
                                            clarify your statement that the outstanding operating leases are below your threshold for
                                            capitalization and therefore, “no right of use assets and liabilities were recognized
                                            under ASU 842” given that in the table above, you have right of use assets and liabilities
                                            recorded on the balance sheet.

Response: We
respectfully advise the Staff that we have revised the disclosures on page F-44 and F-21.

12.
Taxes

China,
page F-46

    2

 7. Please
                                            clarify why you have a provision for income taxes in your income statement of RMB 677,656
                                            with a net loss and negative tax rate of (105.9)%. Your response should address the nature
                                            of the large adjustments to your effective tax rates including the tax loss not recognized
                                            of (30.6)% and tax concession of (97.6)%.

Response: We
respectfully advise the Staff that New Brand was not subject to PRC income tax in view of its tax loss for the six months period ended
March 31, 2023. However, dividend distribution out of the retained profits of foreign-invested enterprises in the PRC (i.e. New Brand)
earned after January 1, 2008 is subject to withholding income tax at a tax rate of 10% unless reduced by treaty. Multi Ridge accounted
for the 10% withholding tax arising from dividend it received from New Brand’s retained profit during the six months period ended
June 30, 2023 as PRC income tax. We respectfully advise the Staff that we have revised the tax policies and the disclosure on page F-46.

Our
negative tax rate (105.9%) was simply derived from dividing our Loss before Income Tax of RMB639,852 by our Provision for Income Taxes
of RMB677,656. As the denominator was negative, the rate derived was negative by presentation. We respectfully advise the Staff that
the terminology of Tax Concession was not perfectly depicting that nature of our withholding tax in the tax reconciliation, we have therefore
revised the disclosure on F-46.

Our
tax loss not recognized (30.6%) was simply derived from dividing our Loss before Income Tax of RMB639,852 (as adjusted by income not
taxable and expense not deductible) by our Loss before Income Tax of RMB639,852. As the denominator was negative, the rate derived was
negative by presentation.

*
* *

    3

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

4

United States securities and exchange commission logo
October 13, 2023
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed September 18, 2023
File No. 333-271502
Dear Suqin Li:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 2 to Registration Statement on Form F-1 filed September 18, 2023
General
1.We note the changes you made to your disclosure appearing on the cover page, Summary
and Risk Factor 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 16, 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

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 13, 2023 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 13, 2023
Page 2
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 referencing the PRC government’s intent to
strengthen its regulatory oversight conveys the same risk. Please restore your disclosures
in these areas to the disclosures as they existed in the amendment that was filed on May
16, 2023.
Dilution, page 44
2.Please tell us how your $(10,719,688) and $(0.09) net tangible book value and net tangible
book value per share were calculated.
September 30, 2022 Annual Financial Statements
Consolidated Statements of Income and Comprehensive Income, page F-4
3.Your note at the bottom of page F-4 indicates that your basic and diluted earnings per
share were retroactively adjusted for the July 2023 stock split, however, we note no
change to the earnings per share amount for each period presented.  Please revise to
include the correct amounts for earnings per share using the weighted average number of
ordinary shares after the stock split of 18 million.
Consolidated Statements of Changes of Shareholders' (Deficit) Equity, page F-5
4.It appears as the No. of Shares column has not been retroactively adjusted for the July
2023 stock split.  Please revise.  Your March 31, 2023 interim shareholders' equity
statement should be similarly revised.
March 31, 2023 Interim Financial Statements
Unaudited Condensed Statements of Income and Comprehensive Income, page F-28
5.Your calculation of earnings (loss) per share appears to be calculated using
comprehensive income rather than net income.  Please revise both your interim and annual
statements of income to calculate earnings per share using net income.
Notes to the Consolidated Financial Statements
10. Leases, page F-44
6.Please clarify your statement that the outstanding operating leases are below your
threshold for capitalization and therefore, "no right of use assets and liabilities were
recognized under ASU 842" given that in the table above, you have right of use assets and
liabilities recorded on the balance sheet.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 13, 2023 Page 3
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 13, 2023
Page 3
12. Taxes
China, page F-46
7.Please clarify why you have a provision for income taxes in your income statement
of RMB 677,656 with a net loss and negative tax rate of (105.9)%.  Your response should
address the nature of the large adjustments to your effective tax rates including the tax loss
not recognized of (30.6)% and tax concession of (97.6)%.
            Please contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

CORRESP
1
filename1.htm

May 16, 2023

Via Edgar Transmission

Mr. Thomas Jones

Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

Washington, D.C. 20549

    Re:

    Majestic Ideal Holdings Ltd. (The “Company”)

    Registration Statement on Form F-1

    Submitted April 28, 2023

    File No. 333-271502

Dear Mr. Jones:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated May 9, 2023 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.

Registration Statement on Form F-1 filed April 28, 2023

Exhibits

    1.

    Please have counsel clarify the reference to
    “all parties” in items (6) and (7) on page 3 of the opinion filed as exhibit 99.5 to instead refer to all parties other than
    the PRC Subsidiary.

    Response: We respectfully advise the Staff that
    we have revised the exhibit 99.5.

    2.

    We note the language in the second to the last
    paragraph of the opinion filed as exhibit 99.5, which states that the opinion “is given for the benefit of the addressee hereof”
    and the reference to “apart from SEC.” Disclaimers of responsibility that in any way state or imply that investors are not entitled
    to rely on the opinion, or other limitations on whom may rely on the opinion, are unacceptable. Delete this disclaimer from the opinion.

    Response: We respectfully advise the Staff that
    we have revised the exhibit 99.5.

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
May 9, 2023
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Registration Statement on Form F-1
Filed April 28, 2023
File No. 333-271502
Dear Suqin Li:
            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.
Registration Statement on Form F-1 filed April 28, 2023
Exhibits
1.Please have counsel clarify the reference to "all parties" in items (6) and (7) on page 3 of
the opinion filed as exhibit 99.5 to instead refer to all parties other than the PRC
Subsidiary.
2.We note the language in the second to the last paragraph of the opinion filed as exhibit
99.5, which states that the opinion "is given for the benefit of the addressee hereof" and
the reference to "apart from SEC."  Disclaimers of responsibility that in any way state or
imply that investors are not entitled to rely on the opinion, or other limitations on whom
may rely on the opinion, are unacceptable. Delete this disclaimer from the opinion.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 May 9, 2023 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
May 9, 2023
Page 2
            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.
            You may contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

United States securities and exchange commission logo
March 14, 2023
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 9 to Draft Registration Statement on Form F-1
Submitted March 2, 2023
CIK No. 0001897532
Dear Suqin Li:
            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. 9 to Draft Registration Statement on Form F-1
Capitalization, page 47
1.Please revise the table to include your indebtedness in accordance with Item 4(a) of Form
F-1 and Item 3.B of Form 20-F.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 March 14, 2023 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
March 14, 2023
Page 2
            You may contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

United States securities and exchange commission logo
December 5, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 7 to Draft Registration Statement on Form F-1
Submitted November 23, 2022
CIK No. 0001897532
Dear Suqin Li:
            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. 7 to Draft Registration Statement on Form F-1 submitted November 23, 2022
Compensation of Directors and Executive Officers, page 94
1.Please update your compensation disclosure for your recently completed fiscal year ended
September 30, 2022.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 December 5, 2022 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
December 5, 2022
Page 2
            You may contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

United States securities and exchange commission logo
November 21, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 6 to Draft Registration Statement on Form F-1
Submitted November 7, 2022
CIK No. 0001897532
Dear Suqin Li:
            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. 6 to Draft Registration Statement on Form F-1 submitted November 7, 2022
Enforceability of Civil Liabilities, page 5
1.We note your response to prior comment 5.  If you did not consult counsel regarding the
disclosure on pages 6 and 7 and the disclosure on page 125 about Hong Kong, then
discuss why you did not consult counsel.
Exhibits
2.We note your response to prior comment 4.  Please file as an exhibit the consent of Loeb
& Loeb LLP.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 November 21, 2022 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
November 21, 2022
Page 2
            You may contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Tom Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.

United States securities and exchange commission logo
October 17, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 5 to Draft Registration Statement on Form F-1
Submitted September 22, 2022
CIK No. 0001897532
Dear Suqin Li:
            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. 5 to Draft Registration Statement on Form F-1 submitted September 22, 2022
Other Pertinent Information, page iii
1.We note your response to prior comment 1 and the revised definitions on page iii.  To the
extent that you exclude Hong Kong from definitions related to China, the PRC and
mainland China, please revise the disclosure on the cover page and on page iii to clarify
that the legal and operational risks associated with operating in China also apply to Hong
Kong. In addition, disclose on the cover page and in the prospectus summary how any
regulatory actions related to data security or anti-monopoly concerns in Hong Kong have
or may impact the company’s ability to conduct its business, accept foreign investments,
or list on a U.S. exchange.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 17, 2022 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 17, 2022
Page 2
Permission Required from Hong Kong Authorities, page 4
2.We note your response to prior comment 1 and the disclosure on page 4 of your prior
amendment that "we and our Hong Kong subsidiary are not required to
obtain any permission or approval from Hong Kong authorities to operate our business or
issue our Shares to foreign investors." However, it appears that in response to prior
comment 1 that you revised the disclosure in this section to instead state that "we are
not currently required to obtain permission from any Hong Kong authorities in connection
with this offering."  Please revise the disclosure to state whether you and your Hong Kong
subsidiary are required to obtain permission or approval from Hong Kong authorities to
operate your business or issue your shares to foreign investors.
3.We note your revised disclosure in this section about change in applicable, laws,
regulations or interpretations and that you will "strive to comply with the then applicable
laws, regulations, or interpretations."  Please expand the disclosure to describe the
consequences to you and your investors if you or your subsidiaries: (i) do not receive or
maintain such permissions or approvals, (ii) inadvertently conclude that such permissions
or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and you are required to obtain such permissions or approvals in the future.
4.We note the disclosure in this section that you have not obtained an opinion of Hong
Kong counsel.  If you did not consult counsel, discuss why you did not consult counsel as
previously requested in the penultimate sentence of prior comment 1.
Enforceability of Civil Liabilities, page 5
5.We note your response to prior comment 1.  To the extent that you exclude Hong Kong
from definitions related to China, the PRC and mainland China, please expand this section
to provide additional disclosure related to the enforceability of civil liabilities in Hong
Kong.
Summary of Risk Factors, page 6
6.We note your disclosure in the table on page 6 that several of your directors and officers
are currently located in Hong Kong.  Please disclose that it is uncertain whether in the
future the Hong Kong government will implement regulations and policies of the Chinese
government or adopt regulations and policies of its own that are substantially similar to
those of the Chinese government. Also, given your disclosure on page 6 about sudden or
unexpected changes in laws and regulations in the PRC with little advance notice,
disclose, if applicable, that it is also uncertain whether having several of your directors
and officers located in Hong Kong will subject you to the oversight of the Chinese
authorities in the future.  Also, please revise your disclosure to directly state that the legal
and operational risks associated with operating in the PRC also apply to Hong Kong.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 17, 2022 Page 3
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 17, 2022
Page 3
General
7.To the extent that you are impacted by the conflict in the Ukraine, please revise to provide
more specific disclosures about the legal and operational risks, as well as the impact on
your results of operations, as a result of such invasion. For additional guidance, please see
the Division of Corporation Finance’s Sample Letter to Companies Regarding Disclosures
Pertaining to Russia’s Invasion of Ukraine and Related Supply Chain Issues issued by the
Staff in May 2022.
8.Please disclose whether and how your business segments, products, lines of service,
projects, or operations are materially impacted by supply chain disruptions, especially in
light of the conflict between Russia and Ukraine. For example, discuss whether you have
or expect to:
• suspend the production, purchase, sale or maintenance of certain items;
• experience higher costs due to constrained capacity or increased commodity prices or
challenges of sourcing materials;
• experience surges or declines in demand for which you are unable to adequately adjust
your supply;
• be exposed to supply chain risk in light of Russia’s invasion of Ukraine and/or related
geopolitical tension; or
• be unable to supply products at competitive prices or at all due to export restrictions,
sanctions, or the ongoing conflict.

Explain whether and how you have undertaken efforts to mitigate the impact and where
possible quantify the impact to your business.
9.Please describe the extent and nature of the role of the board of directors in overseeing
risks related to Russia’s invasion of Ukraine. This could include, but is not limited to,
risks related to cybersecurity, sanctions, employees based in affected regions, and supply
chain/suppliers/service providers in affected regions as well as risks connected with
ongoing or halted operations or investments in affected regions.
10.To the extent material, disclose any new or heightened risk of potential cyberattacks by
state actors or others since Russia's invasion of Ukraine and whether you have taken
actions to mitigate such potential risks.
11.If your operations have experienced or are experiencing inflationary pressures or rising
costs, please expand to identify the principal factors contributing to the inflationary
pressures the company has experienced and clarify the resulting impact to the company.
Please also revise to identify actions planned or taken, if any, to mitigate inflationary
pressures.
12.Please discuss whether recent increased cases of COVID-19 and/or shutdowns related to
additional or increased outbreaks have had a material impact on your operations, supply
chain liquidity or capital resources.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 17, 2022 Page 4
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 17, 2022
Page 4
            You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Jay Ingram, Legal Branch Chief, at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Virginia Tam

United States securities and exchange commission logo
May 16, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted April 28, 2022
CIK No. 0001897532
Dear Ms. Li:
            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. 4 to Draft Registration Statement on Form F-1 submitted April 28, 2022
Other Pertinent Information, page iii
1.You state that references to "China" or "PRC" refer to the People’s Republic of China,
excluding the Taiwan region, Hong Kong, and Macau. Revise the definition of "China" or
the "PRC" to include Hong Kong and Macau and revise the disclosure throughout your
amendment accordingly.  If you do not revise the definition of "China" or the "PRC,"
ensure that disclosure regarding Hong Kong throughout the amendment addresses the
sample letter to China-based companies available on our website.  Also, revise page 4 to
explain how you determined that you and your Hong Kong subsidiary are not required to
obtain any permission or approval from Hong Kong authorities to operate your business or

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 Comapany NameMajestic Ideal Holdings Ltd
 May 16, 2022 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
May 16, 2022
Page 2
issue your shares to foreign investors.   If you relied on the advice of counsel, name
counsel and include a consent from counsel as an exhibit. If you did not consult counsel,
revise page 4 to discuss why you did not consult counsel.  In this regard, we note the
statement  that the "the PRC does not include the Hong Kong Special Administrative
Region, the Macau Special Administrative Region and Taiwan" on page 1 of the opinion
filed as exhibit 99.5.
Permission Required from PRC Authorities, page 4
2.We note that you do not appear to have relied upon an opinion of counsel with respect to
your conclusion you are not subject to cybersecurity review with the CAC to conduct
business operations in China.  If true, state as much and explain why such an opinion was
not obtained. In this regard, we note your disclosure on page 4 that you "confirmed" with
your PRC counsel that you are not subject to cybersecurity review with the CAC to
conduct business operations in China.  However, it is not clear if this constitutes counsel's
opinion and it does not appear that the confirmation or opinion extends to other
permissions and approvals.
3.We note your response to prior comment 7.  The disclosure on page 4 about operations
and the issuance of shares should not be qualified by by the references to permissions
"that will not have material adverse effects" and to "essential" provisions.  Please make
appropriate revisions to your disclosure on page 4 and such references on pages 9 and 20
as well as exhibit 99.5.
Enforceability of Civil Liabilities, page 115
4.We note your response to prior comment 8.  Please relocate the Enforceability of Civil
Liabilities section to an earlier location in the prospectus.
            You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Jay Ingram, Legal Branch Chief, at 202-551-3602 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Virginia Tam

United States securities and exchange commission logo
April 7, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted March 17, 2022
CIK No. 0001897532
Dear Ms. Li:
            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. 3 to Draft Registration Statement on Form F-1 submitted March 17, 2022
Cover Page
1.Please clarify the amount of your cash that is in RMB and Hong Kong dollars. Please
disclose whether cash generated from one subsidiary is used to fund another subsidiary's
operations, whether your subsidiaries have ever faced difficulties or limitations on their
ability to transfer cash between subsidiaries, and whether your subsidiaries have cash
management policies that dictate the amount of such funding. Also, disclose whether your
subsidiaries have cash management policies/procedures that dictate how funds are
transferred. Your disclosure should address the possibility that the PRC could prevent the
cash maintained in the PRC or Hong Kong from leaving, or that the PRC could restrict

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 Comapany NameMajestic Ideal Holdings Ltd
 April 7, 2022 Page 2
 FirstName LastNameSuqin Li
Majestic Ideal Holdings Ltd
April 7, 2022
Page 2
deployment of the cash into the business or for the payment of dividends. Add similar
disclosure to risk factors and to the summary of risk factors.
Risks Relating to Doing Business in China, page 5
2.Please revise the disclosure in the first bullet point to specifically discuss risks arising
from the legal system in China, including risks and uncertainties regarding the
enforcement of laws and that rules and regulations in China can change quickly with little
advance notice, which could result in a material change in your operations and/or the
value of the securities you are registering for sale.
3.Please revise the disclosure in the second bullet point in this section to clarify that
the PRC government may intervene or influence your operations at any time, or may exert
more control over offerings conducted overseas and/or foreign investment in China-
based issuers, which could result in a material change in your operations and/or the value
of the securities you are registering for sale.
4.Please revise the disclosure in the first sentence of the last bullet point on page 5 to
acknowledge any risks that any actions by the Chinese government to exert more
oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers could significantly limit or completely hinder your ability to offer
or continue to offer securities to investors and cause the value of such securities to
significantly decline or be worthless.
Recent Regulatory Developments in China, page 9
5.We note your disclosure about the revised draft released on July 10, 2021.  Please update
your disclosures in this section and elsewhere in your filing to reflect that: (1) the
Cyberspace Administration of China issued the New Measures for Cybersecurity Review
on January 4, 2022; (2) that the New Measures amended the Measures for Cybersecurity
Review released on July 10, 2021; and (3) the New Measures came into effect on
February 15, 2022.  Generally, please ensure that your discussion of PRC laws, rules and
regulations is current.
Recent joint statement by the SEC and the PCAOB, page 17
6.We note your disclosure about the Holding Foreign Companies Accountable Act. Please
revise the disclosure to clarify that the United States Senate has passed the Accelerating
Holding Foreign Companies Accountable Act, which, if enacted, would decrease the
number of  non-inspection years” from three years to two years, and thus, would reduce
the time before your securities may be prohibited from trading or delisted. Update your
disclosure to reflect that the Commission adopted rules to implement the HFCAA and that,
pursuant to the HFCAA, the PCAOB has issued its report notifying the Commission of its
determination that it is unable to inspect or investigate completely accounting firms
headquartered in mainland China or Hong Kong.

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 Comapany NameMajestic Ideal Holdings Ltd
 April 7, 2022 Page 3
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
April 7, 2022
Page 3
In light of recent events indicating greater oversight, page 19
7.Please revise the disclosure in this risk factor to explain how this oversight impacts your
business and your offering.  Regarding the disclosure on page 19 about your belief that
you "are neither currently impacted nor covered by the permission and requirements from
the CSRC or CAC," please revise to clarify whether you obtained an opinion of counsel
regarding required approvals from the CSRC or CAC. If you did obtain an opinion of
counsel, please file the consents as exhibits.
Enforceability of Civil Liabilities, page 114
8.We note the disclosure on pages 83-84 about your officers and directors. Please revise the
disclosure on page 114 to discuss, if applicable, the extent to which your directors and
officers are nationals or residents of the PRC and revise the Risk Factors section to
include a separate risk factor to highlight the risk discussed on page 114.
General
9.Please remove the Filing Fee Table from the cover page and file it as an exhibit to this
registration statement. Refer to Item 601(b)(107) of Regulation S-K.
            You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Jay Ingram. Legal Branch Chief, at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Virginia Tam

United States securities and exchange commission logo
March 14, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted February 18, 2022
CIK No. 0001897532
Dear Ms. Li:
            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 18, 2022
Cover Page
1.Please disclose prominently on the cover page that you are not a Chinese operating
company.  Also, disclose that investors may never hold equity interests in the Chinese
operating company.  In addition, disclose that Chinese regulatory authorities could
disallow this structure, which would likely result in a material change in your operations
and/or value of your ordinary shares, including that it could cause the value of such
securities to significantly decline or become worthless.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 March 14, 2022 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
March 14, 2022
Page 2
2.We note the risks highlighted on the prospectus cover page and the risks mentioned in the
six bullet points in the Risks Related to Doing Business in China section on pages 4-5 of
this amendment.  Please note that your prospectus summary should address, but not
necessarily be limited to, the risks highlighted on the prospectus cover page.  In this
regard, we note that prior amendment included thirteen bullet points in the Risks Related
to Doing Business in China section.
Summary of Risk Factors, page 5
3.We note your response to prior comment 4.  Please expand this section to highlight, if
applicable, that the Hong Kong legal system embodies uncertainties which could limit the
legal protections available to you.
            You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Jay Ingram, Legal Branch Chief, at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Virginia Tam

United States securities and exchange commission logo
February 9, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted January 26, 2022
CIK No. 0001897532
Dear Ms. Li:
            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. 1 to Draft Registration Statement on Form F-1 submitted January 26, 2022
Cover Page
1.In comment 1 of our letter dated January 14, 2022, we made a specific request that would
assist the staff in its analysis of your disclosure and we are reissuing that comment in full.
Several comments contained in this letter have numerous components and the comments
contained in our January 14, 2022 letter had many subcomponents.  As we previously
requested, with the next amendment, please be sure that you file a letter of correspondence
on EDGAR that separates each comment and component, including the comments
contained in our prior letter, and reproduces the disclosure and the specific location in
your prospectus where you believe the comment is addressed.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 February 9, 2022 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
February 9, 2022
Page 2
2.We note your response to comment 3. Please revise to address the following:

• the disclosure in the first bullet point on the cover page should make clear that the
actions could result in a material change in your operations and/or the value of the
securities you are registering for sale;

• the disclosure in the third bullet point on the cover page should make clear that the
actions could significantly limit or completely hinder your ability to offer or continue to
offer securities to investors; and

• in the second paragraph following the bulleted list, make clear that the actions also: (1)
could result in a material change in your operations and/or the value of the securities you
are registering for sale; and (2) could significantly limit or completely hinder your ability
to offer or continue to offer your securities to investors.
3.We note your responses to prior comments 5 and 7.  Please update the disclosure on the
cover page and the disclosure at the bottom of page 2 to state whether the dividend
declared by Multi Ridge which remained unpaid as of September 30, 2021 has since been
paid.
Prospectus Summary, page 1
4.We note your response to prior comment 6. Please disclose each permission or approval
that you or your subsidiaries are required to obtain from Hong Kong authorities to operate
your business and to offer the securities being registered to foreign investors. State
whether you or your subsidiaries are covered by permissions requirements from the China
Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC)
or any other governmental agency that is required to approve the operations of your
subsidiaries, and state affirmatively whether you have received all requisite permissions or
approvals and whether any permissions or approvals have been denied. Please also
describe the consequences to you and your investors if you or your subsidiaries: (i) do not
receive or maintain such permissions or approvals, (ii) inadvertently conclude that such
permissions or approvals are not required, or (iii) applicable laws, regulations, or
interpretations change and you are required to obtain such permissions or approvals in the
future.
Risks Associated with our Business, page 5
5.Please revise this section and the Risk Factors section to move forward the risks related to
doing business in China so that such risks are prominently disclosed within each section in
relation to other identified material risks.

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 Comapany NameMajestic Ideal Holdings Ltd
 February 9, 2022 Page 3
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
February 9, 2022
Page 3
Risks Related to Doing Business in China, page 6
6.We note your response to prior comment 8 and the cross-reference on page 6.  In your
summary of risk factors, disclose the risks that your corporate structure and being based in
or having the majority of the company’s operations in China poses to investors. In
particular, describe the significant regulatory, liquidity, and enforcement risks and provide
cross-references to the more detailed discussion of each risk in the prospectus as opposed
to a cross-reference to the section beginning on page 18.
7.We note your response to comment 8 and your disclosure in the bullet points in this
section. Please specifically discuss risks arising from the legal system in China, including
risks and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of the
securities you are registering for sale.  Also, please ensure that you acknowledge any
risks that any actions by the Chinese government to exert more oversight and control over
offerings that are conducted overseas and/or foreign investment in China-based issuers
could significantly limit or completely hinder your ability to offer or continue to
offer securities to investors and cause the value of such securities to significantly decline
or be worthless.
8.Please include a bullet point to highlight the recent joint statement by the SEC and
PCAOB, proposed rule changes submitted by Nasdaq, and the Holding Foreign
Companies Accountable Act all call for additional and more stringent criteria to be
applied to emerging market companies upon assessing the qualification of their auditors,
especially the non-U.S. auditors who are not inspected by the PCAOB.
Undertakings, page II-1
9.Please revise to include the undertaking of Item 512 of Regulation S-K, such as Item
512(a)(4) of Regulation S-K.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 February 9, 2022 Page 4
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
February 9, 2022
Page 4
            You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Kevin Woody,
Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Jay Ingram, Legal Branch Chief, at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Virginia Tam

United States securities and exchange commission logo
January 14, 2022
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd.
22/F, China United Plaza
1002-1008, Tai Nan West Street
Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd.
Draft Registration Statement on Form F-1
Submitted December 21, 2021
CIK No. 0001897532
Dear Ms. Li:
            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.
Draft Registration Statement on Form F-1 submitted December 21, 2021
General
1.Many of the comments contained in this letter have numerous components.  To facilitate
the staff's analysis of your disclosure, your response letter should separate each comment
and component and reproduce the disclosure and the specific location in your prospectus
where you believe the SEC's concern is addressed.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd.
 January 14, 2022 Page 2
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Suqin Li
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January 14, 2022
Page 2
Cover Page
2.Please disclose prominently on the prospectus cover page that you are not a Chinese
operating company but a Cayman Islands holding company with operations conducted by
your subsidiaries based in China and that this structure involves unique risks to investors.
Provide a cross-reference to your detailed discussion of risks facing the company and the
offering as a result of this structure.
3.Provide prominent disclosure about the legal and operational risks associated with being
based in or having the majority of the company’s operations in China. Your disclosure
should make clear whether these risks could result in a material change in your operations
and/or the value of the securities you are registering for sale or could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless. Your disclosure
should address how recent statements and regulatory actions by China’s government, such
as those related to the use of variable interest entities and data security or anti-monopoly
concerns, have or may impact the company’s ability to conduct its business, accept
foreign investments, or list on a U.S. or other foreign exchange. Please disclose whether
your auditor is subject to the determinations announced by the PCAOB on December 16,
2021 and whether and how the Holding Foreign Companies Accountable Act and related
regulations will affect your company. Your prospectus summary should address, but not
necessarily be limited to, the risks highlighted on the prospectus cover page.
4.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 entities. Disclose clearly the
entity (including the domicile) in which investors are purchasing an interest.
5.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings or settle amounts owed under your agreements. State
whether any transfers, dividends, or distributions have been made to date.
Prospectus Summary, page 1
6.Disclose each permission or approval that you, or your subsidiaries are required to obtain
from Chinese authorities to operate your business and to offer the securities being
registered to foreign investors. State whether you or your subsidiaries are covered by
permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve your or your subsidiaries’ operations, and state affirmatively whether
you have received all requisite permissions or approvals and whether any permissions or
approvals have been denied. Please also describe the consequences to you and your
investors if you or your subsidiaries: (i) do not receive or maintain such permissions or

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 Comapany NameMajestic Ideal Holdings Ltd.
 January 14, 2022 Page 3
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Majestic Ideal Holdings Ltd.
January 14, 2022
Page 3
approvals, (ii) inadvertently conclude that such permissions or approvals are not required,
or (iii) applicable laws, regulations, or interpretations change and you are required to
obtain such permissions or approvals in the future.
7.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 your businesses,
including your subsidiaries, to the parent company and U.S. investors as well as the ability
to settle amounts owed under agreements.
Risks Relating to Doing Business in China, page 4
8.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or having the majority of the company’s operations in China poses to investors.
In particular, describe the significant regulatory, liquidity, and enforcement risks with
cross-references to the more detailed discussion of these risks in the prospectus. For
example, specifically discuss risks arising from the legal system in China, including risks
and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of the
securities you are registering for sale. Acknowledge any risks that any actions by the
Chinese government to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.
9.Disclose that trading in your securities may be prohibited under the Holding Foreign
Companies Accountable Act if the PCAOB determines that it cannot inspect or fully
investigate your auditor, and that as a result an exchange may determine to delist your
securities. Disclose whether your auditor is subject to the determinations announced by
the PCAOB on December 16, 2021.
Risks Related to Doing Business in China, page 15
10.Given the Chinese government’s significant oversight and discretion over the conduct of

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 Comapany NameMajestic Ideal Holdings Ltd.
 January 14, 2022 Page 4
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd.
January 14, 2022
Page 4
your business, please revise to highlight separately the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of the securities you are registering. Also,
given recent statements by the Chinese government indicating an intent to exert more
oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers, acknowledge the risk that any such action could significantly limit
or completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.
11.In light of recent events indicating greater oversight by the Cyberspace Administration of
China (CAC) over data security, particularly for companies seeking to list on a foreign
exchange, please revise your disclosure to explain how this oversight impacts your
business and your offering and to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.
Our Shares may be prohibited from being traded on a national exchange, page 16
12.We note your disclosure about the Holding Foreign Companies Accountable Act. Please
expand your risk factors to disclose that the United States Senate has passed the
Accelerating Holding Foreign Companies Accountable Act, which, if enacted, would
decrease the number of “non-inspection years” from three years to two years, and thus,
would reduce the time before your securities may be prohibited from trading or delisted.
Update your disclosure to reflect that the Commission adopted rules to implement the
HFCAA and that, pursuant to the HFCAA, the PCAOB has issued its report notifying the
Commission of its determination that it is unable to inspect or investigate completely
accounting firms headquartered in mainland China or Hong Kong.
Certain Relationships and Related-Party Transactions, page 83
13.Please ensure that you have provided the required disclosure for transactions with related
parties for the period since the beginning of your last three fiscal years up to the date of
the registration statement.  In this regard, we note the disclosure in this section about
amounts as of September 30, 2021.
Signatures, page II-3
14.Please indicate below the second paragraph of text required on the Form F-1 Signatures
page who is signing your document in the capacity of controller or principal accounting
officer.

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 Comapany NameMajestic Ideal Holdings Ltd.
 January 14, 2022 Page 5
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd.
January 14, 2022
Page 5
            You may contact Heather Clark, Staff Accountant, at 202-551-3624 or Kevin Woody,
 Accounting Branch Chief, at 202-551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Jay Ingram, Legal Branch Chief, at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Virginia Tam