SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 29, 2025

Zhang Guowei
Chief Executive Officer
Jingbo Technology, Inc.
Floor 1 to 6, No. 1 to 10 Chuangyi Road
Yinhu Village, Shoujiang Town
Fuyang District, China 310000

 Re: Jingbo Technology, Inc.
 Form 10-K for the Fiscal Year Ended February 29, 2024
 File No. 000-56570
Dear Zhang Guowei:

 We have completed our review of your filing. 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.

 Sincerely,

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

CORRESP
 1
 filename1.htm

 Lawrence
 Venick
 Partner

 2206-19
 Jardine House
 1
 Connaught Place Central
 Hong
 Kong, SAR

 Direct +852.3923.1188
 Main
 +852.3923.1111
 Fax
 +852.3923.1100
 lvenick@loeb.com

 Via
Edgar

 May
6, 2025

 Morgan
Youngwood and Stephen Krikorian

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 Washington,
D.C. 20549

 Re:
 Jingbo
 Technology, Inc. (the " Company ")

 Form
 10-K/A for the Fiscal Year Ended February 29, 2024

 Form
 10-K for the Fiscal Year Ended February 29, 2024

 Response
 dated April 8, 2025

 File
 No. 000-56570

 Dear
Messrs. Youngwood and Krikorian,

 As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated April 22, 2025 from the Securities
and Exchange Commission (the " Commission ") in which the staff of the Commission (the " Staff ") commented
on the above-referenced Form 10-K/A (the " Form 10-K/A ") for the Fiscal Year Ended February 29, 2024 and Form 10-K
for the Fiscal Year Ended February 29, 2024 (the " Form 10-K ").

 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. The Company has filed an amendment to the Form 10-K (the " Amendment ") in
response to the Staff's comments.

 Amendment
3 to Form 10-K/A for the Fiscal Year Ended February 29, 2024

 Financial
Information Related to the Consolidated VIE, Trusts and Partnerships, page 9

 1.
 We
 note your revised disclosures in response to prior comment 2. Please revise the table to
 include a column for the Huixin WFOE and present your equity investment interest in, and
 your share of Huixin WFOE's net income or losses. Explain why your schedules of Selected
 Condensed Consolidated Balance Sheets Information do not include a separate line item and
 eliminating adjustments for the Parent's investment in Huixin WFOE. In addition, the
 table should present Huixin WFOE's economic interest in the VIE's business operations
 through contractual agreements between the VIEs and Huixin WFOE. That is, Huixin WFOE should
 present the service fee income and related receivable due from the VIE to the WFOE from the
 date the Exclusive Business Corporation Agreement was signed (i.e., WOFE's share of
 VIEs' income or losses). Lastly, refer to all schedules, including the header, as condensed
 "consolidating" financial data. Consider reordering the table to start with the
 parent, then the WOFE and the VIEs accordingly. Supplementally provide us with revised tables.

 Response :
The Company has amended pages 9 and 10 of the Amendment in response to the Staff's comments.

 The
Company added one line in the table on page 9 of the Amendment. The Company respectfully submitted that no service fee and accounts receivable
are due from the VIE to the WFOE since the exclusive business corporation agreement was signed. Pursuant to the exclusive business corporation
agreement, the service fee shall be the net income of the VIE after deducting all the necessary expenses, fees and taxes (excluding the
consulting fee paid to WFOE), offsetting any losses from previous years, and retaining other legally required amounts amounts. As VIE
made losses since the exclusive business corporation agreement was signed, no fee is due to WFOE.

 Item
1A. Risk Factors

 "We
do not have direct ownership of some of our operating entities in Chinese Mainland, but

 exercise
control over...", page 19

 2.
 We
 note your revised disclosures in response to prior comment 4 that state "As a result, through such contractual arrangements
 with the VIE and its shareholders, we are the primary beneficiary of the VIE, and, therefore, consolidate the financial results of
 the VIE in our consolidated financial statements in accordance with all of our current revenue is derived from our VIE in Chinese
 Mainland." Your disclosures appear to infer ownership over the VIEs (e.g., "our VIE"). Please refrain from using
 terms such as "we" or "our" when describing activities or functions of a VIE.

 Response :
The Company has amended pages 19, 20, 21, 22, and 34 of the Amendment in response to the Staff's comments.

 Item
9. Changes in and Disagreements with Accountants on Accounting and Financial

 Disclosure

 Item
9A. Controls and Procedures

 Evaluation
of Disclosure Controls and Procedure,, page 72

 3.
 We
 note your revised disclosures in response to prior comment 5 state "Based on this evaluation of our disclosure controls and
 procedures as of February 28, 2024, our management concluded that our disclosure controls and procedures as of such date are effective
 at the reasonable assurance level." We also note from your disclosures that there are material weaknesses and management concluded
 that your internal controls over financial reporting were not effective as of February 29, 2024. Please help us better understand
 how you were able to conclude that your disclosure controls and procedures are effective when there are material weaknesses in your
 internal controls over financial reporting.

 Response :
The Company has amended page 72 of the Amendment in response to the Staff's comments. A word was inadvertently omitted in the document,
which unintentionally altered the intended meaning.

 *
* *

 Please
contact the undersigned at +1 310 7285129 if you have any questions with respect to the response contained in this letter.

 Sincerely,

 /s/
 Lawrence S. Venick

 Lawrence
 Venick

 Partner

 cc:
Zhang Guowei

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 22, 2025

Zhang Guowei
Chief Executive Officer
Jingbo Technology, Inc.
Floor 1 to 6, No. 1 to 10 Chuangyi Road
Yinhu Village, Shoujiang Town
Fuyang District, China 310000

 Re: Jingbo Technology, Inc.
 Form 10-K/A for the Fiscal Year Ended February 29, 2024
 Form 10-K for the Fiscal Year Ended February 29, 2024
 Response dated April 8, 2025
 File No. 000-56570
Dear Zhang Guowei:

 We have reviewed your April 8, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March
25, 2025 letter.

Amendment 3 to Form 10-K/A for the Fiscal Year Ended February 29, 2024
Financial Information Related to the Consolidated VIE, Trusts and Partnerships,
page 9

1. We note your revised disclosures in response to prior comment 2. Please
revise the
 table to include a column for the Huixin WFOE and present your equity
investment
 interest in, and your share of Huixin WFOE's net income or losses.
Explain why your
 schedules of Selected Condensed Consolidated Balance Sheets Information
do not
 include a separate line item and eliminating adjustments for the
Parent's investment in
 Huixin WFOE. In addition, the table should present Huixin WFOE's
economic
 interest in the VIE s business operations through contractual
agreements between the
 VIEs and Huixin WFOE. That is, Huixin WFOE should present the service
fee
 income and related receivable due from the VIE to the WFOE from the date
the
 April 22, 2025
Page 2

 Exclusive Business Corporation Agreement was signed (i.e., WOFE's share
of VIEs'
 income or losses). Lastly, refer to all schedules, including the header,
as condensed
 "consolidating" financial data. Consider reordering the table to start
with the parent,
 then the WOFE and the VIEs accordingly. Supplementally provide us with
revised
 tables.
Item 1A. Risk Factors
"We do not have direct ownership of some of our operating entities in Chinese
Mainland, but
exercise control over...", page 19

2. We note your revised disclosures in response to prior comment 4 that
state "As a
 result, through such contractual arrangements with the VIE and its
shareholders, we
 are the primary beneficiary of the VIE, and, therefore, consolidate the
financial results
 of the VIE in our consolidated financial statements in accordance with
all of our
 current revenue is derived from our VIE in Chinese Mainland." Your
disclosures
 appear to infer ownership over the VIEs (e.g., our VIE ). Please
refrain from using
 terms such as we or our when describing activities or
functions of a VIE.
Item 9. Changes in and Disagreements with Accountants on Accounting and
Financial
Disclosure
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedure,, page 72

3. We note your revised disclosures in response to prior comment 5 state
"Based on this
 evaluation of our disclosure controls and procedures as of February 28,
2024, our
 management concluded that our disclosure controls and procedures as of
such date are
 effective at the reasonable assurance level." We also note from your
disclosures that
 there are material weaknesses and management concluded that your
internal controls
 over financial reporting were not effective as of February 29, 2024.
Please help us
 better understand how you were able to conclude that your disclosure
controls and
 procedures are effective when there are material weaknesses in your
internal controls
 over financial reporting.
 Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at
202-
551-3488 if you have questions regarding comments on the financial statements
and related
matters.

 Sincerely,

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

CORRESP
 1
 filename1.htm

 Lawrence
 Venick
 Partner

 2206-19
 Jardine House
 1
 Connaught Place Central
 Hong
 Kong, SAR

 Direct +852.3923.1188
 Main
 +852.3923.1111
 Fax +852.3923.1100
 lvenick@loeb.com

 Via
Edgar

 April
8, 2025

 Morgan
Youngwood and Stephen Krikorian

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Technology

 Washington,
D.C. 20549

 Re:
 Jingbo
 Technology, Inc. (the " Company ")
 Form
 10-K/A for the Fiscal Year Ended February 29, 2024
 Form
 10-K for the Fiscal Year Ended February 29, 2024
 Response
 dated March 14, 2025
 File
 No. 000-56570

 Dear
Messrs. Youngwood and Krikorian,

 As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated March 25, 2025 from the Securities
and Exchange Commission (the " Commission ") in which the staff of the Commission (the " Staff ") commented
on the above-referenced Form 10-K/A (the " Form 10-K/A ") for the Fiscal Year Ended February 29, 2024 and Form 10-K
for the Fiscal Year Ended February 29, 2024 (the " Form 10-K ").

 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. The Company has filed an amendment to the Form 10-K (the " Amendment ") in
response to the Staff's comments.

 Form
10-K/A for the Fiscal Year Ended February 29, 2024

 VIE
Structure and Risks Relating to Our Corporate Structure, page 3

 1.
 Disclose
 each permission or approval that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to operate your
 business and to offer the securities being registered to foreign investors. State whether you, your subsidiaries, or VIEs 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 VIE's 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, your subsidiaries, or the VIEs: (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.

 Response :
The Company has amended page 3 of the Amendment in response to the Staff's comments.

 Financial
Information Related to the Consolidated VIEs, Trusts and Partnerships, page 8

 2.
 We
 note that the consolidated VIEs constitute a material part of your consolidated financial statements. Please provide in tabular form
 a condensed consolidating schedule that disaggregates the operations and depicts the financial position, cash flows, and results of
 operations as of the same dates and for the same periods for which audited consolidated financial statements are required. The
 schedule should present major line items, such as revenue and cost of goods/services, and subtotals and disaggregated intercompany
 amounts, such as separate line items for intercompany receivables and investment in subsidiary. The schedule should also
 disaggregate the parent company, the VIEs and its consolidated subsidiaries, the WFOEs that are the primary beneficiary of the VIEs,
 and an aggregation of other entities that are consolidated. The objective of this disclosure is to allow an investor to evaluate the
 nature of assets held by, and the operations of, entities apart from the VIE, as well as the nature and amounts associated with
 intercompany transactions. Any intercompany amounts should be presented on a gross basis and when necessary, additional disclosure
 about such amounts should be included in order to make the information presented not misleading.

 Response :
The Company has amended pages 8-11 of the Amendment in response to the Staff's comments.

 Transfers
of Cash through Our Organizations, page 8

 3.
 Provide
 a clear description of how cash is transferred through your organization. Disclose your intentions
 to distribute earnings or settle amounts owed under the VIE agreements. Quantify any cash
 flows and transfers of other assets by type that have occurred between the holding company,
 its subsidiaries, and the consolidated VIEs, and direction of transfer. Quantify any dividends
 or distributions that a subsidiary or consolidated VIE have made to the holding company and
 which entity made such transfer, and their tax consequences. Similarly quantify dividends
 or distributions made to U.S. investors, the source, and their tax consequences.
 Your disclosure should make clear if no transfers, dividends, or distributions have been
 made to date. Describe any restrictions on foreign exchange and your ability to transfer
 cash between entities, across borders, and to U.S. investors. Describe any restrictions and
 limitations on your ability to distribute earnings from the company, including your subsidiaries
 and/or the consolidated VIEs, to the parent company and U.S. investors as well as the ability
 to settle amounts owed under the VIE agreements.

 Response :
The Company has amended page 11 of the Amendment in response to the Staff's comments.

 Item
1A. Risk Factors

 "We
do not have direct ownership of some of our operating entities in Chinese Mainland, but

 exercise
control over...", page 16

 4.
 You
 disclose that 31% of [Y]our current revenue is derived from our VIEs in Chinese Mainland. Your disclosures appear to infer ownership
 over the VIEs (e.g., "our VIEs"). Please refrain from using terms such as "we" or "our" when
 describing activities or functions of a VIE.

 Response :
The Company has amended the Risk Factors section in response to the Staff's comments.

 Item
9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

 Item
9A. Controls and Procedures

 Evaluation
of Disclosure Controls and Procedure, page 69

 5.
 We
 note your response to prior comment 3 and reissue our comment. We note that you did not disclose management's conclusion regarding
 the effectiveness of your disclosure controls and procedures as of February 29, 2024. Please revise to disclose management's
 conclusion of the effectiveness of your disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e) under the
 Securities
 Exchange
 Act of 1934. We refer you to Item 307 of Regulation S-K. Please note that Item 9 of the Form 10-K requires that you furnish information
 required by Item 307 and 308 of Regulation S-K.

 Response :
 The Company has amended page 72 of the Amendment in response to the Staff's
 comments.

 6.
 We
 note that your most recent amendment no longer includes the following statement "Based on this assessment, management concluded
 that our internal controls over financial reporting were not effective as of February 29, 2024." Please revise to disclose
 management's conclusion of the effectiveness of your internal controls over financial reporting as defined in Rule 13a-15(f)
 under the Securities Exchange Act of 1934. We refer you to Item 308 of Regulation S-K. Please note that Item 9 of the Form 10-K requires
 that you furnish information required by Item 307 and 308 of Regulation S-K. In this respect, you are required to disclose managements'
 conclusion of the effectiveness of both disclosure controls and procedures and internal controls over financial reporting.

 Response :
The Company has amended page 72 of the Amendment in response to the Staff's comments.

 *
* *

 Please
contact the undersigned at +1 310 7285129 if you have any questions with respect to the response contained in this letter.

 Sincerely,

 /s/
 Lawrence S. Venick

 Lawrence
 Venick

 Partner

 cc:
Zhang Guowei

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 25, 2025

Zhang Guowei
Chief Executive Officer
Jingbo Technology, Inc.
Floor 1 to 6, No. 1 to 10 Chuangyi Road
Yinhu Village, Shoujiang Town
Fuyang District, China 310000

 Re: Jingbo Technology, Inc.
 Form 10-K/A for the Fiscal Year Ended February 29, 2024
 Form 10-K for the Fiscal Year Ended February 29, 2024
 Response dated March 14, 2025
 File No. 000-56570
Dear Zhang Guowei:

 We have reviewed your March 14, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our February
13, 2025 letter.

Form 10-K/A for the Fiscal Year Ended February 29, 2024
VIE Structure and Risks Relating to Our Corporate Structure, page 3

1. Disclose each permission or approval that you, your subsidiaries, or the
VIEs are
 required to obtain from Chinese authorities to operate your business and
to offer the
 securities being registered to foreign investors. State whether you,
your subsidiaries,
 or VIEs 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 VIE s
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, your subsidiaries, or the
VIEs: (i) do
 March 25, 2025
Page 2

 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.
Financial Information Related to the Consolidated VIEs, Trusts and
Partnerships, page 8

2. We note that the consolidated VIEs constitute a material part of your
consolidated
 financial statements. Please provide in tabular form a condensed
consolidating
 schedule that disaggregates the operations and depicts the financial
position, cash
 flows, and results of operations as of the same dates and for the same
periods for
 which audited consolidated financial statements are required. The
schedule should
 present major line items, such as revenue and cost of goods/services,
and subtotals
 and disaggregated intercompany amounts, such as separate line items for
 intercompany receivables and investment in subsidiary. The schedule
should also
 disaggregate the parent company, the VIEs and its consolidated
subsidiaries, the
 WFOEs that are the primary beneficiary of the VIEs, and an aggregation
of other
 entities that are consolidated. The objective of this disclosure is to
allow an investor to
 evaluate the nature of assets held by, and the operations of, entities
apart from the
 VIE, as well as the nature and amounts associated with intercompany
transactions.
 Any intercompany amounts should be presented on a gross basis and when
necessary,
 additional disclosure about such amounts should be included in order to
make the
 information presented not misleading.
Transfers of Cash through Our Organizations, page 8

3. Provide a clear description of how cash is transferred through your
organization.
 Disclose your intentions to distribute earnings or settle amounts owed
under the VIE
 agreements. Quantify any cash flows and transfers of other assets by
type that have
 occurred between the holding company, its subsidiaries, and the
consolidated VIEs,
 and direction of transfer. Quantify any dividends or distributions that
a subsidiary or
 consolidated VIE have made to the holding company and which entity made
such
 transfer, and their tax consequences. Similarly quantify dividends or
distributions
 made to U.S. investors, the source, and their tax consequences. Your
disclosure
 should make clear if no transfers, dividends, or distributions have been
made to date.
 Describe any restrictions on foreign exchange and your ability to
transfer cash
 between entities, across borders, and to U.S. investors. Describe any
restrictions and
 limitations on your ability to distribute earnings from the company,
including your
 subsidiaries and/or the consolidated VIEs, to the parent company and
U.S. investors
 as well as the ability to settle amounts owed under the VIE agreements.
Item 1A. Risk Factors
"We do not have direct ownership of some of our operating entities in Chinese
Mainland, but
exercise control over...", page 16

4. You disclose that 31% of [Y]our current revenue is derived from our VIEs
in Chinese
 Mainland. Your disclosures appear to infer ownership over the VIEs
(e.g., our
 VIEs ). Please refrain from using terms such as we or our
when describing
 activities or functions of a VIE.
 March 25, 2025
Page 3

Item 9. Changes in and Disagreements with Accountants on Accounting and
Financial
Disclosure
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedure, page 69

5. We note your response to prior comment 3 and reissue our comment. We
note that
 you did not disclose management's conclusion regarding the effectiveness
of your
 disclosure controls and procedures as of February 29, 2024. Please
revise to disclose
 management's conclusion of the effectiveness of your disclosure controls
and
 procedures as defined in Rules 13a-15(e) and 15d-15(e) under the
Securities
 Exchange Act of 1934. We refer you to Item 307 of Regulation S-K. Please
note that
 Item 9 of the Form 10-K requires that you furnish information required
by Item 307
 and 308 of Regulation S-K.

6. We note that your most recent amendment no longer includes the following
statement
 "Based on this assessment, management concluded that our internal
controls over
 financial reporting were not effective as of February 29, 2024." Please
revise to
 disclose management s conclusion of the effectiveness of your internal
controls over
 financial reporting as defined in Rule 13a-15(f) under the Securities
Exchange Act of
 1934. We refer you to Item 308 of Regulation S-K. Please note that Item
9 of the
 Form 10-K requires that you furnish information required by Item 307 and
308 of
 Regulation S-K. In this respect, you are required to disclose
managements' conclusion
 of the effectiveness of both disclosure controls and procedures and
internal controls
 over financial reporting.

 Please contact Morgan Youngwood at 202-551-3479 or Stephen Krikorian at
202-
551-3488 if you have questions regarding comments on the financial statements
and related
matters.

 Sincerely,

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

CORRESP
 1
 filename1.htm

 Lawrence
 Venick
 Partner

 2206-19
 Jardine House
 1 Connaught Place Central
 Hong Kong, SAR

 Direct +852.3923.1188
 Main +852.3923.1111
 Fax +852.3923.1100
 lvenick@loeb.com

 Via
Edgar

 March
14, 2025

 Morgan Youngwood and Stephen Krikorian Securities and Exchange Commission Division of Corporation Finance Office of Technology Washington, D.C. 20549

 Re:
 Jingbo Technology, Inc. (the " Company ")
 Form 10-K/A for the Fiscal Year Ended February 29, 2024
 Form 10-K for the Fiscal Year Ended February 29, 2024
 File No. 000-56570

 Dear
Messrs. Youngwood and Krikorian,

 As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated February 13, 2025 from the
Securities and Exchange Commission (the " Commission ") in which the staff of the Commission (the " Staff ")
commented on the above-referenced Form 10-K/A (the " Form 10-K/A ") for the Fiscal Year Ended February 29, 2024, Form
10-K for the Fiscal Year Ended February 29, 2024 (the " Form 10-K ").

 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.

 Form
10-K/A for the Fiscal Year Ended February 29, 2024

 General

 1. Please
 revise your filing, as applicable, to provide more specific and prominent disclosures about
 the legal and operational risks associated with China-based companies. For additional guidance,
 please see the Division of Corporation Finance's Sample Letter to China-Based Companies
 issued by the Statt in December 2001.

 Response :
Please refer to pages 3 and 16 of the amended Form 10-K.

 Principal
Robert CALDWELL Roy CHOI Michael FUNG Lewis HO Jeffrey KUNG Lynia LAU Shirley LAU Wallace LAU Alfred LEE Polly LIU Terence WONG

 A
Hong Kong firm of solicitors.

 Los
Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com

 For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.

 Securities and Exchange Commission
 Page 2

 Capital
Stock, page 4

 2. You
 disclose that you "conducted a reverse stock split of the Company's issued and
 outstanding shares of common stock, par value $0.001 per share (the "Common Stock"),
 at a ratio of 1-for-200 (the "Reverse Stock Split")." The Reverse Stock
 Split should result in the adjustment of your computations of basic and diluted EPS retroactively
 for all periods presented to reflect that change in capital structure. Refer to ASC 260-10-55-12,
 505-10-S99-4, and 505-20-30-6. Please revise future filings to retroactively present your
 capital structure in your balance sheet and other disclosures for the Reverse Stock Split.

 Response :
The Company noted the comment of the Staff. Please refer to pages 10, 37, 42, 43, 44, 47, 52 and 68 of the amended Form 10-K.

 Item
9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure.

 Item
9A. Controls and Procedures.

 Evaluation
of Disclosure Controls and Procedures, page 46

 3. We
 note that you did not disclose management's conclusion regarding the effectiveness
 of your disclosure controls and procedures as of February 29, 2024. Please revise to disclose
 management's conclusion of the effectiveness of your disclosure controls and procedures
 as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934. We
 refer you to Item 307 of Regulation S-K. Please note that Item 9 of the Form 10-K requires
 that you furnish information required by Item 307 and 308 of Regulation S-K.

 Response :
Please refer to page 69 of the amended Form 10-K.

 *
* *

 Please
contact the undersigned at +1 310 7285129 if you have any questions with respect to the response contained in this letter.

 Sincerely,

 /s/
 Lawrence S. Venick

 Lawrence
 Venick

 Partner

 cc:
Zhang Guowei

CORRESP
1
filename1.htm

Jingbo
Technology, Inc.

Building
B8, China Zhigu, Yinhu Street,

Fuyang
District, Hangzhou,

Zhejiang,
China

+86
57187197085

Via
Edgar

February
28, 2025

Morgan
Youngwood and Stephen Krikorian

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Technology

Washington,
D.C. 20549

    Re:
    Jingbo
Technology, Inc. (the “Company”)

    Form
    10-K/A for the Fiscal Year Ended February 29, 2024

    Form
    10-K for the Fiscal Year Ended February 29, 2024

    File
    No. 000-56570

Dear
Messrs Youngwood and Krikorian:

This
letter is to confirm our telephone conversation through counsel with you on February 26, 2025 regarding our request for an extension
of time to respond to your comment letter dated February 13, 2025. We are working expeditiously to respond to the comment letter. However,
as discussed, we require additional time to prepare a response. As a result, we respectfully request that you allow us
to submit our response by March 14, 2025.

If
you have any questions about this response or require additional information, please contact me at zgw_savmobi@163.com or our
counsel Rongwei Xie at +1-202-290-5504.

Respectfully
submitted,

Jingbo
Technology, Inc.

/s/
Zhang Guowei

Zhang
Guowei

President,
Chief Executive Officer, Chief Financial Officer and Secretary and Director

February 13, 2025
Zhang Guowei
Chief Executive Officer
Jingbo Technology, Inc.
Floor 1 to 6, No. 1 to 10 Chuangyi Road
Yinhu Village, Shoujiang Town
Fuyang District, China 310000
Re:Jingbo Technology, Inc.
Form 10-K/A for the Fiscal Year Ended February 29, 2024
Form 10-K for the Fiscal Year Ended February 29, 2024
File No. 000-56570
Dear Zhang Guowei:
            We have limited our review of your filings to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K/A for the Fiscal Year Ended February 29, 2024
General
1.Please revise your filing, as applicable, to provide more specific and prominent
disclosures about the legal and operational risks associated with China-based
companies.  For additional guidance, please see the Division of Corporation Finance's
Sample Letter to China-Based Companies issued by the Statt in December 2001.
Capital Stock, page 4
You disclose that you "conducted a reverse stock split of the Company’s issued and
outstanding shares of common stock, par value $0.001 per share (the “Common
Stock”), at a ratio of 1-for-200 (the “Reverse Stock Split”)." The Reverse Stock Split
should result in the adjustment of your computations of basic and diluted EPS
retroactively for all periods presented to reflect that change in capital structure. Refer
to ASC 260-10-55-12, 505-10-S99-4, and 505-20-30-6. Please revise future filings to 2.

February 13, 2025
Page 2
retroactively present your capital structure in your balance sheet and other disclosures
for the Reverse Stock Split.
Item 9. Changes in and Disagreements with Accountants on Accounting and Financial
Disclosure.
Item 9A. Controls and Procedures.
Evaluation of Disclosure Controls and Procedures, page 46
3.We note that you did not disclose management's conclusion regarding the
effectiveness of your disclosure controls and procedures as of February 29, 2024.
Please revise to disclose management's conclusion of the effectiveness of your
disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e) under
the Securities Exchange Act of 1934. We refer you to Item 307 of Regulation S-K.
Please note that Item 9 of the Form 10-K requires that you furnish information
required by Item 307 and 308 of Regulation S-K.
            In closing, 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 Morgan Youngwood at 202-551-3479 or Stephen Krikorian at 202-
551-3488 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

savmobi _ corresp.htm
October 29, 2015
Mark P. Shuman
Securities and Exchange Commission
Washington, D.C. 20549
Re: T-Bamm
Amendment No. 1 to Registration Statement on Form S-1
Filed September 8, 2015
File No. 333-206804
Dear Mr. Shuman; Page 1of8
In response to your letter dated October 2, 2015 the following information, corresponding sequentially to the paragraphs in
your letter, is hereby submitted on behalf of SavMobi Technology Inc. (the "Company"). Amendment No. 1 to Registration
Statement on Form S-1 is being filed concurrently with this letter.
The Company has made certain changes in the Form S-1 filing in response to the Staff's comments. For your convenience, we
have reproduced below the comments contained in the Staff's October 2, 2015 letter in italicized text immediately before our
response.
1. We note your disclosure on page 36 stating that you "expect the balance of proceeds to be mainly applied to further
costs of this prospectus and administrative costs." However, we note your tabular disclosure on page 16 indicating
that irrespective of the proceeds raised, you intend to allocate the majority of the proceeds towards general business
development, and sales and marketing. Please ensure that your disclosure consistently describe your intended
allocations of proceeds.
Response:
We have deleted our disclosure on page 36 so we are consistent in our intended allocation of funds.
2. With respect to every third-party statement in your prospectus, such as the Borrell Associates report, please ensure
that you have disclosed the report dates and provide us with the relevant portions of the industry research reports
you cite. To expedite our review, please clearly mark each source to highlight the applicable portion containing the
statistics, and cross-reference it to the appropriat e location in your prospectus and tell us whether any of the reports
were prepared for you.
Response:
We have revised our disclosure on the Borrell Associates report on page 22 and have attached the relevant portion of the
industry research report cited for your reference . The calculations provided is from the information found on page 16 of 27
(attached) of Borrell Associates Market Demographics , Spending Estimates Target Categories for Online Ad Sales Revenue
Share Estimates Forecasts are from Table 8C: 2007 Market Estimates for Top 20 Online Ad Categories with Local
Ownership: They include; 66.5% of'07 Estimated Online Ad Expenditures of$67,919,701 is $45,166,601.165 divided by the
applicable number of targeted businesses (Ground Transportation- 42,390; Trucking Services- 189,990; Travel Services-
94,720; Telecommunications- 66,070; Other Utilities- 36,110; Retail Home Improvement- 106,680; Food Stores-217,010;
Apparel and Accessory Stores-134,710; Eating and Drinking Places-521,630; Banks-43,930; Credit & Mortgage Services-
97,690; Financial Services- 81,390; Insurance Services- 192,900) for a total of 1,825,220 business is an average of24.74 per
month and rounded up to $299 per year.
No reports referred to within the prospectus were written for or on behalf of the Company.
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savmobi ___ corresp.htm Page 2of8
3. Revise your summary to disclosure that your auditors have expressed substantial doubt about your ability to
continue as a f(oinf( concern.
Response:
We have revised our disclosure on pages 3 and 7 to disclose that our auditors have expressed substantial doubt about our
ability to continue as a going concern.
Risks and Uncertainties Facing the Company, page 6
4. We note your disclosure on page 22, where you estimate the total software development cost for your platform and
app at $38,000. Please revise your disclosure here to describe quantitatively the threshold gross offering amount
require to the fund the software development . ·
Response:
We have revised our disclosure on page 22 to include the minimum required to implement its business plan in the
development of its proposed software.
Use of Proceeds. page 8
5. You state that you may fund your operations through loans based on a verbal agreement with Mr. Sidhu. Where your
reference such loans throughout the document, please also state whether the agreement with Mr. Sidhu to provided
funding is legally binding, to the extent that it is not, revise throughout to state clearly and unequivocally that there
is no f(Uarantee that he will provide such.funding
Response:
We have revised our disclosure throughout the offering tostate that the verbal loan agreement between Mr. Sidhu and the
Company is not legally binding nor is it guaranteed .
2
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Risk Factors. page 9
6. Please add a risk factor that clearly and unequivocally states that you have not yet developed you software platform
or app, and that the resultant risk is that you may never be able to develop a product that is operational or
marketable .
Response:
We have revised our disclosure and have added a risk factor that clearly states that we have not yet developed our software
platfonn or app.
7. Please add separately captioned risk factor disclosing the minimum number of months that you will be able to
conduct your planned operations using currently available capital resources. In addition, disclose the minimum
dollar amount of funding you require to implement your business plan for a minimum period of one year. Revise
your discussion in Capital Resources and Liquidity to also include this if!formation.
Response:
We have revised our disclosure to clearly set forth the allocation of proceeds at various levels of proceeds.
"Because our sole officer and director resides abroad .... " Page 13
8. Please provide a more detailed description of your risk factor addressing why shareholders may have difficulties
enforcing their legal rights under United States security laws. Please address the risk U.S. stockholders face in:
• effecting service of process with the United States against your officer;
• enforcing judgements obtained in U.S. courts based on civil liability provisions of the U.S. federal securities
laws in foreign courts against your officer; and
• bringing an original action in foreign courts to enforce liabilities based on the U.S. federal securities laws
against your officer.
Response:
We have revised our disclosure on page 13 in the offering to provide a more detailed description in processing and enforcing
United States securities laws in a foreign jurisdiction
"Because our Company is a shell company .... " Page 13
9. Please expand your disclosure to explain that Securities Act Rule 144 will not be available for privately placed
shares, and highlight the impact on your ability to attract additional capital to implement your business plan or
sustain operations .
3
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savmobi _ corresp.htm Page 4 of 8
Response:
We have revised our disclosure to explain that privately placed shares under Securities Act Rule 144 may impact our ability
to attract additional capital and the implementation of our business plan and sustain our operations.
Plan of Distribution. page 19
10. You state that you intend to sell the shares outside the United States, particularly in India. Please expand your plan
of distribution discussion with respect to you plan to sell shares in India.
Response:
We have revised our disclosure within the offering on page 19 and have expanded our plan of distribution discussion with
respect to selling shares in India.
11. You state the offering may be extended 90 days beyond the period described in this section, or "such period as the
Company deems reasonable." Please revise your disclosur e to ensure that your intentions in regards to extending the
offering period are balanced with the requirements of Rule 415 and sections 10( a)(3) of the Securities Act.
Response:
We have revised our disclosure in the offering and have eliminated our ability to extend by 90 days the period described in
this section.
Description of Securities to be Registered
Non-cumulative voting. page 20
12. You state that if the offering is completed the "present shareholders" will hold 21% of the offering. This statement is
inconsistent with your disclosures in the beneficial ownership table. Please revise or advise.
Response:
We have corrected our statement on page 20 "Non-cumulative voting." in the offering from "present shareholders" will hold
21% of the offering to 78.95% of this offering.
Description of Business
Marketing Opportunity and Value Proposition. page 24
4
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13. We note that you reference the boom in the smartphone market as potentially providing your company the
opportunity to generate more revenue through your proposed Mobile Marketing Platform. Please refocus your
discussion on the specific market opportunity you intend to pursue, which you state is vendor tools technology.
Response:
We have revised our disclosure on page 24 to refocus our discussions on the marketing opportunity the Company intends to
pursue with our vendor tools technology .
Competition, page 25
14. We note your disclosure referring to your "current revenue streams" and statement that your ''primary source oj
revenue comes from local, small businesses." Since you have yet to generate revenues, these disclosures appear
inappropriate, as they suggest the contrary.
Response:
We have revised our disclosure in our offering on page 25 to correctly disclose our proposed revenue streams and proposed
sources of revenues.
15. Please expand your disclosure to describe with more specificity on what competitive bases you intend to distinguish
yourself.
Response:
We have revised and expanded our disclosure on page 25 to provide specific details on what competitive bases we
distinguish ourselves from the competition .
Directors and Executive Officers
Business Experience, page 31
16. Please revise the description relating to Mr. Sidhu's professional background to ensure that such disclosures fully
comply with Item 401(1) of Regulation S-K. For example, disclose Mr. Sindhu's principal occupations and
employment, in a chronologically complete manner, for the jive year period immediately preceding the date oj
effectiveness.
Response:
We have revised our disclosure on page 31 to clarify Mr. Sidhu's professional background to ensure that such disclosures
fully comply with Item (401)1 of Regulation S-K.
5
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17. We note your disclosur e stating that Mr. Sidhu has not held any previous directorships in the past five years.
However , we note that the Nevada Secretary of State's website indicates that in addition to serving as an officer for
SavMobi Technology, Inc., Mr. Sidhu served as an officer and director for SavMobi , Inc. within the past five years.
Please advise whether this is your CEO, and if so, please provide your analysis for why such professional experienc e
is not disclosed in the registration statement . To the extent material, revise your discussion of trademarks on page 2 5
to discuss whether your ability to obtain a trademark may be impacted by the prior formation of SavMobi, Inc.
Response:
The company SavMobi, Inc. was a Nevada corporation, incorporated on July 13, 2013 by Mr. Sidhu. SavMobi, Inc. was
never active and Mr. Sidhu is in the process of dissolving SavMobi, Inc. with the Nevada Secretary of State. We believe that
as SavMobi, Inc., had no business activities, did not obtain an I.R.S. Employer Identification number and did not raise any
capital; that to disclose Mr. Sidhu's association with SavMobi, Inc., is not material and would not add anything to his
professional experience . Further, the ability to obtain a trademark for the Company under this offering will not be impacted
as Mr. Sidhu incorporated both corporations and is dissolving SavMobi, Inc.
We trust our responses meet with your approval.
Sincerely ,
Isl Lakhwind er Singh Sidhu
President
6
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CORRESP
1
filename1.htm

savmobi_corresp.htmFebruary 8, 2016

THE UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
Mail Stop 7010 100 F Street, NE
Washington, DC 20549

    Attn:

 Mark P. Shuman

 Branch Chief - Legal

 Office of Information Technologies and Services

Re:

 SavMobi Technology Inc. (the "Company")

 Registration Statement on Form S-1

Filed February 4, 2016

 File No. 333-206804

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of the effective date of its Registration Statement on Form S-1 to 12:00 p.m. (Eastern Standard Time) on February 10, 2016 or as soon thereafter as is practicable.

In connection with the Company's request for acceleration of the effective date of its Registration Statement on Form S-1, the Company acknowledges the undertakings in Rule 461 and that:

 ·

 Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 ·

 The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 ·

 The Company may not assert this action as defence in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Thank you for your assistance.

Very truly yours,

        SavMobi Technology Inc.

By: /s/ Lakhwinder Singh Sidhu

 Lakhwinder Singh Sidhu

 President/Chief Executive Officer

CORRESP
1
filename1.htm

savmobi_corresp.htmFebruary 3, 2016

THE UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
Mail Stop 7010 100 F Street, NE
Washington, DC 20549

    Attn:

 Mark P. Shuman

 Branch Chief - Legal

 Office of Information Technologies and Services

Re:

 SavMobi Technology Inc. (the "Company")

 Request for Acceleration of Effective Date filed February 2, 2016

 File No. 333-206804

We request the withdrawal of our filing for acceleration of effective dated, filed on February 2, 2016. We will file an amendment within the next two days.

Thank you for your assistance.

Very truly yours,

SavMobi Technology Inc.

/s/ Lakhwinder Singh Sidhu

Lakhwinder Singh Sidhu

President/Chief Executive Officer

CORRESP
1
filename1.htm

savmobi_corresp.htmFebruary 2, 2016

THE UNITED STATES SECURITIES
AND EXCHANGE COMMISSION
Mail Stop 7010 100 F Street, NE
Washington, DC 20549

    Attn:

 Mark P. Shuman

 Branch Chief - Legal

 Office of Information Technologies and Services

Re:

 SavMobi Technology Inc. (the "Company")

 Registration Statement on Form S-1

Filed January 14, 2016

 File No. 333-206804

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests acceleration of the effective date of its Registration Statement on Form S-1 to 12:00 p.m. (Eastern Standard Time) on February 4, 2016 or as soon thereafter as is practicable.

In connection with the Company's request for acceleration of the effective date of its Registration Statement on Form S-1, the Company acknowledges the undertakings in Rule 461 and that:

 ·

 Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 ·

 The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 ·

 The Company may not assert this action as defence in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Thank you for your assistance.

Very truly yours,

    SavMobi Technology Inc.

/s/ Lakhwinder Singh Sidhu

Lakhwinder Singh Sidhu

President/Chief Executive Officer

Mail Stop 4561
  November 13, 2015

Lakhwinder Singh Sidhu, President
SavMobi Technology Inc.
73B Bank Avenue
Amritsar, Punjab, 143001
India

Re: SavMobi Technology Inc.
Amendment No. 1 to Registration Statement on Form S -1
Filed October 30, 2015
  File No. 333 -206804

Dear Mr. Sidhu:

We have reviewed your amended 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 bel ieve 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.   Unless we note
otherwise , our references to prior comments are to comments in our October 2, 2015 letter .

Risk Factors, page 9

1. We reissue prior comment 7 in part, insofar as you have not disclosed here and in Capital
Resources and Liquidity, the minimum number of months that yo u will be able to
conduct your planned operations using currently available capital resources .

Description of Business, page 22

2. We note your response to prior comment 2.  However, please further revise your
disclosure to explain that the market data presented in this section represents calculations
you have made based on underlying data contained in the Borrell Associates report,
rather than data points actually contained in the reports.

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
November 13, 2015
Page 2

 3. We note your response to pri or comment 4.  However, your disclosure on page 23, states
that “ the tot al software development cost [is] $38,000. ”  Elsewhere in your filing you
state that you requ ire a minimum of $25,000 of gross off ering proceeds, to implement
your business plan.   Please revise to ensure your capital needs are stated consistently, or
tell us why you believe that the existing disclosure s consistently state such needs.

Competition , page 25

4. You state that Yelp and Pirq are your biggest competitors .  This disclosure suggest s that
you are currently operating in this business space.   Since you have yet to launch your
mobile solution, it appears that you should revise this statement to  reflect that you expect
these companies to be competitors in the future.

5. We note your response to prior comment 14.  Please further revise your disclosures to
describe whether the features you intend to include in your software, that you describe in
the ultimate paragraph of page 25, are already included other apps or software.

Business Experience, page 31

6. We note that the biographica l information for your director and officer  has a promotional
tone.  Please revise to limit the information to factually verifiable statements.

7. We note y our response to prior comment 6;  however,  we are unable to concur with your
assertion that this information is not required to be disclosed pursuant to Item 401 of
Regulation S -K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain  that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accu racy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement, please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant  to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
November 13, 2015
Page 3

  the company may not assert staff comments and the declaration of effec tiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for accel eration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relat e to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Morgan Youngwood, Staff Accountant, at (202) 551 -3479, or Stephen
Krikorian, Accounting Branch Chief, at (202) 551 -3488, if you have any questions regarding
comments on the financial statements and other related matters.  If you have any ot her questions,
please contact Ivan Griswold, Attorney -Advisor, at (202) 551 -3853 or in his absence, me at
(202) 551 -3462.  If you require further assistance, please contact Barbara C. Jacobs, Assistant
Director, at (202) 551 -3730.

        Sincerely,

        /s/ Mark P. Shuman

        Mark P. Shuman
        Branch Chief - Legal
Office of Information
Technologies and Services

cc:  Andrew Befumo, Esq.
 Befumo and Schaeffer, PLC

Mail Stop 4561
  October 2 , 2015

Lakhwinder Singh Sidhu, President
SavMobi Technology Inc.
73B Bank Avenue
Amritsar, Punjab, 143001
India

Re: SavMobi Technology Inc.
Registration Statement on Form S -1
Filed September 8, 2015
  File No. 333-206804

Dear Mr. Sidhu :

 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 registratio n 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 regi stration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. We note your disclosure on page 36 stating that you “ expect the balance of the proceeds
to be mainly applied to further costs of this prospectus and administrative costs. ”
However, we note your tabular disclosure on page 16 indicating that irrespective of the
proceeds raised, you intend to allocate a majority of the proceeds towards general
business development, and sales and marke ting.  Please ensure that your disclosure
consistently describe your intended allocations of proceeds.

2. With respect to every third -party statement in your prospectus, such as the  Borell
Associates report , please ensure that you have disclosed the report d ates, and provide us
with the relevant portions of the industry research reports you cite.  To expedite our
review, please clearly mark each source to highlight the applicable portion containing the

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
October 2, 2015
Page 2

 statistic, and cross -reference it to the appropriate loca tion in your prospectus and tell us
whether any of the reports were prepared for you.

3. Revise your summary to disclose that your auditors have expressed substantial doubt
about your ability to continue as a going concern.

Risks and Uncertainties Facing th e Company, page 6

4. We note your disclosure on page 22, where you estimate the total software development
cost for your platform an d app at $38,000.  Please revise your disclosure here to describe
quantitatively the threshold gross offering amount required to fund the software
development.

Use of Proceeds, page 8

5. You state that  you may fund you r operations through loans based on a verbal agreement
with Mr. Sidhu .  Where you reference such loans throughout the document, please also
state whether the agreement with Mr. Sidhu to provide funding is legally binding , to the
extent that it is not, revise throughout to state  clearly and unequivocally that  there is no
guarantee that he will provide such funding.

Risk Factors , page 9

6. Please add a risk f actor that clearly and unequivocally states that you have not yet
developed your software platform or app, and that the resultant risk is that you may never
be able to develop a product that is operational or marketable.

7. Please add a separately captioned  risk factor disclosing the minimum number of months
that you will be able to conduct your planned operations using currently available capital
resources.  In addition, disclose the minimum dollar amount of funding you require to
implement your business plan for a minimum period of one year.  Revise your discussion
in Capital Resources and Liquidity to also include this information.

“Because our sole officer  and director resides abroad…,” page 13

8. Please provide a more detailed description of your risk factor addressing why
shareholders may have difficulties enforcing their legal rights under  United States
securities laws.  Please address the risk U.S. stockh olders face in:

 effecting service of process within the United States against your officer;
 enforcing judgments obtained in U.S. courts based on civil liability provisions of the
U.S. federal securities laws in foreign courts against your officer; and
 bringing an original action in foreign courts to enforce liabilities based on the U.S.
federal securities laws against your officer.

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
October 2, 2015
Page 3

 “Because our Company is a shell company …,” page 13

9. Please expand your disclosure to explain that  Securities Act Rule 144 will not be
available  for privately placed shares, and highlight the impact on your ability to attract
additional capital to implement your business plan or sustain operations.

Plan of Distribution, page 19

10. You state that you int end to sell the shares outside the United States, particularly in India.
Please expand your plan of distribution discussion with respect to your plan to sell shares
in India.

11. You state that the offering may be extended 90 days beyond the period described in this
section, or “such period as the Company deems reasonable.”  Please revise your
disclosure to ensure that your intentions in regards to extending the offering period are
balanced with the requirements of Rule 415 and section 10(a)(3) of the Securiti es Act.

Description of Securities to be Registered

Non-cumulative voting, page 20

12. You state that if the offering is completed the “present shareholders” will hold 21% of the
offering.  This st atement is inconsistent with your disclosures in the  beneficial ownership
table.  Please revis e or advise.

Description of Business

Market Opportunity and Value Proposition , page 24

13. We note that you reference the boom in the smartphone market as potentially providing
your company the opportunity to generate more revenue through your proposed Mobile
Marketing Platform.   Please refocus your discussion on the specific market opportunity
you intend to pursue, which you state is vendor tools technology.

Competition, page 25

14. We note your disclosure referring to your “current revenue streams” and statement that
your “primary source of revenue comes from local, small businesses.”  Since y ou have
yet to generate revenues, these disclosures appear inappropriate, as they suggest the
contrary.

15. Please expand your disclosure to describe with more specificity on what competitive
bases you intend to distinguish yourself.

Lakhwinder Singh Sidhu
SavMobi Technology Inc.
October 2, 2015
Page 4

 Directors  and Executive Officers

Business Experience, page 31

16. Please revise  the description relating to Mr. Sidhu’s  professional background  to ensure
that such disclosures fully comply with Item 401(e) of Regulation S -K.  For example,
disclose Mr. Sindhu’s  principal occupations  and employment, in a chronologically
complete manner, for the five year period immediately precedi ng the date of
effectiveness.

17. We note your disclosure stating that Mr. Sidhu has not held any previous directorships in
the past five years.  However, w e note tha t the Nevada Secretary of State’ s website
indicates that in addition to serving as an officer for SavMobi Technology, Inc., Mr.
Sidhu served as an officer  and director  for SavMobi, Inc. , within the past five years.
Please advise whether this is yo ur CEO, and if so, please provide your analysis for why
such professional experience is not disclosed in the registration statement.    To the extent
material, revise your discussion of trademarks on page 25 to discuss whether your ability
to obtain a trade mark may be impacted by the prior formation of SavMobi, Inc.

You may contact Morgan Youngwood, Staff Accountant, at (202) 551 -3479, or Stephen
Krikorian, Accounting Branch Chief, at (202) 551 -3488, if you have any questions regarding
comments on the finan cial statements and other related matters.  If you have any other questions,
please contact Ivan Griswold, Attorney -Advisor, at (202) 551 -3853 or in his absence, me at
(202) 551 -3462.  If you require further assistance, please contact Barbara C. Jacobs, As sistant
Director, at (202) 551 -3730.

        Sincerely,

        /s/ Mark P. Shuman

        Mark P. Shuman
        Branch Chief - Legal
Office of Information
Technologies and Services

cc:  Andrew Befumo , Esq.
 Befumo and Schaeffer, PLC