SecProbe.io

CORRESP
 1
 filename1.htm

 Xpand
Boom Technology Inc.

 18th
Floor, Block B,

 Yuanlun
Building, No. 350 Qifei Road,

 Binjiang
District, Hangzhou City,

 People's
Republic of China

 HZJL
Cayman Limited

 18th
Floor, Block B,

 Yuanlun
Building, No. 350 Qifei Road,

 Binjiang
District, Hangzhou City,

 People's
Republic of China

 September
24, 2025

 VIA
EDGAR

 Kate
Beukenkamp/Donald Field
Division of Corporation Finance

 U.S.
Securities & Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 RE:
 Xpand
 Boom Technology Inc. and HZJL Cayman Limited (the "Co-Registrants")

 Registration
 Statement on Form F-4

 ( File
 No. 333-289591) (the "Registration Statement")

 Dear
Ms. Beukenkamp and Mr. Field:

 The
Co-Registrants hereby request, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that the Registration Statement will become effective as of 4:00 p.m. ET on September
26, 2025, or as soon thereafter as practicable.

 Very truly yours,

 Xpand
 Boom Technology Inc.

 By:
 /s/
 Lulu Xing

 Name:
 Lulu
 Xing

 Title:
 Sole
 Director

 HZJL Cayman Limited

 By:
 /s/
 Bin Xiong

 Name:
 Bin
 Xiong

 Title:
 Chief
 Executive Officer and Director

 Acceleration
Request:

 333-289591

CORRESP
 1
 filename1.htm

 Xpand
Boom Technology Inc.

 18th
Floor, Block B

 Yuanlun
Building, No, 350 Qifei Road

 Binjiang
District, Hangzhou City

 People's
Republic of China

 September
23, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 100
F Street, N.E.

 Division
of Corporation Finance

 Office
of Trade & Services

 Washington,
D.C. 20549

 Attention:
Blaise Rhodes, Rufus Decker, Kate Beukenkamp and Donald Field

 Re:
 Xpand Boom Technology Inc.

 Amendment No. 2 to Registration Statement on Form
 F-4

 Filed September 17, 2025

 File No. 333-289591

 Ladies
and Gentlemen:

 On
behalf of Xpand Boom Technology Inc. ("Xpand") and HZJL Cayman Limited ("HZJL," and together with Xpand, the
"Co-Registrants"), below is the response of the Co-Registrants to the comments of the staff of the Division of Corporation
Finance (the "Staff") of the United States Securities and Exchange Commission (the "Commission") set forth in
the Staff's letter, dated September 22, 2025, regarding the Co-Registrants' Amendment No. 2 to Registration Statement on
Form F-4 (the "Registration Statement") filed with the Commission on September 17, 2025.

 For
your convenience, the Staff's comments are set forth in bold, followed by responses on behalf of the Co-Registrants.

 Amendment
No. 2 to Registration Statement on Form F-4

 Summary
of the Proxy Statement/Prospectus

 Regulatory
Approvals, page 24

 1.
 If you will be requesting
 effectiveness of your Form F-4 registration statement before completing the CSRC process, please confirm in writing that you will
 notify us promptly of any changes to your disclosure regarding or requested by the CSRC.

 Response:
In response to the Staff's comment, we respectfully confirm that we will be requesting the effectiveness of the Registration Statement
before completing the CSRC process, and we will promptly notify the SEC of any changes to our disclosure regarding, or requested by,
the CSRC.

 Please
call Vivien Bai of Loeb & Loeb LLP at (212) 407-4933, David J. Levine of Loeb & Loeb LLP at (212) 407-4923, or Yu Wang of Han
Kun Law Offices LLP at +852 2820 5656 if you have any questions or if would like additional information with respect to any of the foregoing.

 Sincerely,

 /s/
 Lulu Xing

 Name:
 Lulu Xing

 Title:
 Director

 cc:
 Bin Xiong, CEO, HZJL Cayman Ltd.

 Vivien Bai, Esq., Loeb & Loeb LLP

 David J. Levine, Esq., Loeb & Loeb LLP

 Yu Wang, Esq., Han Kun Law Offices LLP

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

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Amendment No. 2 to Registration Statement on Form F-4
 Filed September 17, 2025
 File No. 333-289591
Dear Lulu Xing and Bin Xiong:

 We have reviewed your amended registration statement and have the
following
comment(s).

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

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our September
16,
2025 letter.
 September 22, 2025
Page 2
Amendment No. 2 to Registration Statement on Form F-4
Summary of the Proxy Statement/Prospectus
Regulatory Approvals, page 24

1. If you will be requesting effectiveness of your Form F-4 registration
statement before
 completing the CSRC process, please confirm in writing that you will
notify us
 promptly of any changes to your disclosure regarding or requested by the
CSRC.
 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David J. Levine
 Yu Wang
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Xpand
Boom Technology Inc.

 18th
Floor, Block B

 Yuanlun
Building, No, 350 Qifei Road

 Binjiang
District, Hangzhou City

 People's
Republic of China

 September
17, 2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 100
F Street, N.E.

 Division
of Corporation Finance

 Office
of Trade & Services

 Washington,
D.C. 20549

 Attention:
Blaise Rhodes, Rufus Decker, Kate Beukenkamp and Donald Field

 Re:

 Xpand
 Boom Technology Inc.

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

 Filed
 September 8, 2025

 File
 No. 333-289591

 Ladies
and Gentlemen:

 On
behalf of Xpand Boom Technology Inc. ("Xpand") and HZJL Cayman Limited ("HZJL," and together with Xpand, the
"Co-Registrants"), below is the response of the Co-Registrants to the comments of the staff of the Division of Corporation
Finance (the "Staff") of the United States Securities and Exchange Commission (the "Commission") set forth in
the Staff's letter, dated September 16, 2025, regarding the Co-Registrants' Amendment No. 1 to Registration Statement on
Form F-4 (the "Registration Statement") filed with the Commission on September 8, 2025. In connection with this letter, an
amendment to the Registration Statement (the "Amended Registration Statement") has been filed with the Commission on the
date hereof.

 For
your convenience, the Staff's comments are set forth in bold, followed by responses on behalf of the Co-Registrants. Unless otherwise
indicated, all page references in the responses set forth below are to the pages of the clean copy of the Amended Registration Statement.
Capitalized terms used but not otherwise defined herein shall have the meanings assigned to such terms in the Amended Registration Statement.

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

 Summary
of the Proxy Statement/Prospectus
Dilution, page 20

 1.
 Please
 update the SPAC dilution disclosures here and elsewhere in the filing to start with the SPAC's net tangible book value as of the
 most recent SPAC balance sheet date (i.e., June 30, 2025). Also, disclose how you computed the $1.862 million decrease in net
 tangible book value for payment of offering costs. If it relates to the cash payment of $1.869 million in deferred underwriting
 compensation recorded as a liability on the SPAC's June 30, 2025 balance sheet, also tell us how this transaction would
 have an impact on the SPAC's net tangible book value. If this transaction relates to offering costs not on the SPAC's balance sheet
 as of June 30, 2025, also explain in
 detail.

 Response: In response
to the Staff's comment, we have revised our dilution disclosures on pages 20 and 90 to start with the SPAC's net
tangible book value as of June 30, 2025. We also clarified that the $1.862 million decrease in net tangible book value for payment
of offering costs does not relate to deferred underwriting compensation. Rather this amount represents estimated professional
expenses, including counsel fees, audit fees and other consulting expenses, to be paid upon the closing of the Business Combination.
We have added this explanation in Note (i) to the dilution table on pages 20 and 90.

 Selected
Historical Financial Information of Rising Dragon, page 175

 2.
 The
 income statement data for the period from March 8, 2024 (inception) through June
 30, 2024 is not consistent with the information presented on page F-3. Additionally,
 in the statement of cash flow data, the cash at end of period for the period from March 8,
 2024 (inception) through December 31, 2024 is inconsistent with the corresponding amount
 on page F-21. Please revise accordingly.

 Response: In response to the Staff's comment, we have revised the disclosure on page 175.

 Please
call Vivien Bai of Loeb & Loeb LLP at (212) 407-4933, David J. Levine of Loeb & Loeb LLP at (212) 407-4923, or Yu Wang of Han
Kun Law Offices LLP at +852 2820 5656 if you have any questions or if would like additional information with respect to any of the foregoing.

 Sincerely,

 /s/Lulu
 Xing

 Name:
 Lulu
 Xing

 Title:
 Director

 cc:
 Bin
 Xiong, CEO, HZJL Cayman Ltd.

 Vivien
 Bai, Esq., Loeb & Loeb LLP

 David
 J. Levine, Esq., Loeb & Loeb LLP

 Yu
 Wang, Esq., Han Kun Law Offices LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 16, 2025

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Amendment No. 1 to Registration Statement on Form F-4
 Filed September 8, 2025
 File No. 333-289591
Dear Lulu Xing and Bin Xiong:

 We have reviewed your amended registration statement and have the
following
comment(s).

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

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our July 14,
2025 letter.
 September 16, 2025
Page 2
Amendment No. 1 to Registration Statement on Form F-4
Summary of the Proxy Statement/Prospectus
Dilution, page 20

1. Please update the SPAC dilution disclosures here and elsewhere in the
filing to start
 with the SPAC's net tangible book value as of the most recent SPAC
balance sheet
 date (i.e., June 30, 2025). Also, disclose how you computed the $1.862
million
 decrease in net tangible book value for payment of offering costs. If it
relates to the
 cash payment of $1.869 million in deferred underwriting compensation
recorded as a
 liability on the SPAC's June 30, 2025 balance sheet, also tell us how
this transaction
 would have an impact on the SPAC's net tangible book value. If this
transaction
 relates to offering costs not on the SPAC's balance sheet as of June 30,
2025, also
 explain in detail.
Selected Historical Financial Information of Rising Dragon, page 175

2. The income statement data for the period from March 8, 2024 (inception)
through
 June 30, 2024 is not consistent with the information presented on page
F-3.
 Additionally, in the statement of cash flow data, the cash at end of
period for the
 period from March 8, 2024 (inception) through December 31, 2024 is
inconsistent
 with the corresponding amount on page F-21. Please revise accordingly.
 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David J. Levine
 Yu Wang
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 14, 2025

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Amendment No. 3 to Draft Registration Statement on Form F-4
 Submitted July 7, 2025
 CIK No. 0002060614
Dear Lulu Xing and Bin Xiong:

 We have reviewed your amended draft registration statement and have the
following
comment(s).

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

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our July 1, 2025 letter.
 July 14, 2025
Page 2

Amendment No. 3 to Draft Registration Statement on Form F-4
Summary of the Proxy Statement/Prospectus
Dilution, page 20

1. We note your response to prior comment 1. Your revised label, Company
valuation
 achieved by non-redeeming shareholders immediately upon closing Business
 Combination, appears to imply that the valuation will be achieved
immediately upon
 closing of the business combination, which does not appear to be true.
The dollar
 amounts presented should represent the future company valuation
necessary for the
 non-redeeming shareholders' interest per common share to equal the
original SPAC
 IPO price. Also, revise the dollar amounts presented in each redemption
scenario to
 reflect the 1.75 million ordinary shares to be issued to Chain Stone
Capital Limited, a
 financial advisor, upon closing of the Business Combination and revise
note (a) to
 disclose your inclusion of these shares. Refer to Item 1604(c)(1) of
Regulation S-K.
Unaudited Pro Forma Condensed Combined Financial Information
Unaudited Pro Forma Condensed Combined Balance Sheet, page 181

2. Please revise total assets and total liabilities, mezzanine equity and
shareholders'
 (deficit) equity in the pro forma balance sheet for Scenario 1, so the
columns foot and
 cross foot.
 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David J. Levine
 Yu Wang
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 1, 2025

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Amendment No. 2 to Draft Registration Statement on Form F-4
 Submitted June 20, 2025
 CIK No. 0002060614
Dear Lulu Xing and Bin Xiong:

 We have reviewed your amended draft registration statement and have the
following
comment(s).

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

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our June 11, 2025 letter.
 July 1, 2025
Page 2

Amendment No. 2 to Draft Registration Statement on Form F-4
Summary of the Proxy Statement/Prospectus
Dilution, page 20

1. We read your response to prior comment 5. Please relabel the pro forma
market value
 of the Company immediately upon closing Business Combination title to
not use pro
 forma or market value in the title, since the dollar amounts presented
represent neither
 pro forma nor market value amounts. The dollar amounts presented should
represent
 the company valuation required to be achieved for the non-redeeming
shareholders'
 interest per common share to equal the original SPAC IPO price. Also,
disclose in a
 footnote how you computed these dollar amounts (i.e., multiplied the $10
SPAC IPO
 price by the sum of (a) the as adjusted ordinary shares in each
redemption scenario
 and (b) the 35 million shares to be issued to HZJL Shareholders).
Finally, correct the
 dollar amounts presented to use the aforementioned computation. Refer to
Item
 1604(c)(1) of Regulation S-K.
Capitalization, page 86

2. We read your changes in response to our prior comments 7 and 8, and note
that you
 have removed the amount related to ordinary shares subject to
redemption. Please
 revise to include such shares in the table on a historical basis and
under each
 redemption scenario. Refer to Item 3.B of Form 20-F.
Unaudited Pro Forma Condensed Combined Financial Information
Unaudited Pro Forma Condensed Combined Balance Sheet, page 181

3. Please revise the pro forma cash and cash equivalents amount presented
for Scenario
 1 so it foots.
 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David J. Levine
 Yu Wang
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 11, 2025

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Amendment No. 1 to Draft Registration Statement on Form F-4
 Submitted May 19, 2025
 CIK No. 0002060614
Dear Lulu Xing and Bin Xiong:

 We have reviewed your amended draft registration statement and have the
following
comment(s).

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

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our April 17, 2025 letter.
 June 11, 2025
Page 2

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

1. We note your response to prior comment 1, including that PubCo will be a
"controlled
 company" within the meaning of the corporate governance standards of the
Nasdaq
 listing rules immediately after the consummation of the Business
Combination. Please
 further revise your disclosure here and in your risk factor on page 179
beginning
 "Because PubCo will be a "controlled company"..." to state whether you
plan to elect
 to rely on any of the corporate governance exemptions that will be
available to you
 under Nasdaq rules.
2. We note your response to prior comment 3 and reissue. Please further
revise your
 Equity Capitalization Summary, and any other tabular representation
regarding
 redemption scenarios throughout your proxy statement/prospectus,
including the
 Dilution table on page 20, to disclose redemption scenarios at quartile
intervals. In
 this regard, we note that you provide four redemption scenarios, but
have excluded the
 25% quartile in the presentations. Please revise accordingly.
Questions and Answers About this Business Combination...
Q: After redemptions, how may shares will be outstanding?, page 10

3. We note your response to prior comment 14, including the addition of a
table listing
 the "Others." Please further revise your disclosure to make clear the
name of the
 "financial advisory" listed in the first line under "Others" here. In
this regard, we note
 that elsewhere you describe how Chain Stone Capital Limited ("CTM") was
engaged
 by HZJL as a financial consultant via a financial advisory engagement
agreement and
 that CTM is entitled to receive $600,000 in cash and 1,750,000 PubCo
Class A
 Ordinary Shares upon completion of the Business Combination as
compensation for
 its services.
Summary of the Proxy Statement/Prospectus
Dilution, page 20

4. We read your response to prior comment 19. Please revise your SPAC
dilution
 disclosures to start with the SPAC's net tangible book value as of the
most recent
 SPAC balance sheet date (i.e., March 31, 2025).
5. We read the changes you made in response to prior comment 20. The pro
forma
 market value amount reflected appears to be neither a pro forma amount
nor a market
 value amount. Please revise to the title to more accurately reflect what
the amount
 represents.
Comparative Per Share Information, page 40

6. Please present pro forma book value (deficit) per share information as
of the most
 recent pro forma balance sheet date only (i.e., December 31, 2024).
Also, revise the
 pro forma net (loss) income and basic and diluted net income (loss) per
share
 information for the year ended June 30, 2024, so that it agrees to your
pro forma
 June 11, 2025
Page 3

 financial information on page 184. Also, present pro forma net (loss)
income and
 basic and diluted net income (loss) per share information for the six
months ended
 December 31, 2024.
Capitalization, page 86

7. We read your response to comment 25. Similar to your pro forma balance
sheet on
 page 181, please include a separate line item for each equity security
and disclose the
 number of shares authorized, issued and outstanding for each equity
security on a
 historical basis and under each redemption scenario.
8. We read your response to prior comment 26. Your total capitalization and
 indebtedness should comprise only the sum of your total shareholders
 equity (deficit) and your indebtedness. Please revise the total
capitalization and
 indebtedness line item so that it sums correctly. Also, remove the other
unrelated line
 items that you have presented, which do not relate to your total
capitalization and
 indebtedness (e.g., prepaid expense, accrued liabilities, etc.). Refer
to Item 3.B of
 Form 20-F.
Summary of HZJL Financial Analysis, page 126

9. We note your response to prior comment 33 and reissue in part. Please
revise to
 disclose whether or not HZJL has affirmed to Rising Dragon that its
projections
 reflect the view of the HZJL's management or board of directors about
its future
 performance as of the most recent practicable date prior to the date of
the disclosure
 document required to be disseminated to security holders. If the
projections no longer
 reflect the views of HZJL's management or board of directors regarding
the future
 performance of HZJL as of the most recent practicable date prior to the
date of the
 disclosure document required to be disseminated to security holders,
state the purpose
 of disclosing the projections and the reasons for any continued reliance
by the
 management or board of directors on the projections. Refer to Item
1609(c) of
 Regulation S-K.
Proposal No. 2 - The Acquistion Merger Proposal
Rising Dragon Board of Director's Reasons for Approving the Business
Combination
Summary of HZJL Financial Analysis
HZJL Management Projections
1. Supply of Food Product Business, page 128

10. We read your response to prior comment 32. Please reconcile your
disclosures
 regarding future anticipated food product increases with those on page
158, which
 state the decrease in food products through June 30, 2024, was because
you intend to
 place more focus on development of branding services. In your response,
tell us why
 you believe you have not experienced the synergistic growth you
anticipated in food
 products considering branding services and online software services
revenues
 increased significantly during the six months ended December 31, 2024.
 June 11, 2025
Page 4
Business of HZJL
Overview, page 140

11. We note your response to prior comment 35 and reissue in part.
Specifically, we note
 that your response states that there is an agreement in place between
Beijing Dianqier
 and Shanghai China Business News Media, effective from July 1, 2024 to
December
 30, 2025, Beijing Dianqier will procure guests for Founder s Glory
 and pay
 Shanghai China Business News Media the relevant production fees in
exchange for
 the advertising revenues generated from Founder s Glory. Please
revise your
 disclosure accordingly to include a description and terms (e.g.,
duration) of this
 agreement. Additionally, please file this agreement as an exhibit or
tell us why you do
 not believe it is necessary to be filed under Item 601(b) of Regulation
S-K.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
HZJL
Discussion of Certain Balance Sheet Items, page 162

12. Certain liabilities in the December 31, 2024 column are not consistent
with those
 presented in the unaudited balance sheet on page F-60. Please revise for
consistency.
Selected Historical Financial Information of Rising Dragon, page 175

13. The middle columns in the Income Statement Data and Statement of Cash
Flow
 Data tables appear to represent the period from March 8, 2024 through
March 31,
 2024 rather than three months then ended. Please revise.
Unaudited Pro Forma Condensed Combined Financial Information
Basis of Pro Forma Presentation, page 179

14. We read your response to prior comment 39. Please include the same
number of
 redemption scenarios throughout your pro forma financial information, in
your
 comparative per share information on page 40 and in your capitalization
table on page
 86 that you do elsewhere throughout the filing.
Unaudited Pro Forma Condensed Combined Balance Sheet, page 181

15. Please disclose your basis for not reflecting the payment of the
deferred underwriting
 fees payable under any pro forma scenario. Also, disclose why the
deferred
 underwriting fees payable are not reflected as a current liability under
any pro forma
 scenario that they remain unpaid. In addition, disclose here and in the
footnotes to
 Rising Dragon's historical financial statements:
 the terms of their payment under your agreement with the
underwriter, and
 the ramifications of not meeting those payment terms upon
consummation of the
 Business Combination.
Unaudited Pro Forma Combined Statement of Operations for the Year Ended June
30, 2024,
page 184

16. We read your response to prior comment 41. You continue to exclude the
other
 income, net, net loss attributable to non-controlling interest and net
income (loss)
 June 11, 2025
Page 5

 attributable to ordinary shareholders line items shown on page F-34 from
column (B)
 HZJL on page 184. HZJL's net income in column (B) on page 184 also still
differs
 from the amount shown on page F-34. Please revise or advise.
 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: David J. Levine
 Yu Wang
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 17, 2025

Lulu Xing
Chief Executive Officer
Xpand Boom Technology Inc.
18th Floor, Block B
Yuanlun Building, No, 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

Bin Xiong
Chief Executive Officer
HZJL Cayman Ltd
18th Floor, Block B
Yuanlun Building, No. 350 Qifei Road
Binjiang District, Hangzhou City
People's Republic of China

 Re: Xpand Boom Technology Inc.
 Draft Registration Statement on Form F-4
 Submitted March 21, 2025
 CIK No. 0002060614
Dear Lulu Xing and Bin Xiong:

 We have reviewed your draft registration statement and have the following
comment(s).

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

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.
 April 17, 2025
Page 2

Draft Registration Statement on Form F-4 submitted March 21, 2025
Cover Page

1. We note your disclosure on page 195 that Bin Xiong through XB B Limited
will have
 80% voting power via their Class B Ordinary Share ownership upon
completion of the
 business combination. To the extent PubCo will be a controlled company
after the
 business combination, please revise the proxy statement/prospectus cover
page to (i)
 clearly state as much, (ii) disclose the percentage of voting power to
be held by the
 controlling shareholder following the business combination and (iii) if
true, state that
 the controlling shareholder will have the ability to determine all
matters requiring
 approval by shareholders. Additionally, and if applicable, please
include a standalone
 risk factor that addresses the risks of being a controlled company.
2. Please revise the proxy statement/prospectus cover page to disclose more
clearly the
 RDAC board of directors determination required by Items 1604(a)(1) and
1606(a) of
 Regulation S-K.
3. Please revise your table regarding the Equity Capitalization Summary,
and any other
 tabular representation regarding redemption scenarios throughout your
proxy
 statement/prospectus including the Dilution table on page 20, to
disclose redemption
 scenarios at quartile intervals. Refer to Item 1604(c) of Regulation
S-K.
4. Please refer to the Compensation Received by the Sponsor table on the
proxy
 statement/prospectus cover page. Please revise the "Interest in
Securities" column to
 detail the purchase of Private Units by the Sponsor in connection with
RDAC's
 IPO. Refer to Item 1604(a)(3) of Regulation S-K. Additionally, please
make
 conforming changes to the comparable table on page 29 and elsewhere as
 applicable. Refer to Item 1604(b)(4) of Regulation S-K.
5. Please refer to the "Conflicts of Interest" section on the proxy
statement/prospectus
 cover page. Please revise to address whether, in connection with the
de-SPAC
 transaction, there may be any actual or potential material conflict of
interest between:
 on one hand, the target company officers or target company directors;
and, on the
 other hand, unaffiliated security holders of the SPAC. Refer to Item
1604(a)(4) of
 Regulation S-K.
6. Please revise the "Conflicts of Interest" section to provide a
cross-reference to your
 risk factor beginning "We may have conflicts of interest with our
largest
 shareholders..." on page 64. Refer to Item 1604(a)(4) of Regulation S-K.
Use of Certain Terms, page i

7. For clarity and consistency, please briefly revise certain terms here to
make clear the
 relationship of certain entities to PubCo, RDAC, HZJL or others. For
example, but not
 limited to, we note that "Lucid" refers to Lucid Capital Markets, LLC.
However, it is
 not until page 168 where you disclose Lucid to be the representative of
the
 underwriters in Rising Dragon's IPO.
 April 17, 2025
Page 3
8. We note your disclosure that "Investors will only hold equity interests
in HZJL, a
 Cayman Islands holding company and will never have a direct ownership
interest in
 HZJL's PRC Operating Entities." We also note that this registration
statement relates
 to the registration of securities related to PubCo not HZJL. Please
reconcile and revise
 this disclosure as applicable.
Questions and Answers about the Business Combination and the Extraordinary
General
Meeting
Q: What is the redemption scenario accompanying with the Business Combination?,
page 5

9. For the RDAC Public Shareholders, RDAC Initial Shareholders and Others
share
 amounts presented here and elsewhere throughout the filing, please
disclose with
 quantification in a footnote to the table the composition of the share
amounts
 presented. Also, ensure that the RDAC Public Shareholders and RDAC
Initial
 Shareholders line items are reconciled to share amounts shown in the
latest RDAC
 balance sheet as well. This comment also applies to share amounts titled
differently
 elsewhere in the filing (e.g., shares subject to possible redemption,
shares not subject
 to possible redemption, etc.).
Questions and Answers about the Business Combination...
Q: What is the redemption scenario accompanying with the Business Combination?,
page 5

10. We note that the answer to the included question discusses "book value
per share" and
 pro forma impacts on such value. We also note that the included table
doesn't appear
 to align with the answer and doesn't detail any book value calculations.
Please
 reconcile the answer and included table as applicable.
11. We note that page 114 notes that the parties intend to adopt an Employee
Stock
 Ownership Plan. To the entent known, please revise the "potential
sources of dilution"
 to include details regarding the plan, i.e. the number of reserved
shares, etc.
Q: What will PubCo's share structure be following the Business Combination?,
page 6

12. We note that Bin Xiong through XB B Limited will own all of PubCo's
Class B
 Ordinary Shares. Please revise to disclose their ownerhsip of the Class
B Ordinary
 Shares and the respective voting power to be held by XB B Limited upon
closing of
 the business combination.
Q: Did Rising Dragon obtain a fairness opinion prior to entering into the
Merger Agreement?,
page 9

13. Please revise your disclosure here and elsewhere throughout the proxy
 statement/prospectus where appropriate to briefly describe the
qualifications of CHFT
 as well as describe the method of selection of CHFT. Refer to Item
1607(b)(1)-(3) of
 Regulation S-K.
Q: After redemptions, how many shares will be outstanding?, page 10

14. We note that the table includes an "Others" line. Please revise to
include a footnote to
 disclose who is included within this line item (i.e. underwriters or
financial
 advisors).
 April 17, 2025
Page 4

Q: What happens to the funds deposited in the trust account following the
Business
Combination?, page 13

15. Please revise the answer to discuss in greater detail how the funds in
the trust account
 will be used in connection with the business combination. Consider
adding a table or
 chart to detail the use of such funds.
Post-Business Combination Structure and Impact on the Public Float, page 19

16. Please revise this post-business combination structure diagram to
include both share
 holdings as well as voting percentages held by the respective parties.
17. Please revise this corporate structure diagram to include the place of
incorporation for
 each entity. Consider the use of footnotes. In this regard, we note that
below the
 diagram you state that "HZJL 100% owns Joy A Limited, a British Virgin
Islands
 business company, which 100% owns HZJL's other subsidiaries."
Summary of the Proxy Statement/Prospectus
Dilution, page 20

18. The redemption of public shares in an amount that would cause Rising
Dragon s net
 tangible assets to be less than $5,000,001 could prevent the Business
Combination
 from proceeding. Please revise your dilution table and other redemption
scenarios
 throughout the filing to only reflect redemption scenarios that are
possible under
 current terms, without the need for a waiver.
19. Please revise your SPAC dilution disclosures to start with the SPAC's
net tangible
 book value as of the most recent SPAC balance sheet date presented.
20. The company valuation amounts presented here and elsewhere throughout
the
 filing do not represent your company's valuation. Please revise the
title to better
 reflect what it actually represents. Refer to Item 1604(c)(1) of
Regulation S-K.
Regulatory Approvals, page 24

21. We note your disclosure that you are required to file with the CSRC in
connection
 with this offering and the business combination. In subsequent
amendments, please
 disclose the date of filing and the status of your filing with the CSRC.
Interests of Certain Persons in the Business Combination, page 30

22. Please revise this section or add a new conflicts of interest section
for the target
 company to disclose any actual or potential material conflict of
interests due to the de-
 SPAC transaction between the target company officers and directors and
unaffiliated
 security holders of RDAC. Refer to Item 1604(b)(3) of Regulation S-K.
Summary of Risk Factors, page 33

23. Please amend your disclosure here and risk factors sections to provide
an appropriate
 risk factor and state that, to the extent cash/assets in the business is
in the PRC/Hong
 Kong or a PRC/Hong Kong entity, the funds/assets may not be available to
fund
 operations or for other use outside of the PRC/Hong Kong due to
interventions in or
 the imposition of restrictions and limitations on the ability of you or
your subsidiaries
 April 17, 2025
Page 5

 by the PRC government to transfer cash/assets. On the cover page,
provide cross-
 references to these other discussions. We note your discussion under the
subheading
 "Cash Transfers among HZJL and its Subsidiaries" on page 23.
Risk Factors
Risks Related to Ownership of PubCo's Securities
We may have conflicts of interest with our largest shareholder..., page 64

24. Please revise this risk factor and elsewhere throughout the proxy
statement/prospectus
 where appropriate to quantify the voting power that will be held by your
largest
 shareholder immediately after the completion of the business
combination. In this
 regard, we note that here you describe the largest shareholder as having
"a fair
 amount" of voting rights. Additionally, we note that the tables in the
section titled
 "Security Ownership of the Combined Company after the Business
 Combination" reflects voting power by Mr. Bin Xiong of up to 80%
assuming no
 redemptions and up to 83.1% assuming maximum redemptions. Further,
please revise
 this risk factor to name your largest shareholder and state his
position.
Capitalization, page 84

25. Please discuss each adjustment being made to arrive at the as adjusted
amounts in
 each scenario presented. Also, break out the shareholders' equity line
item into its
 separate components.
26. Your total capitalization equals the sum of your total stockholders'
equity and non-
 controlling interest, however, please note capitalization is generally
defined in
 practice as the sum of a company's debt and equity. Please revise or
advise
 accordingly. Refer to Item 3.B of Form 20-F.
U.S. Federal Income Tax Consequences of the Reincorporation Merger to U.S.
Holders, page
93

27. Please provide a tax opinion covering the material federal tax
consequences to RDAC
 security holders regarding the Reincorporation Merger and revise the
disclosure in
 this section to acknowledge and reflect that the tax consequences are
the opinion of
 counsel. Refer to Item 4(a)(6) of Form F-4 and Items 601(b)(8) and
1605(b)(6) of
 Regulation S-K. For guidance in preparing the opinion and related
disclosure, please
 refer to Section III of Staff Legal Bulletin No. 19. Additionally,
please revise to
 address and express a conclusion for each material federal tax
consequence, i.e.
 whether the Reincorporation Merger qualifies as a reorganization with in
the meaning
 of Section 368 of the Code. A description of the law is not sufficient.
If there is a lack
 of authority directly addressing the tax consequences of the
transaction, conflicting
 authority or significant doubt about the tax consequences of the
transaction, counsel
 may issue a should or more likely than not opinion to make
clear that the opinion
 is subject to a degree of uncertainty. In such cases, counsel should
explain clearly why
 it cannot give a will opinion. Refer to Sections III.C.1, III.C.2
and III.C.4 of Staff
 Legal Bulletin No. 19.
 April 17, 2025
Page 6
Proposal No. 2 - The Acquisition Merger
General Description of the Acquisition Merger, page 99

28. Please revise to disclose whether Mr. Bin Xiong, the Chief Executive
Officer of
 HZJL, has entered into any agreement with the company to continue his
employment
 and role with HZJL in connection with the business combination.
29. Please revise this section to describe the effects of the de-SPAC
transaction and any
 related financing transaction on the special purpose acquisition company
and its
 affiliates, the SPAC sponsor and its affiliates, and unaffiliated
security holders of the
 special purpose acquisition company. The description must include a
reasonably
 detailed discussion of both the benefits and detriments of the de-SPAC
transaction and
 any related financing transaction to the special purpose acquisition
company and its
 affiliates, the SPAC sponsor and its affiliates, and unaffiliated
security holders of the
 special purpose acquisition company. The benefits and detriments of the
de-SPAC
 transaction and any related financing transaction must be quantified to
the extent
 practicable. We note your discussion under the subheading "Benefits and
Detriments
 of the Business Combination HZJL" on page 128. Refer to Item 1605(c) of
Regulation
 S-K.
Selected Comparable Companies:, page 118

30. We note your disclosure regarding the selection of Supply of Food
Products, Online
 Software Services and Branding Services comparable companies used in
reaching the
 valuation of $350 million for HZJL, including the disclosed differences
between
 HZJL and these companies, and employing a conservative valuation metric.
However,
 please revise your disclosure to briefly discuss why you did not select
any earlier-
 stage companies or companies that are otherwise at more similar revenue
or other
 financial metric levels to that of HZJL in determining a valuation. In
this regard, we
 note your disclosure that states that HZJL is "an early-stage company"
as compared to
 the comparable companies, which are generally better capitalized and
more
 established business operations than HZJL.
2. Online Software Services Business, page 126

31. Please explain the source of and assumptions behind forecasted income
derived from
 agency fees and subscription revenues, as these sources of revenue are
not found
 elsewhere in your filing. In addition, please provide the basis for and
discuss the
 assumptions and factors used to determine the 580 agents in 2025,
including how this
 number of agents was derived from historical data. Similarly revise your
disclosures
 regarding the assumptions and factors used in arriving at the forecasted
revenues for
 the branding services business. Also, disclose your rationale for
assuming the volume
 of promotional units will increase from 260 thousand in 2025 to 11.65
million in
 2029.
 April 17, 2025
Page 7
Proposal No. 2 - The Acquisition Merger Proposal
Rising Dragon Board of Director's Reasons for Approving the Business
Combination
Summary of HZJL Financial Analysis
HZJL Management Projections
1. Supply of Food Product Business, page 126

32. Food product busine