SecProbe.io

CORRESP
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 filename1.htm

 December 31, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549

 Attn: Mr. Eddie Kim

 Re: Zeta Network Group
 Registration Statement on Form F-3 (File No. 333-292327)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of Regulation
C (" Rule 461 ") promulgated under the Securities Act of 1933, as amended, the undersigned registrant (the
" Registrant ") hereby requests that the effectiveness of the above-referenced Registration Statement on Form
F-3 (the " Registration Statement ") be accelerated to, and that the Registration Statement become effective at,
4:00 p.m., Eastern Time on January 5, 2026, or as soon thereafter as practicable.

 If there is any change in
the acceleration request set forth above, the Registrant will promptly notify you of the change, in which case the Registrant may be making
an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may be made
by an executive officer of the Registrant or by any attorney from the Registrant's U.S. counsel, Cooley LLP.

 If you have any questions
regarding this request and to provide notice of effectiveness, please contact Reid S. Hooper by phone at +1 202 776 2097 or via email
at rhooper@cooley.com or Yilin Xu by phone at +86 10 8540 0695 or via email at yilin.xu@cooley.com.

 Very truly yours,

 Zeta Network Group

 By:
 /s/ Samantha Huang

 Name:
 Samantha Huang

 Title:
 Chief Executive Officer

 cc: Lili Jiang, Chief Financial Officer, Zeta Network Group
Yilin Xu, Esq., Cooley LLP
Reid S. Hooper, Esq., Cooley LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 December 30, 2025

Samantha Huang
Chief Executive Officer
Zeta Network Group
14 Wall Street, 20th Floor
New York, NY 10005

 Re: Zeta Network Group
 Registration Statement on Form F-3
 Filed December 22, 2025
 File No. 333-292327
Dear Samantha Huang:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Eddie Kim at 202-551-8713 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Yilin Xu
</TEXT>
</DOCUMENT>

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COLOR STAR TECHNOLOGY CO., LTD.

80 Broad Street, 5th Floor

New York, NY 10007

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Rebekah Reed

August 26, 2024

    Re:
    Color Star Technology Co., Ltd.

    Registration Statement on Form F-3 (File No. 333-281668)

    Initially Filed on August 20, 2024

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended, Color Star Technology Co., Ltd. (the “Company”) hereby requests acceleration of effectiveness of the above referenced
Registration Statement, so that it will become effective at 4:30 p.m. ET on August 28, 2024, or as soon as thereafter practicable.

Very truly yours,

    /s/ Louis Luo

    Name: Louis Luo

    Title: Chief Executive Officer

    cc:
    Joan Wu, Esq.

    Hunter Taubman Fischer & Li LLC

August 26, 2024
Louis Luo
Chief Executive Officer
Color Star Technology Co., Ltd.
80 Broad Street, 5th Floor
New York, NY 10005
Re:Color Star Technology Co., Ltd.
Registration Statement on Form F-3
Filed August 20, 2024
File No. 333-281668
Dear Louis Luo:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that
the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Rebekah Reed at 202-551-5332 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Joan Wu

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COLOR STAR TECHNOLOGY CO., LTD.

7 World Trade Center, Suite 4621

New York, NY 10022

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Jennie Beysolow

June 29, 2023

    Re:
    Color Star Technology Co., Ltd.

    Registration Statement on Form F-3 (File No. 333- 272844)

    Initially Filed on June 23, 2023

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933,
as amended, Color Star Technology Co., Ltd. (the “Company”) hereby requests acceleration of effectiveness of the above referenced
Registration Statement, so that it will become effective at 4:30 p.m. ET on July 3, 2023, or as soon as thereafter practicable.

Very truly yours,

    /s/ Louis Luo

    Name: Louis Luo

    Title: Chief Executive Officer

    cc:
    Joan Wu, Esq.

    Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
June 29, 2023
Wei Zhang
Chairwoman
Color Star Technology Co., Ltd.
7 World Trade Center, Suite 4621
New York, NY 10022
Re:Color Star Technology Co., Ltd.
Registration Statement on Form F-3
Filed June 23, 2023
File No. 333-272844
Dear Wei Zhang:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jennie Beysolow at 202-551-8108 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Joan Wu, Esq.

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Color Star Technology Co., Ltd.

 800
3rd Ave, Suite 2800

New York, NY 10022

June 21, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

    Re:
    Color Star Technology Co., Ltd.

    Registration Statement on Form F-3

    Originally filed on May 26, 2021

    Registration No. 333-256508

Dear Sir or Madam:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities
Act of 1933, as amended, Color Star Technology Co., Ltd. hereby requests the Securities and Exchange Commission take appropriate action
to cause the above-referenced Registration Statement on Form F-3 to become effective on June 23, 2021, at 4:00 PM Eastern Time, or as
soon thereafter as is practicable.

Please feel free to direct any questions or comments concerning this request
to our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

     By:
    /s/ Basil Wilson

    Basil Wilson

    Chief Executive Officer

United States securities and exchange commission logo
June 4, 2021
Basil Wilson
Co Chief Executive Officer
Color Star Technology Co., Ltd.
800 3rd Avenue, Suite 2800
New York, NY 10022
Re:Color Star Technology Co., Ltd.
Registration Statement on Form F-3
Filed May 26, 2021
File No. 333- 256508
Dear Mr. Wilson :
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Hannah Menchel at 202-551-5702 or Pam Howell at 202-551-3357 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

United States securities and exchange commission logo
March 1, 2021
Biao (Luke) Lu
Chief Executive Officer
Color Star Technology Co., Ltd.
800 3rd Avenue, Suite 2800
New York, NY 10022
Re:Color Star Technology Co., Ltd.
Form 20-F for the Fiscal Year Ended June 30, 2020
Filed November 13, 2020
File No. 333-226308
Dear Mr. Lu:
            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 Real Estate & Construction
cc:       Elizabeth Fei Chen

CORRESP
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Color Star Technology Co., Ltd.

800 3rd Ave, Suite 2800

New York, NY 10022

February 26, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

Attention: Frank Knapp

    RE:
    Color
    Star Technology Co., Ltd.

    Form
    20-F for the Fiscal Year Ended June 30, 2020

    Filed
    November 13, 2020

    File
    No. 333-226308

Ladies and Gentlemen:

This letter is being
furnished in response to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the
Securities and Exchange Commission (the “Commission”) that were contained in the Staff’s letter dated
February 8, 2021, to Color Star Technology Co., Ltd. (the “Company”) with respect to its Annual Report on Form
20-F for the fiscal year ended June 30, 2020, filed with the Commission on November 13, 2020 (the “Original Form 20-F”).

In response to the
Staff’s comments, we have filed the Amendment No. 1 to the Original Form 20-F for the purpose of amending Exhibit 12.1 and
12.2 of the Original Form 20-F in order to include the internal control over financial reporting language.

If you have any questions,
please do not hesitate to contact the undersigned at 228027057@qq.com, or Elizabeth F. Chen of Pryor Cashman LLP, outside counsel
to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

    Very truly yours,

    /s/ Biao (Luke) Lu

    Biao (Luke) Lu

    Chief Executive Officer

    cc:
Elizabeth Fei Chen, Esq.

United States securities and exchange commission logo
February 8, 2021
Biao (Luke) Lu
Chief Executive Officer
Color Star Technology Co., Ltd.
800 3rd Avenue, Suite 2800
New York, NY 10022
Re:Color Star Technology Co., Ltd.
Form 20-F for the Fiscal Year Ended June 30, 2020
Filed November 13, 2020
File No. 333-226308
Dear Mr. Lu:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended June 30, 2020
Exhibit 12.1 and 12.2, page 1
1.We note that your certifications do not include paragraph 4(b) related to internal control
over financial reporting.   It appears your annual report on Form 20-F for the fiscal year
ended June 30, 2020 represents your second annual report and therefore you are no longer
within the transition period.   Pursuant to Question 246.13 of the Compliance and
Disclosure Interpretations of Regulation S-K, please file an amendment that is limited to
the cover page, explanatory note, signature page, and paragraphs 1, 2, 4, and 5 of the
certification.

 FirstName LastNameBiao (Luke) Lu
 Comapany NameColor Star Technology Co., Ltd.
 February 8, 2021 Page 2
 FirstName LastName
Biao (Luke) Lu
Color Star Technology Co., Ltd.
February 8, 2021
Page 2
            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.
            You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Wilson Lee, Staff
Accountant at (202) 551-3468 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Elizabeth Fei Chen

United States securities and exchange commission logo
December 17, 2020
Biao (Luke) Lu
Chief Executive Officer
Color Star Technology Co., Ltd.
800 3rd Ave, Suite 2800
New York NY 10022
Re:Color Star Technology Co., Ltd.
Registration Statement on Form F-1
Filed December 11, 2020
File No. 333-251315
Dear Mr. Lu:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Ronald (Ron) E. Alper at 202-551-3329 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Elizabeth Fei Chen

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Color Star Technology Co., Ltd.

800 3rd Ave, Suite 2800

New York, NY 10022

December 18, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C. 20549

Attention: Ronald (Ron) E. Alper

RE:  Color
                                         Star Technology Co., Ltd.

    Registration Statement on Form F-1

    Filed December 11, 2020

    File No. 333-251315

Ladies and Gentlemen:

Color Star Technology Co.,
Ltd. (the “Company”) hereby requests that the above-captioned registration statement (the “Registration Statement”)
be declared effective at 9 a.m., Eastern Time on Wednesday, December 23, 2020, or as soon thereafter as may be practicable.

We acknowledge that a declaration
by the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority,
that the Registration Statement is effective does not foreclose the Commission from taking any action with respect to the Registration
Statement. We further acknowledge that such a declaration of effectiveness does not relieve the Company from our full responsibility
for the adequacy and accuracy of the disclosure in the Registration Statement. We understand that we may not assert staff comments
to the Registration Statement or the declaration of effectiveness by the Commission as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

If you have any questions,
please do not hesitate to contact the undersigned at 228027057@qq.com, or Elizabeth F. Chen of Pryor Cashman LLP, outside counsel
to the Company, at echen@pryorcashman.com (Tel: 212-326-0199).

    Very truly yours,

    /s/ Biao (Luke) Lu

    Biao (Luke) Lu

    Chief Executive Officer

cc:  Elizabeth
Fei Chen, Esq.

CORRESP
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COLOR STAR TECHNOLOGY COMPANY, LIMITED.

800 3rd Ave, Suite 2800

New York NY 10022

(212) 220-3967

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

August 13,
2020

    Re:
    Color Star Technology Company, Limited. (the “Company”)

    File No. 333- 238510

    Registration Statement on Form F-3 (the “Registration Statement”)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

The Company
filed the Registration Statement on Form F-3 on May 19, 2020. Pursuant to Rule 461 under the Securities Act of 1933, as amended,
the Company respectfully requests acceleration of the effective date of the Registration Statement to 5 pm ET on August 17, 2020
or as soon as practicable thereafter.

The Company acknowledges that:

• Should the Securities
and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the Registration
Statement effective, the Commission is not foreclosed from taking any action with respect to the Registration Statement;

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

• The Company may
not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

Very truly yours,

COLOR STAR TECHNOLOGY COMPANY, LIMITED.

By:	/s/ Biao Liu

Name:	Biao Liu

Title:	Chief
Executive Officer

CORRESP
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Color
Star Technology Company, Limited

800
3rd Ave, Suite 2800

New
York, NY 10022

July
10, 2020

Attn:
Wilson Lee, Robert Telewicz, Ruairi Regan, Pam Howell

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Real Estate & Construction

Washington,
D.C. 20549

    Re:
    Color
    Star Technology Company, Limited

    Form
    F-3

    Response
    Filed June 9, 2020

    File
    No. 333-239510

Dear
Mr. Lee, Mr. Telewicz, Mr. Regan, and Mr. Howell:

Color
Star Technology Company, Limited (the “Company,” “we”, or “our”), an
exempt company formed under the laws of Cayman Islands, hereby transmits its response to the letter received from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”), dated June 17, 2020
regarding our Response to the Staff’s comment letter on Form F-3 previously filed on June 9, 2020. For ease of reference,
we have repeated the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement
on Form F-3 submitted accompanying this response letter is referred to as F-3/A.

FORM
F-3 FILED ON MAY 19, 2020

Our
Business

History
and Development of the Company, page 3

 1. We
                                         have considered your response to comment one and note your conclusion that held for sale
                                         criteria was not met until March 2020. Please address the following with respect to your
                                         response:

 ● Given
                                         the footnote disclosures in your interim financial statements outlining your decision
                                         to dispose of your concrete business as early as November 2019 and the eventual disposition
                                         through sale to existing shareholders, it remains unclear why held for sale criteria
                                         was not met prior to March 2020. Please tell us how you considered the guidance in Section
                                         855-10-25 of the Accounting Standards Codification in determining that the details related
                                         to your disposition represented a non-recognized versus recognized subsequent event.
                                         Your response should outline all facts and circumstances considered that support your
                                         conclusion.

Response:
We acknowledge the Staff’s comment and respectfully inform the Staff that our footnote disclosures in our interim financial
statements only disclosed that we received a notification letter (the “Deficiency Notice”) from The Nasdaq Stock Market
LLC (“Nasdaq”) regarding the Company’s noncompliance Nasdaq’s stockholders’ equity requirements
in November 2019. At the time of receipt of the Deficiency Notice, we have not begun planning for the disposition of our concrete
business. It is also further disclosed in the footnote disclosures that the Company’s decision to dispose of the concrete
business only came after February 2020.

    1

As
discussed in our prior response letter dated June 9, 2020 in our response to comment No. 1, we determined that we met all of the
criteria in accordance with ASC 205-20-45-1E for discontinued operations classification in the beginning of March 2020. We evaluated
the guidance in ASC 855-10-25 and determined that the details related to our disposition represented a non-recognized subsequent
event rather than a recognized subsequent event. ASC 855-10-25-3 provided examples of recognized and non-recognized subsequent
events described in ASC 855-10-55-2. Per the examples provided in ASC 855-10-25-3b, a business combination that occurs after the
balance sheet date but before the financial statements are issued or available to be issued are considered a non-recognized subsequent
event. We interpreted the disposal of our concrete business transaction as discontinued operations in March 2020 to be most akin
to the business combination or acquisition transaction in accordance with ASC 855-10-25-3b. As a result, we interpreted the disposal
of our concrete business transaction in March 2020 as a non-recognized subsequent event to our interim financial statements for
the period ended December 31, 2019.

 ● Please
                                         tell us whether you believe the disposition of your concrete business is a material change
                                         in your business affairs. In your response, please clarify how you assessed the need
                                         to include pro-forma financial information related to your disposition and any other
                                         financial information required because of a material disposition of assets outside the
                                         normal course of business. Reference is made to paragraph 11-01(a)(4) of Article 11 of
                                         Regulation S-X and Item 5(b)(1)(i) and (iv) of Part I of Form F-3.

Response: We
acknowledge the Staff’s comment and have revised the disclosure on page 20 - 26 in the F-3/A to include the pro-forma
financial information related to the disposition of our concrete business and all the subsequent events from December 31,
2019 to the filing of the F-3/A.

 ● Finally,
                                         please tell us whether you believe the change in your operations from a concrete business
                                         to an education service business represents a fundamental change, and if so, whether
                                         you believe your filing includes adequate information, including financial information,
                                         for a reader to understand the impact of that change.

Response:
We acknowledge the Staff’s comment and respectfully inform the Staff that we believe the change in our operations from
a concrete business to a performance support and music education business represents a fundamental change. We have revised
the disclosure on page 20 - 26 in the F-3/A to include the pro-forma financial information related to the disposition of our
concrete business and all the subsequent events from December 31, 2019 to the filing of the F-3/A.

 2. We
                                         note your response to comment two did not address your impending acquisition of Color
                                         China Entertainment Limited. Please clarify how you have evaluated the guidance in Rule
                                         3-05 and Article 11 of Regulation S-X in determining the need to provide separate financial
                                         statements and pro-forma financial information related to the Color China impending acquisition.
                                         Your response should discuss how your predecessor business factored into your significance
                                         assessment and the basis for your conclusions.

Response:
We acknowledge the Staff’s comment and respectfully inform the Staff that our evaluation of the guidance in Rule
3-05 and Article 11 of Regulation S-X in determining the need to provide separate financial statements and pro-forma financial
information related to our acquisition of Color China Entertainment Co., Ltd. (“Color China”) on June 3, 2020 is as
follows:

We
re-visited the guidance in Rule 3-05 and Article 11 of Regulation S-X and interpreted that the significant test shall still be
measured with our June 30, 2019 financial statements without the consideration of the disposition of our concrete business. As
a result, we completed our review of the assessment of significance of Color China using the three testing criteria: 1) asset
test, 2) investment test and 3) income test, and compared Color China’s June 30, 2019 financial statements to our June 30,
2019 financial statements. We concluded that none of the three testing criteria conditions exceeded 20 percent. Consequently,
we determined that the acquisition of Color China is not deemed to be significant and the separate financial statements and pro-forma
financial information in connection with the acquisition of Color China are not required. In addition, there were no historical
financial information of Color China as Color China has no historical operations other than holding a significant collection of
music performance specific equipment for legal title purpose, which we acquired on June 3, 2020 to begin our performance support
and music education business.

    2

In
responding to the Staff’s comments, the Company acknowledges that:

 ● the
                                         Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 ● Staff
                                         comments do not foreclose the Commission from taking any action with respect to the filing;
                                         and

 ● the
                                         Company may not assert Staff comments as a defense in any proceeding initiated by the
                                         Commission or any person under the federal securities laws of the United States.

We
appreciate the assistance the Staff has provided with its comments. If you have further questions, we respectfully ask that you
forward them by electronic mail to our counsel, Joan Wu, Esq., at jwu@htflawyers.com or by telephone at (212) 530-2208.

    Very
    truly yours,

    /s/
    Yang (Sean) Liu

    Name:
     Yang
    (Sean) Liu

    Title:
     Chief
    Executive Officer

    Color
    Star Technology Company, Limited

cc: Joan
Wu

  Hunter
Taubman Fischer & Li LLC

3

United States securities and exchange commission logo
June 17, 2020
Yang (Sean) Liu
Chief Executive Officer
Color Star Technology Company, Limited
800 3rd Avenue, Suite 2800
New York, New York 10022
Re:Color Star Technology Company, Limited
Form F-3
Response Dated June 9, 2020
File No. 333-238510
Dear Mr. Liu:
            We have reviewed your June 9, 2020 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our June 3, 2020 letter.
FORM F-3 FILED ON MAY 19, 2020
Our Business
History and Development of the Company, page 3
1.We have considered your response to comment one and note your conclusion that held for
sale criteria was not met until March 2020.   Please address the following with respect to
your response:
•Given the footnote disclosures in your interim financial statements outlining your
decision to dispose of your concrete business as early as November 2019 and the
eventual disposition through sale to existing shareholders, it remains unclear why
held for sale criteria was not met prior to March 2020.   Please tell us how you
considered the guidance in Section 855-10-25 of the Accounting Standards

 FirstName LastNameYang (Sean) Liu
 Comapany NameColor Star Technology Company, Limited
 June 17, 2020 Page 2
 FirstName LastName
Yang (Sean) Liu
Color Star Technology Company, Limited
June 17, 2020
Page 2
Codification in determining that the details related to your disposition represented a
non-recognized versus recognized subsequent event.    Your response should outline
all facts and circumstances considered that support your conclusion.
•Please tell us whether you believe the disposition of your concrete business is a
material change in your business affairs.   In your response, please clarify how you
assessed the need to include pro-forma financial information related to your
disposition and any other financial information required because of a material
disposition of assets outside the normal course of business.   Reference is made to
paragraph 11-01(a)(4) of Article 11 of Regulation S-X and Item 5(b)(1)(i) and (iv) of
Part I of Form F-3.
•Finally, please tell us whether you believe the change in your operations from a
concrete business to an education service business represents a fundamental change,
and if so, whether you believe your filing includes adequate information, including
financial information, for a reader to understand the impact of that change.
2.We note your response to comment two did not address your impending acquisition of
Color China Entertainment Limited.    Please clarify how you have evaluated the guidance
in Rule 3-05 and Article 11 of Regulation S-X in determining the need to provide separate
financial statements and pro-forma financial information related to the Color China
impending acquisition.    Your response should discuss how your predecessor business
factored into your significance assessment and the basis for your conclusions.
            You may contact Wilson Lee at (202) 551 - 3468 or Robert Telewicz at (202) 551 -
3438 if you have questions regarding comments on the financial statements and related
matters.  Please contact Ruairi Regan at (202) 551 - 3269 or Pam Howell at (202) 551 -
3357 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Joan Wu, Esq.

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Color Star Technology Company, Limited

800 3rd Ave, Suite 2800

New York, NY 10022

June 9, 2020

Attn: Wilson Lee, Robert Telewicz, Ruairi Regan, Pam Howell

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

Washington, D.C. 20549

 Re: Color Star Technology Company, Limited

Registration Statement on Form F-3

Filed May 19, 2020

File No. 333-239510

Dear Mr. Lee, Mr. Telewicz, Mr. Regan, and Mr. Howell:

Color Star Technology Company,
Limited (the “Company,” “we”, or “our”), an exempt company formed under
the laws of Cayman Islands, hereby transmits its response to the letter received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”), dated June 3, 2020 regarding our Registration
Statement on Form F-3 previously filed on May 19, 2020. For ease of reference, we have repeated the Commission’s comments
in this response and numbered them accordingly.

1. We note that on May
6, 2020, the Company completed the disposition of its former concrete business for proceeds of $600,000. Please tell us how you
considered the guidance in ASC Topic 205-20 in determining that the business should not be classified as discontinued operations
in your interim financial statements for the period ended December 31, 2019. In addition, given your disposition and incorporation
by reference of annual audited financial statements issued prior to such disposition, please clarify how you assessed the need
to reissue your audited financial statements to report the results of your disposition in discontinued operations. Reference is
made to Part I Item 5(b) of the instructions to Form F-3 and question 126.40 of the Compliance and Disclosure Interpretations related
to Securities Act Forms.

Response: We acknowledge
the Staff’s comment and respectfully inform the Staff of our consideration as set forth below in ASC Topic 205-20 in determining
that the business should not be classified as discontinued operations in our interim financial statements for the period ended
December 31, 2019.

In accordance with ASC
205-20-45-1B, A disposal of a component of an entity or a group of components of an entity shall be reported in discontinued
operations if the disposal represents a strategic shift that has (or will have) a major effect on an entity’s operations
and financial results when any of the following occurs:

 a. The component of an entity or group of components of an entity meets the criteria in paragraph
205-20-45-1E
to be classified as held for sale.

 b. The component of an entity or group of components of an entity is disposed of by sale.

 c. The component of an entity or group of components of an entity is disposed of other than by
sale in accordance with paragraph 360-10-45-15
(for example, by abandonment or in a distribution to owners in a spinoff).

    1

In accordance with ASC
205-20-45-1E, A component of an entity or a group of components of an entity, or a business or nonprofit activity (the entity
to be sold), shall be classified as held for sale in the period in which all of the following criteria are met:

 a. Management, having the authority to approve the action, commits to a plan to sell the entity
to be sold.

 b. The entity to be sold is available for immediate sale in its present condition subject only
to terms that are usual and customary for sales of such entities to be sold. (See Examples 5 through 7 [paragraphs 360-10-55-37
through 55-42], which illustrate when that criterion would be met.)

 c. An active program to locate a buyer or buyers and other actions required to complete the plan
to sell the entity to be sold have been initiated.

 d. The sale of the entity to be sold is probable,
and transfer of the entity to be sold is expected to qualify for recognition as a completed sale, within one year, except as permitted
by paragraph 205-20-45-1G.
(See Example 8 [paragraph 360-10-55-43],
which illustrates when that criterion would be met.)

 e. The entity to be sold is being actively marketed for sale at a price that is reasonable in relation
to its current fair value. The price at which an entity to be sold is being marketed is indicative of whether the entity currently
has the intent and ability to sell the entity to be sold. A market price that is reasonable in relation to fair value indicates
that the entity to be sold is available for immediate sale, whereas a market price in excess of fair value indicates that the entity
to be sold is not available for immediate sale.

 f. Actions required to complete the plan indicate that it is unlikely that significant changes
to the plan will be made or that the plan will be withdrawn.

In accordance with ASC
205-20-45-3, The statement in which net income of a business entity is reported or the statement of activities of a not-for-profit
entity (NFP) for current and prior periods shall report the results of operations of the discontinued operation, including any
gain or loss recognized in accordance with paragraph 205-20-45-3C,
in the period in which a discontinued operation either has been disposed of or is classified as held for sale.

We have evaluated our discontinued
operation presentation in our interim financial statements for the period ended December 31, 2019 in accordance with ASC 205-20-45-1B,
1E and 3 for our concrete business. We determined that we did not meet all of the criteria in accordance with ASC205-20-45-1E until
the beginning of March 2020. However, we did not begin to dispose our concrete business until March 11, 2020 when we entered into
a letter of intent for the disposition and officially closed the transaction on May 6, 2020. These dates are all subsequent to
our interim financial statements period dated as of December 31, 2019. As a result, we concluded that we are not required to classify
our concrete business as discontinued operations in our interim financial statements for the period ended December 31, 2019 but
in our annual financial statements for the period ended June 30, 2020. We are also required to retroactively reclassify the June
30, 2019 financial operations of our concrete business as discontinued operation in our June 30, 2020 annual financial statements
to be incorporated in our June 30, 2020 Form 20-F.

We also acknowledge the
Staff’s comment and respectfully inform the Staff that we re-visited Part I Item 11(b) of instruction of Form F-3 and question
126.40 of the Compliance and Disclosure and determined that we are not required to reissue our audited June 30, 2019 financial
statements in accordance with ASC 205-20 as our concrete business did not meet all the criteria as held for sale until the beginning
of March 2020, and the disposal date is in May 2020, which is subsequent to June 30, 2019. In accordance with Part I Item 11(b)(ii)
of instruction of Form F-3, financial statements are only required to be restated if there has been a change in accounting principles
or a correction in an error where such change or correction requires a material retroactive restatement of financial statements.

2. Please
clarify how you have evaluated the guidance in Rule 3-05 and Article 11 of Regulation S-X in determining the need to provide separate
financial statements and pro-forma financial information related to your acquisitions. Your response should discuss how the disposition
of your predecessor business factored into your significance assessment and the basis for your conclusions.

Response: We acknowledge
the Staff’s comment and respectfully inform the Staff that our evaluation of the guidance in Rule 3-05 and Article 11 of
Regulation S-X in determining the need to provide separate financial statements and pro-forma financial information related to
our acquisition of Sunway Kids International Education Group Ltd. (“Sunway Kids”) on February 14, 2020 is as
follows:

    2

In accordance with Regulation
S-X Rule 3-05 (b)(2), In all cases not specified in paragraph (b)(1) of this section, financial statements of the business acquired
or to be acquired shall be filed for the periods specified in this paragraph (b)(2) or such shorter period as the business has
been in existence. The periods for which such financial statements are to be filed shall be determined using the conditions specified
in the definition of significant subsidiary in Rule 1-02(w) as follows:

 (i) If none of the conditions exceeds 20 percent, financial statements are not required. However,
if the aggregate impact of the individually insignificant businesses acquired since the date of the most recent audited balance
sheet filed for the registrant exceeds 50%, financial statements covering at least the substantial majority of the businesses acquired
shall be furnished. Such financial statements shall be for at least the most recent fiscal year and any interim periods specified
in Rules 3-01 and 3-02.

We completed our review
of the assessment of significance of an acquired business using the three testing criteria: 1) asset test, 2) investment test,
and 3) income test by comparing Sunway Kids’ June 30, 2019 financial statements to our June 30, 2019 financial statements
and concluded that none of the three testing criteria conditions exceeded 20 percent. As a result, we determined that the acquisition
of Sunway Kids is not deemed to be significant and the separate financial statements and pro-forma financial information in connection
with the acquisition of Sunway Kids are not required.

We also acknowledge the
Staff’s comment and respectfully inform the Staff that we did not factor the disposition of our concrete business into our
significance assessment as the plan to dispose of our concrete business was only made in March 2020, and we did not officially
complete the disposition until May 2020. These dates are subsequent to our acquisition of Sunway Kids and thus we were unable to
factor in the disposition of our concrete business into our significance assessment when we acquired Sunway Kids.

In responding to the Staff’s
comments, the Company acknowledges that:

 ● the Company is responsible for the adequacy
and accuracy of the disclosure in the filing;

 ● Staff comments do not foreclose the Commission
from taking any action with respect to the filing; and

 ● the Company may not assert Staff comments
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate the assistance
the Staff has provided with its comments. If you have further questions, we respectfully ask that you forward them by electronic
mail to our counsel, Joan Wu, Esq., at jwu@htflawyers.com or by telephone at (212) 530-2208.

    Very truly yours,

    /s/ Yang (Sean) Liu

    Name:
     Yang (Sean) Liu

    Title:
     Chief Executive Officer

    Color Star Technology Company, Limited

 cc: Joan Wu

Hunter Taubman Fischer & Li LLC

3

United States securities and exchange commission logo
June 3, 2020
Yang (Sean) Liu
Chief Executive Officer
Color Star Technology Company, Limited
800 3rd Avenue, Suite 2800
New York, New York 10022
Re:Color Star Technology Company, Limited
Registration Statement on Form F-3
Filed May 19, 2020
File No. 333-238510
Dear Mr. Liu:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
FORM F-3 FILED ON MAY 19, 2020
Our Business
History and Development of the Company, page 3
1.We note that on May 6, 2020, the Company completed the disposition of its former
concrete business for proceeds of $600,000.   Please tell us how you considered the
guidance in ASC Topic 205-20 in determining that the business should not be classified as
discontinued operations in your interim financial statements for the period ended
December 31, 2019.  In addition, given your disposition and incorporation by reference of
annual audited financial statements issued prior to such disposition, please clarify how
you assessed the need to reissue your audited financial statements to report the results of
your disposition in discontinued operations.  Reference is made to Part I Item 5(b) of the
instructions to Form F-3 and question 126.40 of the Compliance and Disclosure

 FirstName LastNameYang (Sean) Liu
 Comapany NameColor Star Technology Company, Limited
 June 3, 2020 Page 2
 FirstName LastName
Yang (Sean) Liu
Color Star Technology Company, Limited
June 3, 2020
Page 2
Interpretations related to Securities Act Forms.
2.Please clarify how you have evaluated the guidance in Rule 3-05 and Article 11 of
Regulation S-X in determining the need to provide separate financial statements and pro-
forma financial information related to your acquisitions.    Your response should discuss
how the disposition of your predecessor business factored into your significance
assessment and the basis for your conclusions.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Wilson Lee at (202) 551 - 3468 or Robert Telewicz at (202) 551 -
3438 if you have questions regarding comments on the financial statements and related matters.
Please contact Ruairi Regan at (202) 551 - 3269 or Pam Howell at (202) 551 - 3357 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

CORRESP
1
filename1.htm

Huitao Technology Co., Ltd.

North West Fourth Ring Road

Yingu Mansion Suite 1708

Haidian District Beijing,

People’s Republic of China 100190

+86 10 82525361

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Ronald Alper

Special Counsel

Office of Real Estate & Construction

March 6, 2020

    Re:
    Huitao Technology Co., Ltd.

    Registration Statement on Form F-3

    Originally Filed February 25, 2020, as amended

    File No. 333-236616

Dear Mr. Alper:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Huitao Technology Co., Ltd. (the “Registrant”) hereby requests acceleration
of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EST on March 10,
2020, or as soon as thereafter practicable.

Please note that we acknowledge the following:

    •
    should the Securities and Exchange Commission (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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •
    the Registrant may not assert staff comments
and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

    Sincerely,

    By:
    /s/ Yang (Sean) Liu

    Name: Yang (Sean) Liu

    Title: Chief Executive Officer

    Huitao Technology Co., Ltd.

cc:     	Hunter
Taubman Fischer & Li LLC

March 4, 2020
Yang (Sean) Liu
Chief Executive Officer
Huitao Technology Co., Ltd.
9 North West Fourth Ring Road
Yingu Mansion Suite 1708, Haidian District
Beijing, People’s Republic of China 100190
Re:Huitao Technology Co., Ltd.
Registration Statement on Form F-3
Filed February 25, 2020
File No. 333-236616
Dear Mr. Liu:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Ronald (Ron) Alper at 202-551-3329 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Joan Wu

CORRESP
1
filename1.htm

China Advanced Construction Materials Group,
Inc.

North
West Fourth Ring Road

Yingu
Mansion Suite 1708

Haidian
District Beijing,

People’s
Republic of China 100190

+86
10 82525361

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
DC 20549

Attn:
Asia Timmons-Pierce

Special
Counsel

Office
of Manufacturing and Construction

September
24, 2018

    Re:
    China
    Advanced Construction Materials Group, Inc./Cayman

    Registration
    Statement on Form F-4

    Originally
    Filed July 24, 2018, as amended

    File No.
    333-226308

Dear
Ms. Timmons-Pierce:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, China Advanced Construction Materials Group, Inc. (the “Registrant”)
hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective
at 9:00 a.m. EST on September 26, 2018, or as soon as thereafter practicable.

Please
note that we acknowledge the following:

    ●
    should
    the Securities and Exchange Commission (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 Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
    the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    By:
    /s/
    Xianfu     Han

    Name:
    Xianfu Han

    Title:
    Chief Executive
    Officer

    China
    Advanced Construction Materials Group, Inc.

    cc:
    Joan Wu, Esq.

CORRESP
1
filename1.htm

China Advanced Construction Materials
Group, Inc.

North West Fourth Ring Road

Yingu Mansion Suite 1708

Haidian District Beijing,

People’s Republic of China 100190

+86 10 82525361

August 31, 2018

VIA EMAIL AND MAIL

Asia Timmons-Pierce

Special Counsel

Office of Manufacturing and Construction

    Re:
    China Advanced Construction Materials Group, Inc./Cayman

    Registration Statement on Form F-4

    Filed July 24, 2018

    File No. 333-226308

Dear Ms. Timmons-Pierce:

This letter is in response to the letter
dated August 20, 2018 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to China Advanced Construction Materials Group, Inc. (the “Company”, “we” or “our”),
an exempt company formed under the laws of Cayman Islands. For ease of reference, we have repeated the Commission’s comments
in this response and numbered them accordingly. An amended Registration Statement on Form F-4/A submitted accompanying this Response
Letter is referred to as Amendment No.1.

Director Compensation, page 26

 1. Provide the information specified in paragraph (r)(2) of Item 402 of Regulation S-K concerning the compensation of the directors for your last completed fiscal year, that is, 2018. See Item 11 of Schedule 14A.

Response: In response to the Staff’s
comments, the Company included the directors’ compensation information for the fiscal year ended June 30, 2018 on page 26
of Amendment No. 1.

Summary Executive Compensation Table,
page 27

2. Provide the information specified in
paragraph (n)(2) of Item 402 of Regulation S-K concerning the compensation of the named executive officers for your last two completed
fiscal years, that is, 2018 and 2017. See Item 11 of Schedule 14A.

Response: In response to the Staff’s
comments, we included the named executive officers’ compensation information for the fiscal years ended June 30, 2018 and
2017 on page 27 of Amendment No. 1.

Transactions with Related Party, page
30

3. Please disclose the material terms of
your agreement with Beijing Lianlv Technical Group Ltd. and file the agreement as an exhibit to your registration statement. See
Item 601(b)(10) of Regulation S-K.

Response: In response to the Staff’s
comment, we included the material terms of your agreement with Beijing Lianlv Technical Group Ltd on page 30 of Amendment No. 1
and included the unofficial English translation of the agreement as an exhibit.

Where You Can Find Additional Information,
page 53

4. Under a separate caption, incorporate
by reference your latest annual report on Form 10-K and the other reports specified by Item 11(a)(2) of Form F-4. Additionally,
provide the disclosure specified by Item 11(b) of Form F-4.

Response: In response to the Staff’s
comments, we incorporated by reference our annual report on Form 10-K for the fiscal year ended June 30, 20017 and included additional
disclosure specified by Item 11(b) of Form F-4 on page 53 of Amendment No. 1.

Signatures, page II-3

5. The registration statement must be
signed also by your principal accounting officer or controller. Further, any person who occupies more than one of the specified
offices, for example, principal financial officer and principal accounting officer or controller, must indicate each capacity
in which he signs the registration statement. See Instructions 1 and 2 for signatures on Form F-4, and revise.

Response: In response to the Staff’s
comments, the Company has revised the signature page accordingly.

General

6. To the extent that our comments on the
Form F-4 are applicable to the preliminary proxy statement, please make conforming changes.

Response:
The Company has made  corresponding changes to the preliminary proxy statement.

In responding to your comments, the Company
acknowledges that:

    ●
    the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

    ●
    Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

    ●
    the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate the assistance the Staff
has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. of Hunter
Taubman Fischer & Li LLC, at (212) 732-7184.

    Sincerely,

    By:
    /s/
    Xianfu Han

    Chief Executive Officer

    China Advanced Construction Materials Group, Inc.

 cc: Joan Wu, Esq.

August 20, 2018
Xianfu Han
Chief Executive Officer
China Advanced Construction Materials Group, Inc./Cayman
9 North West Fourth Ring Road
Yingu Mansion Suite 1708
Haidian District Beijing
People’s Republic of China
Re:China Advanced Construction Materials Group, Inc./Cayman
Registration Statement on Form
Filed July 24, 2018
File No. 333-226308
Dear Mr. Han:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-4 filed July 24, 2018
Director Compensation, page 26
1.Provide the information specified in paragraph (r)(2) of Item 402 of Regulation S-K
concerning the compensation of the directors for your last completed fiscal year, that
is, 2018.  See Item 11 of Schedule 14A.
Summary Executive Compensation Table, page 27
2.Provide the information specified in paragraph (n)(2) of Item 402 of Regulation S-K

 FirstName LastNameXianfu  Han
 Comapany NameChina Advanced Construction Materials Group, Inc./Cayman
 August 20, 2018 Page 2
 FirstName LastNameXianfu  Han
China Advanced Construction Materials Group, Inc./Cayman
August 20, 2018
Page 2
concerning the compensation of the named executive officers for your last two completed
fiscal years, that is, 2018 and 2017.  See Item 11 of Schedule 14A.
Transactions with Related Party, page 30
3.Please disclose the material terms of your agreement with  Beijing Lianlv Technical
Group Ltd. and file the agreement as an exhibit to your registration statement.  See Item
601(b)(10) of Regulation S-K.
Where You Can Find Additional Information, page 53
4.Under a separate caption, incorporate by reference your latest annual report on Form 10-K
and the other reports specified by Item 11(a)(2) of Form F-4.  Additionally, provide the
disclosure specified by Item 11(b) of Form F-4.
Signatures, page II-3
5.The registration statement must be signed also by your principal accounting officer or
controller.  Further, any person who occupies more than one of the specified offices, for
example, principal financial officer and principal accounting officer or controller, must
indicate each capacity in which he signs the registration statement.   See Instructions 1 and
2 for signatures on Form F-4, and revise.
General
6.To the extent that our comments on the Form F-4 are applicable to the preliminary proxy
statement, please make conforming changes.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Kevin Stertzel (Staff Accountant) at (202)-551-3723 or John
Cash (Accounting Branch Chief) at (202)-551-3768 if you have questions regarding comments
on the financial statements and related matters.  Please contact Edward Kelly (Staff Attorney) at
202-551-3728 or Asia Timmons-Pierce (Special Counsel) at (202)-551-3754 with any other
questions.
Sincerely,

 FirstName LastNameXianfu  Han
 Comapany NameChina Advanced Construction Materials Group, Inc./Cayman
 August 20, 2018 Page 3
 FirstName LastName
Xianfu  Han
China Advanced Construction Materials Group, Inc./Cayman
August 20, 2018
Page 3
Division of Corporation Finance
Office of Manufacturing and
Construction