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                             July 12, 2021

       Joseph C. Passalaqua
       Chief Executive Officer
       Nine Alliance Science & Technology Group
       7325 Oswego Road
       Liverpool, NY 13090

                                                        Re: Nine Alliance
Science & Technology Group
                                                            Form 10-12G
                                                            Filed June 16, 2021
                                                            File No. 000-56293

       Dear Mr. Passalaqua:

              We have reviewed your filing 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 these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response and any amendment you may file in
response to these
       comments, we may have additional comments.

       Registration Statement on Form 10-12G

       General

   1.                                                   Please note that this
registration statement on Form 10 becomes effective automatically 60
                                                        days after its initial
filing pursuant to Section 12(g)(1) of the Exchange Act of 1934. You
                                                        will then be subject to
the reporting requirements of the Exchange Act, including the
                                                        requirements to file
Forms 10-K, 10-Q, and 8-K, even if comments remain open on the
                                                        Form 10. If you do not
wish to become subject to these reporting requirements before
                                                        completion of our
review, you may wish to consider withdrawing the Form 10 before
                                                        it becomes effective
automatically and submitting a new Form 10 that includes changes
                                                        responsive to our
comments.
 Joseph C. Passalaqua
FirstName  LastNameJoseph  C. Passalaqua
Nine Alliance Science & Technology  Group
Comapany
July       NameNine Alliance Science & Technology Group
     12, 2021
July 12,
Page  2 2021 Page 2
FirstName LastName
Item 1
Business, page 1

2.       Please revise your disclosure to describe your corporate history and
to distinguish clearly
         between previous and current business operations, including the
following:

                Indicate, if true, you no longer have operations relating to
the ladies' handbag
              business;
                Include discussion of the dormancy period and custodianship
proceeding mentioned
              in Note 1 of the financial statements;
                Describe your current operations and/or include a
cross-reference to the discussion on
              page 8; and

                Reconcile the apparent inconsistency between statements such as
"we have . . .
              limited business operations" (page 1) and "we are not currently
engaged in any
              business operations" (page 2), and among descriptions of your
plans to acquire an
              interest in eligible companies (page 1), effect an acquisition or
merger with an
              operating company (page 5), or consummate a reverse merger or
other business
              combination (pages 7-8).
3.       You appear to be a shell company as that term is defined in Securities
Act Rule 405 of
         Regulation C. In this regard, we note that you have nominal operations
and nominal
         assets to date. Please revise your cover page to disclose that you are
a shell company and
         add a risk factor that highlights the consequences of shell company
status or otherwise
         provide us with a detailed legal analysis explaining why you are not a
shell company.
4.       We note the statement, "We intend to use the net proceeds from the
initial offering to
         develop our business operations." Please delete or advise how this is
relevant to the
         current filing.
5.       Please tell why you filed Form 15 on June 2, 2021. We note the absence
of reporting
         between the NT 10-K filed December 29, 2017, and the Form 8-K filed
June 1, 2021.
         Provide your analysis as to whether the Company's reporting
requirements under
         Securities Act Section 15(d) were automatically suspended or
voluntarily suspended; if
         the latter, tell us how the Company meets the eligibility requirements
of Exchange Act
         Rule 12h-3(a). Refer to Exchange Act Forms Question 108.01 of the
Division's
         Compliance and Disclosure Interpretations on our website.
Item 4
Security Ownership of Certain Beneficial Owners and Management, page 9

6.       Please provide the address of all 5% shareholders, as required by Item
403 of Regulation
         S-K.
 Joseph C. Passalaqua
FirstName  LastNameJoseph  C. Passalaqua
Nine Alliance Science & Technology  Group
Comapany
July       NameNine Alliance Science & Technology Group
     12, 2021
July 12,
Page  3 2021 Page 3
FirstName LastName
Item 5
Directors and Executive Officers, page 9

7.       Please expand Mr. Passalaqua's biographical information to include his
business
         experience during the past five years. Please refer to Item 401(e) of
Regulation S-K.
Item 9
Market Price of, and Dividends on, the Registrant's Common Equity and Related
Stockholder
Matters, page 11

8.       Please furnish a statement to the effect that there is no established
public trading market
         for your shares. In addition, please disclose the range of high and
low bid information for
         each full quarterly period within the two most recent fiscal years and
any subsequent
         interim period for which financial statements are included. Please
refer to Item
         201(a)(1)(iii) of Regulation S-K. Please revise to state that
presently the OTC Pink Sheets
         have placed a "limited information warning" on your company because
you are not
         making material information public. Please explain the nature,
significance and basis for
         this warning.
9.       We note your statement here that you are a shell company, please
revise to disclose the
         requirements that must be met under Rule 144(i) for your security
holders to be able to
         rely on Rule 144 for the resale of restricted and/or control
securities, and the effect these
         restrictions may have on the liquidity of a holder's shares.
Item 10
Recent Sales of Unregistered Securities, page 12

10.      Please revise this section to cover the past three years, as required
by Item 701 of
         Regulation S-K. Please indicate the section of the Securities Act or
the rule of the
         Commission under which exemption from registration was claimed for the
sale of shares
         to Joseph C. Passalaqua.
Item 11
Description of Registrant's Securities to be Registered, page 12

11.      The par value of your common stock is stated as $0.0001 per share.
Please reconcile this
         with disclosure found on the cover page of Form 10, which states the
par value as $0.001
         per share.
12.      Please disclose that your sole director and executive officer will
control any matter put to
         a vote of your shareholders and assess the material risks of potential
conflicts of interest.
 Joseph C. Passalaqua
FirstName  LastNameJoseph  C. Passalaqua
Nine Alliance Science & Technology  Group
Comapany
July       NameNine Alliance Science & Technology Group
     12, 2021
July 12,
Page  4 2021 Page 4
FirstName LastName
Item 15
Financial Statements and Exhibits, page 14

13.      Please refile your exhibits in the proper text-searchable format.
Please refer to Section
         5.2.3.6 of the EDGAR Filer Manual (Volume II) EDGAR Filing (Version
58) (June 2021)
         and Item 301 of Regulation S-T.
Financial Statements
General, page 15

14.      We note that in February 2021 you changed the par value of your common
stock from
         $0.001 to $0.0001. Please revise your balance sheets and statements of
stockholders
         equity to give retroactive effect to this change in your capital
structure. Additionally,
         please provide a footnote to your financial statements to disclose the
retroactive treatment,
         the reason for the change in par value, and the date the change became
effective. Please
         refer to SAB Topic 4C.
Note 7 - Subsequent Events, page 27

15.      Please revise your footnote to provide the disclosure required by ASC
855-10-50-1b. This
         comment also applies to Note 7 to the unaudited financial statements
on page 38.
        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 Dale Welcome at 202-551-3865 or John Cash at
202-551-3768 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Angelini at 202-551-3047 or Sergio Chinos at 202-551-7844 with
any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing
cc:      Stephen Mills
