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United States securities and exchange commission logo





                               November 14, 2023

       Yee Man Thomas Law
       Chief Executive Officer
       Junee Limited
       Studio 20, 11 F, International Plaza
       20 Sheung Yuet Road
       Kowloon Bay, Kowloon, Hong Kong

                                                        Re: Junee Limited
                                                            Amendment No. 9 to
Registration Statement on Form F-1
                                                            Filed October 31,
2023
                                                            File No. 333-266116

       Dear Yee Man Thomas Law:

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

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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our September 25,
2023 letter.

       Amendment No. 9 to Registration Statement on Form F-1

       General

   1.                                                   Please refer to the
resale prospectus cover page. We note your disclosure that the closing
                                                        of the resale offering
is "conditioned upon NASDAQ   s final approval of your listing
                                                        application." Please
revise to clarify whether or not the resale offering is contingent on the
                                                        listing of your
Ordinary Shares on NASDAQ.
   2.                                                   We note your disclosure
that the resale shares may be sold concurrently with your initial
                                                        public offering and
from time to time thereafter. We also note that the selling shareholders
                                                        will sell the resale
shares at the public offering price and, following listing on NASDAQ,
                                                        at the market. Please
revise your disclosure to clearly indicate whether any resales will be
                                                        made before the shares
in the initial public offering begin trading on NASDAQ. If so,
 Yee Man Thomas Law
Junee Limited
November 14, 2023
Page 2
      please confirm that you will specify prior to effectiveness the fixed
price at which or bona
      fide price range within which the selling shareholders will sell their
shares and revise the
      resale prospectus cover page as applicable. Refer to Item 501(b)(3) of
Regulation S-K.
      Alternatively, please revise your resale prospectus cover page to remove
the reference to
      the concurrent sale of shares with the initial public offering and
clarify that the selling
      shareholders will sell their shares only once trading of your common
stock begins.
       Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Donald Field at 202-551-3680 with any
other questions.



                                                            Sincerely,
FirstName LastNameYee Man Thomas Law
                                                            Division of
Corporation Finance
Comapany NameJunee Limited
                                                            Office of Trade &
Services
November 14, 2023 Page 2
cc:       Lisa Forcht
FirstName LastName
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