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                                                            November 19, 2024

Son Tam
Chief Executive Officer
Epsium Enterprise Ltd
Alameda Dr. Carlos D   assumpcao
Edf China Civil Plaza 235-243, 14 Andar P
Macau, SAR China

       Re: Epsium Enterprise Ltd
           Amendment No. 5 to Registration Statement on Form F-1
           Filed November 4, 2024
           File No. 333-276313
Dear Son Tam:

     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 October 2,
2024 letter.

Amendment No. 5 to Registration Statement on Form F-1 filed November 4, 2024
Risk Factors
Risks Related to Our Business and Industry, page 15

1.     We note that your revenues for the six months ended June 30, 2024
declined 61.34%,
       attributed primarily to    depression of economic activities in local
market    and an
          overall economic downturn result[ing] in reduced demand for alcoholic
beverages in
       Macau.    We further note your risk factor disclosure that your business
   may be
       negatively affected by various economic and social disruptions,
including but not
       limited to a slowdown, recession, or inflationary pressures in the
general
       economy   These disruptions could result in reduced demand for the
Operating
       Entity   s products       Please update where appropriate if recent
inflationary pressures
 November 19, 2024
Page 2

      and economic conditions have materially impacted your operations.
Identify the types
      of inflationary pressures you are facing and how your business has been
affected, as
      well as any actions planned or taken to mitigate such pressures.
Industry Overview, page 66

2.    Please update the description of the state of your industry for
consistency with the
      results of operations disclosure that there has been a    noticeable
decrease in the
      demand for alcoholic beverages in Macau    and that a recent    overall
economic
      downtown    has caused    a serious contraction of the wholesale market
for low-priced
      alcoholic beverages." In this regard, we note that much of the disclosure
in this
      section is given as of 2022 or early 2023 and includes statements
implying that the
      market and demand for alcoholic beverages in Macau is continuing to grow
(e.g.,    As
      the economy recovers, the consumption of alcoholic beverages in Macau is
expected
      to increase       and    [t]he growth trend likely correlates to the
expansion of the middle
      and upper classes in Macau and their ability and willingness to purchase
high-end and
      craft alcoholic beverages      ).
Underwriting, page 117

3.    Provide additional information as to why your disclosure and Sections
2.27 and 3.18
      of the form of underwriting agreement filed as Exhibit 1.1 indicate that
the lock-up
      arrangements applicable to the company, directors, officers, and holders
of at least 5%
      of outstanding ordinary shares will be in favor only of EF Hutton, rather
than both
      underwriters for the offering. Explain the purpose of this distinction,
and clarify
      whether this is meant to suggest that EF Hutton will be able to
unilaterally release
      such parties from their lock-up arrangements, and if so, why this was
decided upon. In
      this regard, we note that Section 3.19 of the form of underwriting
agreement suggests
      that EF Hutton will have the sole ability to waive the lock-up period,
but the form of
      press release included within Exhibit 1.1 and description of lock-up
agreements at
      page 119 are inconsistent on this point.
       Please contact James Giugliano at 202-551-3319 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rebekah Reed at 202-551-5332 or Dietrich King at
202-551-8071
with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Laura Hua Lua Hemman, Esq.
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