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                                                            August 29, 2024

Hok C Chan
Chief Executive Officer
Toppoint Holdings Inc.
1250 Kenas Road
North Wales, PA 19454

       Re: Toppoint Holdings Inc.
           Registration Statement on Form S-1
           Filed August 12, 2024
           File No. 333-281474
Dear Hok C Chan:

       We have reviewed your 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 July 3, 2024 letter.

Registration Statement on Form S-1
Note 2: Summary of Significant Accounting Policies
Revenue Recognition, page F-8

1.     We note your response to comment two states that your transit time is
typically within a
       24 hour period. Please note that ASC 606 does not provide a practical
expedient for
       contracts with a short duration and therefore, requires an assessment of
the criteria of
       ASC 606-10-25-27 to determine whether the performance obligation is
satisfied over
       time, regardless of transit duration period. Tell us supplementally the
revenue amounts
       recognized in the financial reporting periods presented, for transit
periods within 24 hours
       and in excess of 24 hours. For transit periods in excess of 24 hours,
identify the length of
       transit time. To the extent you believe that the impacts of your current
recognition of
       revenue at a point in time is not materially different than recognition
over time, please
       provide an analysis that supports this view. Refer to SAB Topic 1:M.
2.     We note that you are adopting a policy that provides customers a right
of refund within
 August 29, 2024
Page 2

       two years beginning when transportation services are provided or monies
are received by
       you. In consideration of this supplementary information, please tell us
how you
       considered the guidance for sales with rights of return at ASC
606-10-55-22 to 55-29 in
       applying the core principles of revenue recognition outlined in ASC
606-10-05-4.
       Specifically tell us how you determined the amount of the transaction
price allocated to
       the performance obligation and the amount of consideration to which you
are entitled in
       exchange for providing transit services and how you also considered
guidance on
       constraining estimates of variable consideration and accounting for a
significant financing
       component over the two-year refund period. We refer you to ASC
606-10-32-2 to 32-27.
3.     Expand your policy disclosure to include the information about
performance obligations
       with respect to the policy for a customer   s two-year refund rights, as
applicable. See ASC
       606-10-50-12 to 50-15.
       Please contact Brian McAllister at 202-551-3341 or Shannon Buskirk at
202-551-3717 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Michael Purcell at 202-551-5351 or Kevin Dougherty at 202-551-3271 with
any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Energy &
Transportation
cc:   Louis Bevilacqua
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