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United States securities and exchange commission logo





                            October 26, 2023

       Suqin Li
       Chief Executive Officer
       Majestic Ideal Holdings Ltd
       22/F, China United Plaza
       1002-1008, Tai Nan West Street
       Cheung Sha Wan, Kowloon, Hong Kong

                                                        Re: Majestic Ideal
Holdings Ltd
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            Filed October 20,
2023
                                                            File No. 333-271502

       Dear Suqin Li:

            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 October 13, 2023
letter.

       Amendment No. 3 to Registration Statement on Form F-1 filed October 20,
2023

       General

   1.                                                   We note your response
to prior comment 1 and we reissue the comment. Please amend to
                                                        provide the information
summarized and requested in the prior comment.

       Dilution, page 44

   2.                                                   Your revised
disclosures in response to prior comment 2 indicate that your intangible
                                                        assets include deferred
IPO costs, right-of-use assets and deferred tax assets and are
                                                        therefore excluded from
net tangible book value. It appears as though your net tangible
                                                        book value as currently
presented does not exclude your right-of-use assets of RMB
                                                        712,011. Please revise.
 Suqin Li
Majestic Ideal Holdings Ltd
October 26, 2023
Page 2
3.    In a related matter, your current presentation lists your net tangible
book value in USD
      with the $, however, your calculated value is actually from your March
31, 2023 balance
      sheet in RMB. In addition, your net tangible book value per share is
presented according
      to the USD figures. Please revise to present your net tangible book value
in U.S. Dollars
      to align with your net tangible book value per share.
Compensation of Directors and Executive Officers, page 93

4.    Please update the disclosure in this section to include compensation
information for the
      most recently completed fiscal year.
Financial Statements, page F-1

5.    We note this registration statement is your initial public offering. In
this regard, your
      audited financial statements must be no more than 12 months old at the
time of filing and
      upon the effectiveness of the registration statement unless you are able
to represent the
      you are not required to comply with the 12 month requirement in any other
jurisdiction
      outside the United States and that complying with the 12 month
requirement is
      impracticable or involves undue hardship in which case the last year of
audited financial
      statements may not be older than 15 months at the time of offering. If
applicable, your
      representation should be filed as an exhibit to the registration
statements. Refer to the
      Instructions to Item 8.A.4 of Form 20-F.
       Please contact Heather Clark at 202-551-3624 or Kevin Woody at
202-551-3629 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any
other questions.



                                                            Sincerely,
FirstName LastNameSuqin Li
                                                            Division of
Corporation Finance
Comapany NameMajestic Ideal Holdings Ltd
                                                            Office of
Manufacturing
October 26, 2023 Page 2
cc:       Lawrence S. Venick, Esq.
FirstName LastName
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