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United States securities and exchange commission logo





                             July 20, 2020

       Bong Lau
       Chief Executive Officer
       Intelligent Living Application Group Inc.
       Unit 2, 5/F, Block A, Profit Industrial Building
       1-15 Kwai Fung Street, Kwai Chung
       New Territories, Hong Kong

                                                        Re: Intelligent Living
Application Group Inc.
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted June 23,
2020
                                                            CIK No. 1814963

       Dear Mr. Lau:

              We have reviewed your draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Confidential Draft Registration Statement on Form F-1

       Selected Consolidated Financial and Operating Data, page 54

   1.                                                   Refer to the first
sentence of the introductory paragraph. Revise to omit the reference to
                                                        providing selected
consolidated statements of cash flows data, or provide such cash flows
                                                        data in a table similar
to that provided on page 13 under Summary Consolidated Financial
                                                        and Operating Data.
 Bong Lau
FirstName   LastNameBong    LauGroup Inc.
Intelligent Living Application
Comapany
July        NameIntelligent Living Application Group Inc.
     20, 2020
July 20,
Page  2 2020 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 61

2.       Refer to the last sentence in the first paragraph on page 61, where a
shareholder and
         director forgave a related party loan of $1,173,849 as contribution of
capital to the
         company in 2019. Please reconcile this disclosure with that on page
57, under the
         Overview section, that you were able to reduce your bank borrowings
and related interest
         costs with a shareholder contribution of approximately $1.2 million in
2019. In this
         regard, the statements of shareholders' equity does provide for this
amount as a
         shareholder contribution; however, the financing activities section of
the statements of
         cash flows reflects such amount as cash proceeds from the shareholder
rather than as a
         supplemental non-cash financing activity of related party debt
forgiveness in exchange
         for equity. Please revise the narrative disclosures and financial
statements accordingly to
         clarify the form of shareholder contribution received and how it was
applied (i.e., cash
         proceeds received and used to reduce bank borrowings or related party
loan forgiveness in
         exchange for non-cash equity contribution). Reference is also made to
disclosure in the
         last paragraph under Related Party Transactions on page 102, which
appears to imply the
         loan was forgiven without the payment of a cash contribution and also
to Note 8, Related
         Party Balances and Transactions on page F-17.

Our Business, page 73

3.       Please revise your business section to provide a discussion of the
sources and availability
         of raw materials used in your operations. Please refer to Item 4.B.4
of Form 20-F.
4.       We note your disclosure that you intend to launch smart lock and smart
security products
         to meet increasing consumer demands. We further note that you are
currently in the
         research phase of your smart locks and smart security products, and
that you plan to use
         part of the proceeds from this offerings for research and development
purposes of smart
         locks, smart security, and internet of things products. Please revise
this section to
         elaborate on some of the challenges that you may face in the smart
locks and smart
         security industry. In addition, please consider revising your
prospectus accordingly, for
         example, but not limited to, including appropriate risk factor
disclosure.
Report of Independent Registered Public Accounting Firm, page F-2

5.       We note the auditors' report does not indicate a going concern opinion
was issued that
         raises substantial doubt about the Company's ability to continue as a
going concern. As
         appropriate and to be consistent with disclosures in the Risk Factor
on page 15 and Note 2
         on page F-8 that there are matters that raise substantial doubt about
your ability to
         continue as a going concern, please have your auditors revise their
auditors' opinion
         accordingly or supplementally explain why revision is not necessary
based on your
         current disclosures.
 Bong Lau
Intelligent Living Application Group Inc.
July 20, 2020
Page 3


       You may contact Beverly Singleton, Staff Accountant, at (202) 551-3328
or Melissa
Raminpour, Accounting Branch Chief, at (202) 551-3379 if you have questions
regarding
comments on the financial statements and related matters. Please contact Sergio
Chinos, Staff
Attorney, at (202) 551-7844 or Asia Timmons-Pierce, Special Counsel, at (202)
551-3754 with
any other questions.



                                                          Sincerely,
FirstName LastNameBong Lau
                                                       Division of Corporation
Finance
Comapany NameIntelligent Living Application Group Inc.
                                                       Office of Manufacturing
July 20, 2020 Page 3
cc:       Jeffrey Li
FirstName LastName
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