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United States securities and exchange commission logo





                              March 21, 2024

       Chuanbo Jiang
       Chief Executive Officer
       STAK Inc.
       Building 11, 8th Floor, No. 6 Beitanghe East Road,
       Tianning District, Changzhou, Jiangsu,
       People   s Republic of China, 213000

                                                        Re: STAK Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted March 12,
2024
                                                            CIK No. 0002002453

       Dear Chuanbo Jiang:

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

              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 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 the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       February 16, 2024 letter.

       Draft Registration Statement Amendment No. 1 on Form F-1

       Prospectus Summary, page 1

   1.                                                   In response to prior
comment 7, you added a risk factor that the Chinese government may
                                                        intervene or influence
your operations at any time. Please highlight this in the prospectus
                                                        summary.
 Chuanbo Jiang
FirstName
STAK Inc. LastNameChuanbo Jiang
Comapany
March      NameSTAK Inc.
       21, 2024
March2 21, 2024 Page 2
Page
FirstName LastName
Business
Our Supply Chain, page 64

2.       Please refer to prior comment 11 and discuss the material terms of the
framework
         cooperation agreements that you have with your two manufacturers,
including the term of
         the agreement. We note that both agreements terminate on December 31,
2025.
Note 2 - Summary of Significant Accounting Policies , page F-8

3.       We note your response to prior comment 13. Your response indicates
that you provide "a
         manufacturer's standard warranty" to your customers on all products
sold. Disclose what
         is covered under this "manufacturer's standard warranty". Refer to ASC
606-10-55-30
         through 55-35. Please revise to disclose your policy for accounting
for product warranties
         in accordance with ASC 460-10. Refer to ASC 460-10-50-8(b) and
50-8(c).
(m) Revenue recognition , page F-10

4.       We note your expanded disclosure on page 65 in response to our prior
comment 14.
         Please expand your revenue recognition disclosure to clarify who you
have concluded is
         your customer in the sales of specialized oilfield vehicles and
specialized oilfield
         equipment. Refer to ASC 606-10-20. In this regard, we note your
disclosure on page 65,
         that, "We sell our products to customers, who then resell our products
to end-users."
         Further, we note in your risk factor disclosure on page 19, that you
promote and attract
         new customers through methods that include, "utilizing a dedicated
network of specialized
         vehicle dealers." Given these disclosures, it is unclear whether you
have concluded the
         dealers or the end-users are your customers. Please advise and
disclose accordingly. Tell
         us the nature of the two businesses that you have disclosed on page 19
that were your
         largest customers in the fiscal years ended June 30, 2023 and 2022,
respectively. If you
         have concluded the dealer is your customer, tell us how you have
considered the guidance
         in ASC 606-10-32-25. If applicable, disclose your accounting for
consideration payable to
         a customer.
5.       We have reviewed your response to the third bullet point of prior
comment 14 related to
         your service income from automation solutions. We continue to note
that you recognized
         the related revenue of the developed software or function at a point
in time upon the
         customers' acceptance of the developed software or function. Please
confirm and clarify
         your disclosures that the multiple promises that you identify, that
include software
         development, training, debugging, maintenance, and other services
occur prior to to the
         customers' acceptance of the developed software or function. Refer to
ASC 606-10-25-14
         and 19. For example, please explain the nature and delivery timing for
the software and
         equipment maintenance. Lastly, please tell us your consideration of
whether the multiple
         promises in the contract represent the combined outputs (i.e.,
developed
         software) specified by the customer. Refer to ASC 606-10-25-21(a).
 Chuanbo Jiang
FirstName
STAK Inc. LastNameChuanbo Jiang
Comapany
March      NameSTAK Inc.
       21, 2024
March3 21, 2024 Page 3
Page
FirstName LastName
       Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at
202-551-3488 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Lauren Pierce at 202-551-3887 or Jan Woo at 202-551-3453 with any other
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Technology
cc:      Lawrence S. Venick, Esq.
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