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                                                           September 30, 2024

Elvis Cheung
Chief Executive Officer
707 Cayman Holdings Ltd.
5/F., AIA Financial Centre
712 Prince Edward Road East
San Po Kong, Kowloon, Hong Kong

       Re: 707 Cayman Holdings Ltd.
           Registration Statement on Form F-1
           Filed September 5, 2024
           File No. 333-281949
Dear Elvis Cheung:

     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 August 23, 2024 letter.

Form F-1 filed September 5, 2024
Implications of Being a "Controlled Company", page 6

1.     We note your disclosure here that JME will be the beneficial owner of
15,612,000
       ordinary shares or 71.13% of the issued and outstanding ordinary shares
after the
       completion of the offering. This appears to be inconsistent with the
disclosure on the
       cover page which states JME will be the beneficial owner of 30,310,000
ordinary shares
       or 73.19% and the disclosure on page 26 which states JME will be the
beneficial owner of
       20,310,000 ordinary shares or 73.19%. Please clarify or revise.
The Offering, page 9

2.     We note your disclosure here that there are 20,200,000 issued and
outstanding ordinary
       shares prior to the offering. This appears to be inconsistent with the
disclosure in the
 September 30, 2024
Page 2

       financial statements on page F-2 which states there are 999,999 ordinary
shares issued and
       outstanding. Please clarify or revise.
General

3.     Please provide us with a detailed analysis as to why the proposed
secondary offering is
       not an indirect primary offering on your behalf and thus appropriate to
characterize the
       transaction as a valid secondary offering under Securities Act Rule
415(a)(1)(i). Refer to
       and discuss in your response Securities Act Rules Compliance and
Disclosure
       Interpretation 612.09. Among other relevant issues, discuss in your
response why you are
       registering the resale offering simultaneously with the primary
offering, how you
       determined the number of ordinary shares being registered in connection
with the resale
       offering, how and when the Resale Shareholders were selected to
participate in the resale
       offering including which party(ies) initiated contact regarding the
potential resale
       transaction, why it was decided that the Resale Shareholders would not
be subject to lock-
       up arrangements and whether the underwriter sought to have them
subjected to lock-up
       arrangements, and why the availability of a set of resale shares larger
than the size of the
       primary offering for offer and sale into the market once trading
commences does not
       create concern for the underwriters' ability to facilitate the creation
of a public market.

       Also disclose the exemption pursuant to which the Resale Shareholders
received their
       shares, and whether each Resale Shareholder and the person that controls
it has had any
       position, office or other material relationship with JEM within the past
three years. Also
       clarify what you mean when you say that each Resale Shareholder acquired
the shares to
       be resold "from allotment from the Company for cash."

       Finally, we note that the Resale Shareholders subscribed for shares "for
the purpose and
       preparation of the offering." Please describe in further detail the
nature of this transaction,
       when/how shares were issued, and whether such shares are included in the
Resale
       Shareholders' current holdings.
4.     We note your disclosure on page ALT-7 that the Resale Shareholders may
sell their
       securities by means of "purchases by a broker-dealer as principal and
resale by the broker-
       dealer for its account." Please confirm your understanding that the sale
by a Resale
       Shareholder by such means would constitute a material change to your
plan of distribution
       requiring a post-effective amendment. Refer to your undertaking provided
pursuant to
       Item 512(a)(1)(iii) of Regulation S-K.
 September 30, 2024
Page 3

       Please contact Amy Geddes at 202-551-3304 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any
other
questions.



                                                       Sincerely,

                                                       Division of Corporation
Finance
                                                       Office of Trade &
Services
cc:   David L. Ficksman
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