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United States securities and exchange commission logo





                            November 20, 2023

       Ye Tao
       Chief Executive Officer
       3 E Network Technology Group Ltd
       B046 of Room 801, 11 Sixing Street
       Huangge Town, Nansha District
       Guangzhou, Guangdong Province, PRC

                                                        Re: 3 E Network
Technology Group Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted November
7, 2023
                                                            CIK No. 0001993097

       Dear Ye Tao:

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

              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 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.

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

       Prospectus Summary, page 1

   1.                                                   Please refer to prior
comments 3 and 6. Highlight separately the risk that the Chinese
                                                        government may
intervene or influence your operations at any time, which could result in
                                                        a material change in
your operations and/or the value of your securities. Also, given
                                                        recent statements by
the Chinese government indicating an intent to exert more oversight
                                                        and control over
offerings that are conducted overseas and/or foreign investment in China-
                                                        based issuers,
acknowledge the risk that any such action could significantly limit or
                                                        completely hinder your
ability to offer or continue to offer securities to investors and
                                                        cause the value of such
securities to significantly decline or be worthless. We remind you
                                                        that, pursuant to
federal securities rules, the term    control    (including the terms
                                                           controlling,
controlled by,    and    under common control with   ) means    the possession,
 Ye Tao
3 E Network Technology Group Ltd
November 20, 2023
Page 2
      direct or indirect, of the power to direct or cause the direction of the
management and
      policies of a person, whether through the ownership of voting securities,
by contract, or
      otherwise.
       Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Marion Graham at 202-551-6521 or Jan Woo at 202-551-3453 with any other
questions.



                                                            Sincerely,
FirstName LastNameYe Tao
                                                            Division of
Corporation Finance
Comapany Name3 E Network Technology Group Ltd
                                                            Office of
Technology
November 20, 2023 Page 2
cc:       Anna Wang
FirstName LastName
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