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                                                            July 12, 2024

Ng Wai Ian
Director, Chairman of the Board and Chief Executive Officer
Zenta Group Co Ltd
Avenida do Infante D. Henrique
No. 47-53A, Macau Square
8th Floor, Unit J
Macau 999078

       Re: Zenta Group Co Ltd
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted June 14, 2024
           CIK No. 0002011458
Dear Ng Wai Ian:

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

        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
May 30, 2024 letter.

Amendment No. 1 to Draft Registration Statement filed June 14, 2024
Industry Overview, page 52

1.     You note that the competitive landscape for the investment services
industry includes
       banks, securities companies and insurance companies. Please clarify
whether you are
       offering the types of services offered by these entities. Your
disclosure in the prospectus
       suggests that your focus is on specialized consulting for industrial
parks.
 July 12, 2024
Page 2
General

2.     Where you discuss your investment consultation services business on page
69, and
       elsewhere as appropriate, please revise to clearly indicate the type of
investment
       consultation services provided and the scope of current projects you
have
       undertaken. Your description of yourself as an investment advisor
suggests that you make
       securities investment recommendations, however your disclosure suggests
that you
       provide other services such as hiring and coordinating professionals and
advising on
       internal controls and risk management. To the extent your investment
consultation
       services relate to a specific type of investment or are more of a
project-based consultation
       service that sometimes includes investments, please make this clear and
indicate the type
       of investments on which you advise. Based on Note 3 to your financial
statements, it
       appears that the investment services relate to acquiring a stake in a
specific project in an
       industrial park. If all of your investment services and brokerage fees
relate to this type of
       investment, please make this clear in your disclosure. Indicate how you
identify the
       investment opportunities and whether they are the same projects as those
you consult on
       when generating project research fees, and disclose that all of your
investment
       consultation services to date have been provided to related parties, if
true. Please also
       indicate whether you are required to register under any applicable
regulations given your
       services as an investment advisor.
3.     Please define the scope of the fintech business that you are developing
and the specific
       services you are providing. The term fintech implies many different
types of services and
       technology, as evidenced by your definition of fintech services on page
57, and it is
       unclear which you are pursuing and how you will be involved. Also revise
the description
       of the fintech industry in your Industry Overview to focus on the
particular type of fintech
       that you are, or plan to be, involved in. Please also explain the type
of services you will
       provide pursuant to the business agreements entered into in January
2024, as the
       disclosure says only that you will provide "fintech product and on-going
services."

        Please contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at
202-551-3336
if you have questions regarding comments on the financial statements and
related matters. Please
contact Jenna Hough at 202-551-3063 or Erin Jaskot at 202-551-3442 with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services
cc:   Lawrence Venick
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