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                                                             February 20, 2025

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 Registration Statement on Form F-1
           Filed February 7, 2025
           File No. 333-284140
Dear Ng Wai Ian:

     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 January 31,
2025 letter.

Amendment No. 1 to Form F-1 filed February 7, 2025
Prospectus Summary
Overview, page 1

1.     We note your revised disclosure pursuant to prior comment 5. Here and
elsewhere as
       applicable, such as on page 64, please explain what you mean by the
property markets
       are "under pressure" in Mainland China and Macau and how and why that
impacted
       your industrial park consultation services. To the extent this
represents a known trend
       or uncertainty that is reasonably likely to have a material impact on
future operating
       results, please disclose this in an appropriate place in your
registration statement. See
       Item 5.D. of Form 20-F.
 February 20, 2025
Page 2

        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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