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                               May 10, 2022

       Dominic Wells
       Chief Executive Officer
       Onfolio Holdings, Inc.
       Executive Centre Taipei, Level 4
       Neihu New Century Building No, No. 55, Zhouzi St
       Neihu District, Taipei City, 114, Taiwan

                                                        Re: Onfolio Holdings,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed April 26,
2022
                                                            File No. 333-264191

       Dear Mr. Wells:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

       Form S-1/A filed April 26, 2022

       Financial Statements
       Consolidated Statements of Operations, page F-4

   1.                                                   Please revise to state
separately the cost of products sold and cost of services for the
                                                        periods presented
pursuant to Rule 5-03(b)(2) of Regulation S-X.
       Note 2 - Summary of Significant Accounting Policies, page F-7

   2.                                                   Please expand the
accounting policy disclosure to include your accounting policy for cost
                                                        of product revenues and
cost of services.
 Dominic Wells
FirstName  LastNameDominic Wells
Onfolio Holdings, Inc.
Comapany
May        NameOnfolio Holdings, Inc.
     10, 2022
May 10,
Page 2 2022 Page 2
FirstName LastName
        You may contact Claire DeLabar, Senior Staff Accountant, at
202-551-3349 or Robert
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Kyle
Wiley, Staff
Attorney, at 202-344-5791 or Jeff Kauten, Staff Attorney, at 202-551-3447 with
any other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Technology
cc:      David M. Bovi