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                             November 7, 2022

       Eva Yuk Yin Siu
       Chairlady of the Board & CEO
       Neo-Concept International Group Holdings Ltd
       10/F, Seaview Centre
       No.139-141 Hoi Bun Road
       Kwun Tong
       Kowloon, Hong Kong

                                                        Re: Neo-Concept
International Group Holdings Ltd
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted October
24, 2022
                                                            CIK Number
0001916331

       Dear Eva Yuk Yin Siu:

             We have reviewed your amended draft 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 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 comments apply 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 these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amended Draft Registration Statement

       Cover Page

   1.                                                   We note your revisions
in response to comment 1. Your references to "China" appear to
                                                        exclude Hong Kong and
Macau. Revise the definition of the PRC or China to include
                                                        Hong Kong and Macau and
revise the disclosure throughout your amendment
                                                        accordingly.
   2.                                                   We note your disclosure
that the offering is contingent upon listing on the Nasdaq Capital
 Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
November 7, 2022
Page 2
         Market or another national exchange. Please explain the actions you
will take if you do
         not receive approval to list on Nasdaq. Please ensure the disclosure
is consistent with your
         underwriting agreement.
3.       To the extent you intend to proceed with your offering if your Nasdaq
listing is denied,
         revise your cover page to indicate that the offering is not contingent
on Nasdaq approval
         of your listing application and that if the shares are not approved
for listing, you may
         experience difficulty selling your shares. Include risk factor
disclosures to address the
         impact on liquidity and the value of shares.
Risk Factors, page 14

4.       We note recent instances of extreme stock price run-ups followed by
rapid price declines
         and stock price volatility seemingly unrelated to company performance
following a
         number of recent initial public offerings, particularly among
companies with relatively
         smaller public floats. Revise to include a separate risk factor
addressing the potential for
         rapid and substantial price volatility and any known factors
particular to your offering that
         may add to this risk and discuss the risks to investors when investing
in stock where the
         price is changing rapidly. Clearly state that such volatility,
including any stock-run up,
         may be unrelated to your actual or expected operating performance and
financial
         condition or prospects, making it difficult for prospective investors
to assess the rapidly
         changing value of your stock.
       You may contact Mindy Hooker at 202-551-3732 or Martin James at
202-551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any
other questions.



FirstName LastNameEva Yuk Yin Siu                   Sincerely,
Comapany NameNeo-Concept International Group Holdings Ltd
                                                    Division of Corporation
Finance
November 7, 2022 Page 2                             Office of Manufacturing
FirstName LastName