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                               January 22, 2024

       Tim Hoi Ching
       Chief Executive Officer
       Raytech Holding Ltd
       Unit 609, 6/F, Nan Fung Commercial Centre
       No. 19 Lam Lok Street
       Kowloon Bay, Hong Kong

                                                        Re: Raytech Holding Ltd
                                                            Amendment No. 2 to
Form F-1
                                                            Filed January 18,
2024
                                                            File No. 333-275197

       Dear Tim Hoi Ching:

            We have reviewed your amended registration statement and have the
following
       comments.

              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.

       Amendment No. 2 to Form F-1

       Related Party Transactions, page 110

   1.                                                   We note from your
disclosures on pages F-23 and F-41 that you have an outstanding
                                                        amount due from a
director ($99,776) as of September 30, 2023. Please clarify, or revise
                                                        as necessary, your
statement that the amount due from a director was wholly settled in
                                                        cash subsequently in
July 2023.
   2.                                                   Section 402 of the
Sarbanes-Oxley Act of 2002 prohibits public companies from
                                                        extending or
maintaining credit in the form of personal loans to or for any director or
                                                        executive officer. To
the extent necessary, disclose the action that will be taken to ensure
                                                        any applicable
arrangements will be extinguished prior to the completion of the initial
                                                        public offering, or
tell us why this provision does not apply to the loan to Mr. Ching
                                                        disclosed in this
section.
 Tim Hoi Ching
Raytech Holding Ltd
January 22, 2024
Page 2

       Please contact Heather Clark at 202-551-3624 or Hugh West at
202-551-3872 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at 202-551-3641 with any
other
questions.



                                                        Sincerely,
FirstName LastNameTim Hoi Ching
                                                        Division of Corporation
Finance
Comapany NameRaytech Holding Ltd
                                                        Office of Manufacturing
January 22, 2024 Page 2
cc:       Arila Zhou
FirstName LastName