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                              April 29, 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. 6 to
Form F-1
                                                            Filed April 26,
2024
                                                            File No. 333-275197

       Dear Tim Hoi Ching:

                                                        We have reviewed your
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.

       Amendment 6 to Form F-1

       General

   1.                                                   Please update your
compensation disclosure to reflect the fiscal year ended March 31,
                                                        2024. Refer to Item 4
of Form 1-A and Item 6.B of Form 20-F.
   2.                                                   Please update your
disclosure as appropriate to reflect any recent developments that
                                                        materially impact your
business, financial condition, and/or results of operations.
       Exhibit 23.1, page 1

   3.                                                   We note that the
consent references the audit report in amendment 6 to Form F-1. As
                                                        amendment 6 does is an
exhibits only amendment and therefore, does not include the audit
                                                        report to which the
consent refers, please revise. As an alternative, consider referring only
                                                        to the audit report in
the F-1 filing rather than to a specific amendment.
 Tim Hoi Ching
FirstName   LastNameTim Hoi Ching
Raytech Holding   Ltd
Comapany
April       NameRaytech Holding Ltd
       29, 2024
April 229, 2024 Page 2
Page
FirstName LastName
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       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,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing
cc:      Arila Zhou