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                            March 28, 2023

       Sin Yi Cheng
       President and Director
       Protopia Global Holdings Inc.
       Room 1116, 11/F, Star House, 3 Salisbury Road
       Tsim Sha Tsui, Kowloon
       Hong Kong

                                                        Re: Protopia Global
Holdings Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed March 15,
2023
                                                            File No. 333-269343

       Dear Sin Yi Cheng:

             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.
Unless we note
       otherwise, our references to prior comments are to comments in our
February 17, 2023 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Prospectus Summary, page 1

   1.                                                   We note your revised
disclosure in response to comment 4. Please expand your disclosure
                                                        in the prospectus
summary to also include a description of the permissions that you or
                                                        your subsidiary are
required to obtain from Hong Kong and Chinese authorities to operate
                                                        your business and to
offer the securities being registered to foreign investors. State
                                                        whether you or your
subsidiary are covered by permissions requirements from the China
                                                        Securities Regulatory
Commission (CSRC), Cyberspace Administration of China (CAC)
                                                        or any other
governmental agency that is required to approve your subsidiary's operations,
                                                        and state affirmatively
whether you have received all requisite permissions or approvals
 Sin Yi Cheng
Protopia Global Holdings Inc.
March 28, 2023
Page 2
         and whether any permissions or approvals have been denied. Please also
describe the
         consequences to you and your investors if you or your subsidiary: (i)
do not receive or
         maintain such permissions or approvals, (ii) inadvertently conclude
that such permissions
         or approvals are not required, or (iii) applicable laws, regulations,
or interpretations
         change and you are required to obtain such permissions or approvals in
the future. Please
         also disclose that you relied upon an opinion of counsel with respect
to your conclusions
         regarding permissions and approvals required to operate your business
and to offer
         securities to investors. We note that you currently include this
requested disclosure on the
         cover page and in the risk factors. Please include it in the
prospectus summary as well.
Risk Factors
Risks Related to This Offering and the Ordinary Shares
Our officers and directors currently hold and will continue to hold a
sufficient total outstanding
voting power..., page 37

2.       We note your disclosure that your officers and directors will
collectively own an
         aggregate of over 50% of the total voting power of your outstanding
ordinary shares upon
         completion of the offering, and that they may take actions which are
not in your best
         interests. Please reconcile this disclosure with the disclosure on
page 66 which states that
         your directors owe a fiduciary duty to you under Cayman Islands law,
including that they
         must "act in what they consider in good faith to be in our best
interests."
Regulations, page 55

3.       We note your revised disclosure in response to comment 14 and reissue
in part. Please
         disclose how the Hong Kong Personal Data (Privacy) Ordinance applies
to your business
         and the efforts you have undertaken to comply with the regulation.
Please revise
         consistent with Item 101(h)(4)(viii) and (ix) of Regulation S-K.
General

4.       We note that you relied on the opinion of PRC counsel throughout your
registration
         statement. Please provide a consent of counsel as an exhibit.
       You may contact Scott Stringer at 202-551-3272 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Mara Ransom at 202-551-3264 with any
other
questions.



FirstName LastNameSin Yi Cheng                                 Sincerely,
Comapany NameProtopia Global Holdings Inc.
                                                               Division of
Corporation Finance
March 28, 2023 Page 2                                          Office of Trade
& Services
FirstName LastName