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                             October 2, 2023

       Chen Yuanhang
       Chief Executive Officer
       LVPAI GROUP Ltd
       50 West Liberty Street, Suite 880
       Reno, Nevada 89501

                                                        Re: LVPAI GROUP Ltd
                                                            Form 10-K for the
fiscal year ended January 31, 2023
                                                            Filed May 25, 2023
                                                            Response dated May
15, 2023
                                                            File No. 033-20966

       Dear Chen Yuanhang:

              We have reviewed your May 15, 2023 response to our comment letter
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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       February 24, 2023 letter.

       Annual Report on Form 10-K for the fiscal year ended January 31, 2023

       General

   1.                                                   Refer to prior comment
1. Please provide prominent disclosure about the legal and
                                                        operational risks
associated with a majority of your directors and officers based in or
                                                        having significant ties
to China. Your disclosure should make clear whether these risks
                                                        could result in a
material change in your search for a target company and/or the value of
                                                        the securities you are
registering for sale. Your disclosure should address how recent
                                                        statements and
regulatory actions by China   s government, such as those related to data
                                                        security or
antimonopoly concerns, have or may impact the company   s ability to conduct
                                                        its business, accept
foreign investments, or list on a U.S. or other foreign exchange.
 Chen Yuanhang
FirstName  LastNameChen Yuanhang
LVPAI GROUP     Ltd
Comapany
October    NameLVPAI GROUP Ltd
        2, 2023
October
Page 2 2, 2023 Page 2
FirstName LastName
2.       Disclose each permission or approval that you or your officers and
directors are required
         to obtain from Chinese authorities to search for a target company.
State whether your
         directors and officers are covered by permissions requirements from
the China Securities
         Regulatory Commission (CSRC), Cyberspace Administration of China (CAC)
or any
         other governmental agency, and state affirmatively whether you have
received all
         requisite permissions or approvals and whether any permissions or
approvals have been
         denied. Please also describe the consequences to you and your
investors if your officers
         and directors (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.
3.       Given the significant oversight and discretion of the government of
the People   s Republic
         of China (PRC) over the conduct of your directors' and officers'
search for a target
         company, please describe any material impact that intervention or
control by the PRC
         government has or may have on your business or on the value of your
securities. We
         remind you that, pursuant to federal securities rules, the term
control    (including the
         terms    controlling,       controlled by,    and    under common
control with   ) means    the
         possession, direct or indirect, of the power to direct or cause the
direction of the
         management and policies of a person, whether through the ownership of
voting securities,
         by contract, or otherwise.
4.       We note your disclosure on page 3 regarding PRC M&A Rules. Please
address
         specifically any PRC regulations concerning mergers and acquisitions
by foreign investors
         that your initial business combination transaction may be subject to,
including PRC
         regulatory reviews, which may impact your ability to complete a
business combination in
         the prescribed time period. Also address any impact PRC law or
regulation may have on
         the cash flows associated with the business combination, including
shareholder
         redemption rights.
5.       Please revise the introduction to your Business section to disclose
the risks that the
         location of the sponsors and the majority of your executive officers
and/or directors
         having significant ties to China may make you a less attractive
partner to a non-China-
         based target company, which may therefore limit the pool of
acquisition candidates.
6.       We note your disclosure on page 2 regarding enforcement of judgments
in China. Please
         include a separate section on enforcement of liabilities addressing
the enforcement risks
         related to civil liabilities due to your sponsor and some of your
officers and directors
         being located in China or Hong Kong. For example, revise to discuss
more specifically
         the limitations on investors being able to effect service of process
and enforce civil
         liabilities in China, lack of reciprocity and treaties, and cost and
time constraints. Also,
         please disclose these risks in the business section, which should
contain disclosures
         consistent with the separate section. Additionally, please identify
each officer and director
         located in China or Hong Kong and disclose that it will be more
difficult to enforce
         liabilities and enforce judgments on those individuals.
 Chen Yuanhang
LVPAI GROUP Ltd
October 2, 2023
Page 3

       You may contact Peter McPhun at 202-551-3581 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Maryse Mills-Apenteng at 202-551-3457
with any
other questions.



                                                        Sincerely,
FirstName LastNameChen Yuanhang
                                                        Division of Corporation
Finance
Comapany NameLVPAI GROUP Ltd
                                                        Office of Real Estate &
Construction
October 2, 2023 Page 3
cc:       Ben Borgers, Esq.
FirstName LastName