September 24, 2024

Yan Ping Sheng
Chief Executive Officer
China Teletech Holding Inc.
16th Floor, North Tower,
528 Pudong South Road
Shanghai, China 200120

       Re: China Teletech Holding Inc.
           Registration Statement on Form 10-12G
           Filed August 27, 2024
           File No. 000-56680
Dear Yan Ping Sheng:

       We have reviewed your filing and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Registration Statement on Form 10-12G
Cover Page

1.     We note that you have a dual class capital structure whereby Series A
Preferred Share has
       the voting power of 1,000 common shares and it appears Mr. Yang, Kung-Fu
will have
       majority voting control of the company through his control of World
Capital Holding,
       Ltd. Please revise your cover page to discuss the dual class nature of
your capital structure
       and quantify the voting control that Messrs. Yan Ping Shen and Yang,
Kung-Fu have. In
       addition, revise your disclosure here and throughout the filing,
including the cover page,
       to detail the dilutive effect of the Series A Preferred Shares and the
controlling impact of
       the Series A Preferred Shares. In addition, explain in greater detail
your capital structure,
       and the nature of the disparate voting rights.
 September 24, 2024
Page 2
Liquidity and Capital Resources, page 15

2.     Please disclose the amount of capital resources needed to fund your
planned
       operations for the next twelve months. To the extent you do not
currently have sufficient
       capital, please describe the level of operations that you will be able
to perform with your
       existing capital resources and liquidity.
Security Ownership of Certain Beneficial Owners and Management, page 17

3.     Please revise your beneficial ownership table to add a column that
includes the aggregate
       voting power held by each person or entity identified.
Directors and Executives Officers, page 18

4.     We note the CEO is involved as the CEO of three other companies
World Financial
       Holding Group (USA), Shanghai Capital Holding Co., Ltd and Shanghai
Qifan Enterprise
       Management Co., Ltd. Please revise to discuss any potential conflicts of
interest and how
       much time per week the CEO is involved in the management of China
Teletech Holding,
       Inc.
Report of Independent Registered Public Accounting Firm, page F-11

5.     We note that your audit firm identified material weaknesses in internal
control over
       financial reporting that are communicated as critical audit matters.
Please provide us with
       the basis for the audit firm   s determination that the material
weaknesses meet the
       definition of critical audit matters. That is, explain how the matters
relate to accounts or
       disclosures that are material to the financial statements and whether
auditing those
       affected account balances and disclosures involved especially
challenging, subjective, or
       complex auditor judgment. Refer to PCAOB AS 3101. In addition, please
revise to
       include an audit opinion that complies with the guidance in paragraph 14
of PCAOB AS
       3101 regarding the communication of critical audit matters.
General

6.     You appear to be a shell company as that term is defined in Securities
Act Rule 405 of
       Regulation C. In this regard, we note that you have nominal operations
and no or nominal
       assets to date. Please disclose prominently in the Business section that
you are a shell
       company and add disclosure highlighting the consequences of your shell
company status.
       Discuss the prohibition on the use of Form S-8 by shell companies,
enhanced reporting
       requirements imposed on shell companies, and the conditions that must be
satisfied before
       restricted and control securities may be resold in reliance on Rule 144.
Revise throughout
       as appropriate for consistency. In addition, we note your disclosure
that your stated
       business purpose "includes a merger [with] a target company in the food
industry
       business" but also note your disclosure indicating you do not believe
you are a blank
       check company. Please disclose that you are a "blank check" company
under paragraph
       (a)(2) of Rule 419 of the Securities Act, and provide disclosure
regarding your status as a
       blank check company and in an appropriate place in your filing, provide
details regarding
       compliance with Rule 419 in connection with any offering of your
securities. In the
       alternative, provide us with a detailed analysis regarding why you do
not believe you are a
       "blank check" company pursuant to paragraph (a)(2) of Rule 419 of the
Securities Act.
 September 24, 2024
Page 3

7.     Please revise your filing throughout, as applicable, to provide more
specific and
       prominent disclosures about the legal and operational risks associated
with China-
       based companies. For additional guidance, please see the Division of
Corporation
       Finance's Sample Letter to China-Based Companies issued by the Staff in
December
       2021.
8.     We note your disclosure on page F-17 that the Company is an emerging
growth company.
       However, the corresponding box on the cover page of the filing is not
checked. Please
       clarify whether you qualify as an emerging growth company. Refer to
Section 2(a)(19) of
       the Securities Act of 1933. If you do qualify as an Emerging Growth
Company, please
       check the box on the cover page to indicate as such and revise your
prospectus to:

             Describe how and when a company may lose emerging growth company
status;

             Briefly describe the various exemptions that are available to you,
such as an
           exemption from Section 404(b) of the Sarbanes-Oxley Act of 2002 and
Section 14(a)
           and (b) of the Securities Exchange Act of 1934;

             State your election under Section 107(b) of the JOBS Act;

             If you have elected to opt out of the extended transition period
for complying with
           new or revised accounting standards pursuant to Section 107(b),
include a statement
           that the election is irrevocable; or

             If you have elected to avail yourself of the extended transition
period for complying
           with new or revised accounting standards under Section 102(b)(1),
provide a risk
           factor explaining that this election allows you to delay the
adoption of new or revised
           accounting standards that have different effective dates for public
and private
           companies until those standards apply to private companies. Also
state that as a result
           of this election, your financial statements may not be comparable to
companies that
           comply with public company effective dates.
 September 24, 2024
Page 4

        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.

       Please contact Melissa Walsh at 202-551-3224 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Uwem Bassey at 202-551-3433 or Matthew Derby at 202-551-3334 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:   Rhonda Keaveney, Agent