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                              August 14, 2023

       Yanru Zhou
       Chief Financial Officer
       SUIC Worldwide Holdings Ltd.
       136-20 38th Ave. Unit 3G
       Flushing , NY 11354

                                                        Re: SUIC Worldwide
Holdings Ltd.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed June 30, 2023
                                                            Form 10-Q for the
Quarterly Period Ended March 31, 2023
                                                            Filed July 3, 2023
                                                            File No. 000-53737

       Dear Yanru Zhou:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Report of Independent Registered Public Accounting Firm, page F-1

   1.                                                   Please amend your
filing to also include an audit report for your financial statements for
                                                        the year ended December
31, 2021.
   2.                                                   Please ask your auditor
to correct the first paragraph of their opinion to comply with
                                                        PCAOB auditing
standards. The first paragraph of the audit report should also have the
                                                        same name of the
Company included in your financial statements.

       Income Statement, page F-3

   3.                                                   Revise your income
statement to include bad debt expense as part of operating expense.
 Yanru Zhou
FirstName LastNameYanru   Zhou
SUIC Worldwide   Holdings Ltd.
Comapany
August 14, NameSUIC
           2023       Worldwide Holdings Ltd.
August
Page 2 14, 2023 Page 2
FirstName LastName
Note 1 - Organization and Basis of Presentation, page F-6

4.       We see your disclosure that on August 7, 2021 you acquired 49% of the
registered shares
         of Midas Touch Technology Co. Ltd. Revise your filing to explain how
you accounted for
         the acquisition and how the company accounts for its interest (i.e.
equity method,
         consolidation, etc.).
5.       In this regard, if you account for your 49% investment in Midas Touch
Technology under
         the equity method, tell us how you considered the requirements of Rule
3-09 of
         Regulation S-X with regard to the separate financial statements of
your investee.
Note 3 - Revenue Recognition, page F-7

6.       Please explain to us the location where your revenues are generated.
Form 10-Q for the Quarterly Period Ended March 31, 2023

Item 2. Managements Discussion and Analysis of Financial Condition and Results
of Operations
Three Months Ended March 31, 2023 and March 31, 2022
Cost of Revenue, page 13

7.       You indicate that the increase was due to professional expenses. Cost
of Revenue
         significantly decreased during the period, however. Please revise your
filing to explain the
         significant decrease in cost of revenue during the period.
Item 9A. Controls and Procedures, page 16

8.       Please tell us how your management was able to conclude that your
disclosure controls
         and procedures were effective at March 31, 2023 when they concluded
that they were not
         effective as of December 31, 2022 due to the fact that the directors
have little
         understanding of U.S. GAAP and Sarbanes Oxley and you also indicate on
page 13 that
         there were no changes in internal control during the period. Please
advise.
Income Statement, page F-3

9.       We do not see where you reflect your general and administrative
operating expenses in
         your Income Statement. Please advise.
Note 8 Contingency and Commitment, page F-10

10.      We see your disclosure that you signed a joint venture agreement and
several letters of
         intent during the period. Revise your filing to include the
significant terms of these
         agreements and disclose the related accounting treatment for these
arrangements.
       In closing, 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.
 Yanru Zhou
SUIC Worldwide Holdings Ltd.
August 14, 2023
Page 3

        You may contact Julie Sherman at (202) 551-3640 or Brian Cascio,
Accounting Branch
Chief, at (202) 551-3676 with any questions.



                                                         Sincerely,
FirstName LastNameYanru Zhou
                                                         Division of
Corporation Finance
Comapany NameSUIC Worldwide Holdings Ltd.
                                                         Office of Industrial
Applications and
August 14, 2023 Page 3                                   Services
FirstName LastName