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                             April 25, 2022

       Yu Yang
       Chief Executive Officer
       Qiansui International Group Co. Ltd.
       7th Floor, Naiten Building, No. 1
       Six Li Oiao, Fentai District
       Beijing, China 100161

                                                        Re: Qiansui
International Group Co. Ltd.
                                                            Form 10-K for the
Year Ended December 31, 2020
                                                            Filed September 23,
2021
                                                            File No. 000-54159

       Dear Mr. Yang:

              We have reviewed your January 12, 2022 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
       December 13, 2021 letter.

       Form 10-K for the Year Ended December 31, 2020

       Item 1. Business, page 3

   1.                                                   Please disclose that
the legal and regulatory risks associated with being based in China
                                                        may make you a less
attractive partner in an initial business combination than a blank
                                                        check company without
any ties to China. Please also state that your ties to China may
                                                        make it harder for you
to complete an initial business combination with a target company
                                                        without any such ties.
   2.                                                   We note your response
to comment 2 and reissue our comment in part. Please revise your
                                                        disclosure to state
that Chinese government intervention could result in a material change
                                                        in your operations
and/or the value of your common stock. Acknowledge any risks that
 Yu Yang
FirstName   LastNameYu   Yang
Qiansui International Group Co. Ltd.
Comapany
April       NameQiansui International Group Co. Ltd.
       25, 2022
April 225, 2022 Page 2
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FirstName LastName
         any actions by the Chinese government to exert more oversight and
control over offerings
         that are conducted overseas and/or foreign investment in China-based
issuers could
         significantly limit or completely hinder your ability to offer or
continue to offer securities
         to investors and cause the value of such securities to significantly
decline or be worthless.
         Confirm the risks you will disclose will be include in Item 1.
Business section of the
         document with cross-references to a more detailed discussion of these
risks in Item 1A.
         Risk Factors.
3.       We note your response to comment 3 and reissue our comment. Given your
Class A
         common stock currently trades on the OTC Pink Market we are unclear
how you have
         determined you have not issued securities to foreign investors.
Disclose each permission
         that you are required to obtain from Chinese authorities to operate
and issue securities to
         foreign investors. State affirmatively whether you have received all
requisite permissions
         and whether any permissions have been denied. Please address the
consequences to you
         and your investors if you do not receive or maintain approvals where
you inadvertently
         conclude that such approvals are not required, or applicable laws,
regulations, or
         interpretations change and you are required to obtain approval in the
future. Confirm you
         will include the disclosure in Item 1. Business section of the
document.
4.       We note your response to comment 4 and reissue the comment. Provide a
clear description
         of how cash will be transferred through the post-combination
organization if you acquire a
         company based in China. Describe any restrictions on foreign exchange
and your ability
         to transfer cash between entities, across borders, and to U.S.
investors that may apply after
         a business combination with a company based in China. Describe any
restrictions and
         limitations on your ability to distribute earnings from your
businesses, including
         subsidiaries, to the parent company and U.S. investors. Confirm you
will include the
         disclosure in Item 1. Business section of the document.
5.       We note your response to comment 5. Please revise your disclosure to
also state that if the
         Accelerating Holding Foreign Companies Accountable Act is enacted this
would also
         reduce the time before your securities may be prohibited from trading.
Disclose whether
         your auditor is subject to the determinations announced by the PCAOB
on December 16,
         2021. Confirm you will include the disclosure in Item 1. Business
section of the
         document.
Part I, page 3

6.       We note your response to comment 6 and reissue the comment in part. We
note that your
         principal executive offices are located in China, a majority of your
executive officers
         and/or directors are located in or have significant ties to China and
your disclosure that
         you will not restrict potential target companies to any specific
business, industry or
         geographical location and, thus, may acquire a company that may be
based in China or
         Hong Kong. Please confirm you will disclose this prominently at the
onset of Part I.
         Revise your disclosure at the onset of Part I to also address how
recent statements and
         regulatory actions by China   s government, such as those related to
the use of variable
 Yu Yang
FirstName   LastNameYu   Yang
Qiansui International Group Co. Ltd.
Comapany
April       NameQiansui International Group Co. Ltd.
       25, 2022
April 325, 2022 Page 3
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FirstName LastName
         interest entities and data security or anti-monopoly concerns, has or
may impact the
         company   s ability to conduct its business, accept foreign
investments, or list on an U.S. or
         other foreign exchange. In addition, disclose at the onset of Part I
whether your auditor is
         subject to the determinations announced by the PCAOB on December 16,
2021 and
         whether and how the Holding Foreign Companies Accountable Act and
related
         regulations will affect your company. Provide a cross-reference to
your detailed
         discussion of risks facing the company and the offering. Confirm
disclosure under Item 1.
         Business will address, but not necessarily be limited to, the risks
highlighted at the onset
         of Part I.
Item 1A. Risk Factors, page 8

7.       We note your response to comment 8 and reissue the comment. Please
expand your risk
         factor disclosure to 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. Confirm you will
include the
         disclosure in Item 1A. Risk Factors.
8.       We note your response to comment 9. Please revise your disclosure to
state that any action
         by the Chinese government to exert more oversight and control over
offerings that are
         conducted overseas and/or foreign investment in China-based issuers
could cause the
         value of your securities to significantly decline or be worthless.
Confirm you will include
         the disclosure in Item 1A. Risk Factors.
9.       We note your response to comment 10 and reissue the comment. Given you
are listing on
         a foreign exchange, please revise your disclosure to explain how
recent events indicating
         greater oversight by the Cyberspace Administration of China over data
security could
         impact the process of searching for a target and completing an initial
business
         combination, and/or your business on a post-combination basis.
Disclose to what extent
         you believe that you are compliant with the regulations that have been
issued by the CAC
         to date. Confirm you will include the disclosure in Item 1A. Risk
Factors.
10.      We note your response to comment 11 and your disclosure about the
Holding Foreign
         Companies Accountable Act. Please expand your risk factors to disclose
that the United
         States Senate has passed the Accelerating Holding Foreign Companies
Accountable Act,
         which, if enacted, would decrease the number of    non-inspection
years    from three years
         to two years, and thus, would reduce the time before your securities
may be prohibited
         from trading or delisted. Update your disclosure to reflect that the
Commission adopted
         rules to implement the HFCAA and that, pursuant to the HFCAA, the
PCAOB has issued
         its report notifying the Commission of its determination that it is
unable to inspect or
         investigate completely accounting firms headquartered in mainland
China or Hong Kong.
         Confirm you will include the disclosure in Item 1A. Risk Factors.

         You may contact William Demarest, Staff Accountant at 202-551-3432 or
Shannon
 Yu Yang
Qiansui International Group Co. Ltd.
April 25, 2022
Page 4

Menjivar, Accounting Branch Chief at 202-551-3856 if you have any questions.



                                                         Sincerely,
FirstName LastNameYu Yang
                                                         Division of
Corporation Finance
Comapany NameQiansui International Group Co. Ltd.
                                                         Office of Real Estate
& Construction
April 25, 2022 Page 4
cc:       Daniel Luciano
FirstName LastName