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                            June 20, 2024

       Shufang Gao
       Chief Executive Officer
       Tianci International, Inc.
       Unit B,10/F., Ritz Plaza, No.122 Austin Road, Tsim Sha Tsui
       Kowloon, Hong Kong 999077

                                                        Re: Tianci
International, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 10, 2024
                                                            File No. 333-280089

       Dear Shufang Gao:

              We have conducted a limited review of your registration statement
and have the
       following comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

       Registration Statement on Form S-1

       Prospectus Summary, page 1

   1.                                                   Disclose each
permission or approval that you or your subsidiaries are required to obtain
                                                        from Chinese
authorities to operate your business and to offer the securities being
                                                        registered to foreign
investors. State whether you or your subsidiaries 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 you or your subsidiaries: (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.
 Shufang Gao
FirstName  LastNameShufang   Gao
Tianci International, Inc.
Comapany
June        NameTianci International, Inc.
     20, 2024
June 20,
Page 2 2024 Page 2
FirstName LastName
Risk Factors
Risks Related to Doing Business in Hong Kong, page 29

2.       We note your cover page disclosure indicating that you nd your
subsidiaries "should not
         become subject to certain laws...such as those relating to data and
cyberspace security."
         However, in light of recent events indicating greater oversight by the
Cyberspace
         Administration of China (CAC) over data security, particularly for
companies seeking to
         list on a foreign exchange, please revise your disclosure to explain
how this oversight
         impacts your business and your offering and to what extent you believe
that you are
         compliant with the regulations or policies that have been issued by
the CAC to date.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Kyle Wiley at 202-344-5791 or Matthew Derby at
202-551-3334 with any
other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Anthony Basch