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                            February 14, 2023

       Jianjun Zhong
       President and Chief Executive Officer
       Kenongwo Group US, Inc.
       Yangjia Group, Xiaobu Town
       Yuanzhou District, Yichun City
       Jiangxi Province, China 336000

                                                        Re: Kenongwo Group US,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Response dated
February 2, 2023
                                                            File No. 333-239929

       Dear Jianjun Zhong:

              We have reviewed your February 2, 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
       December 9, 2022 letter.

       Correspondence filed January 13, 2023

       Item 1. Business, page 1

   1.                                                   We note your response
to our prior comment 1 and reissue. At the onset of Part I, please
                                                        disclose prominently
that you are not a Chinese operating company but a Nevada holding
                                                        company with operations
conducted by your subsidiary in China.
 Jianjun Zhong
FirstName
Kenongwo LastNameJianjun
           Group US, Inc. Zhong
Comapany14,
February   NameKenongwo
            2023          Group US, Inc.
February
Page  2 14, 2023 Page 2
FirstName LastName
2.       We note your response to our prior comment 2 and reissue it in part.
Provide prominent
         disclosure about the legal and operational risks associated with being
based in or having
         the majority of the company   s operations in China. We also note your
statements in your
         response to comment 2 that    [y]our research direction is beneficial
to Chinese agriculture
         and even the world   s agriculture    and that    [y]our company   s
products are not only
         welcomed by [y]our customers, but also supported and helped by the
local government in
         China.    Please explain the basis of each of these claims.
Furthermore, please clarify how
         your research is    beneficial to Chinese agriculture    as well as
how your products are
            supported and helped by the local government in China.
3.       We note your response to our prior comment 3 and reissue. Please
prominently disclose
         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.
4.       We note your response to our prior comment 4 and resissue in part.
Please provide a clear
         description in Item 1 of how cash is transferred through your
organization. Quantify any
         cash flows and transfers of other assets by type that have occurred
between the holding
         company and its subsidiary, and direction of transfer. Quantify any
dividends or
         distributions that the subsidiary have made to the holding company,
and its tax
         consequences. Your disclosure should make clear if no transfers,
dividends, or
         distributions have been made to date. Describe any restrictions on
foreign exchange and
         your ability to transfer cash between entities and across borders.
Describe any restrictions
         and limitations on your ability to distribute earnings from the
company, including your
         subsidiary, to the parent company.
5.       We note your response to our prior comment 5 and reissue. Disclose
each permission or
         approval that you or your subsidiary are required to obtain from
Chinese authorities to
         operate your business and to offer securities to foreign investors.
State whether you or
         your subsidiary are covered by permissions requirements from the China
Securities
         Regulatory Commission (CSRC), Cyberspace Administration of China (CAC)
in
         particular, or any other governmental agency that is required to
approve your operations,
         and state affirmatively whether you have received all requisite
permissions or approvals
         and whether any permissions or approvals have been denied. If you or
your subsidiary are
         not required to obtain any permissions or approvals from Chinese
authorities to operate
         your business and to offer securities to foreign investors, then
please revise to state this
         explicitly. If you are not required to obtain permissions requirements
or approvals from
         the CSRC and CAC or any other governmental agency please revise to
state this
         explicitly. Please also describe the consequences to you and your
investors if you or your
         subsidiary: (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. Please note that (ii) and (iii) must be
disclosed regardless of
         whether or not you currently hold permissions or approvals.
 Jianjun Zhong
Kenongwo Group US, Inc.
February 14, 2023
Page 3
Item 1A. Risk Factors, page 11

6.       We note your response to our prior comment 6 and reissue. In your
summary of risk
         factors, disclose the risks that your corporate structure and being
based in or having the
         majority of the company   s operations in China poses to investors. In
particular, describe
         the significant regulatory, liquidity, and enforcement risks. For
example, specifically
         discuss risks arising from the legal system in China, including risks
and uncertainties
         regarding the enforcement of laws and that rules and regulations in
China can change
         quickly with little advance notice; and the risk that the Chinese
government may intervene
         or influence your operations at any time, or may exert more control
over offerings
         conducted overseas and/or foreign investment in China-based issuers,
which could result
         in a material change in your operations and/or the value of your
securities. Acknowledge
         any risks that 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 your securities
to significantly decline
         or be worthless
7.       We note your response to our prior comment 7 and reissue it. Given the
Chinese
         government   s significant oversight and discretion over the conduct
of your business,
         please revise to highlight separately the risk that the Chinese
government may intervene or
         influence your operations at any time, which could result in a
material change in your
         operations and/or the value of your securities. Also, given recent
statements by the
         Chinese government indicating an intent to exert more oversight and
control over
         offerings that are conducted overseas and/or foreign investment in
China-based issuers,
         acknowledge the risk that any such action 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.
8.       We note your statements that "[y]our company is doing the right thing"
and "[y]our
         company is not contrary to China's national policy." Please revise to
provide your basis
         for these statements.
9.     We note your response to our prior comment 8 and reissue it. 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 ability to
FirstName LastNameJianjun Zhong
       offer securities to investors and to what extent you believe that you
are compliant with the
Comapany    NameKenongwo
       regulations or policiesGroup   US,been
                                that have  Inc. issued by the CAC to date. If
you do not believe you
       are14,
February   subject
              2023to  CAC
                    Page  3 oversight, please revise your disclose to state so
explicitly.
FirstName LastName
 Jianjun Zhong
FirstName
Kenongwo LastNameJianjun
           Group US, Inc. Zhong
Comapany14,
February   NameKenongwo
            2023          Group US, Inc.
February
Page  4 14, 2023 Page 4
FirstName LastName
General

10.      We note your response to our prior comment 10. In your discussion of
the enforceability
         of civil liabilities against foreign persons please revise to
explicitly address judgments
         obtained in U.S. courts as required by Item 101(g)(1)(ii) and (iii) of
Regulation S-K, as
         required by Item 1 of Form 10-K.
11.      With respect to your disclosure regarding all risks related to doing
business in China,
         please ensure that your disclosure does not suggest there are
mitigating factors regarding
         the nature of your relationship with the Chinese government, the
manner in which you are
         regulated, or the degree to which your operations could be affected by
economic,
         industrial, or other policies in China.
       You may contact Michael Fay at 202-551-3812 or Brian Cascio at
202-551-3676 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jordan Nimitz at 202-551-5831 or Margaret Schwartz at 202-551-7153 with
any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Industrial Applications and
                                                               Services
cc:      John Lowy, Esq.