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                              November 3, 2023

       Lei Xia
       Chief Executive Officer
       ICZOOM Group Inc.
       Room 3801, Building A, Sunhope e METRO
       No. 7018 Cai Tian Road, Futian District, Shenzhen
       Guangdong, China, 518000

                                                        Re: ICZOOM Group Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted October
5, 2023
                                                            CIK 0001854572

       Dear Lei Xia:

              We have conducted a limited review of your registration statement
and have the
       following comment(s).

              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.

       Draft Registration Statement on Form F-1 submitted October 5, 2023

       Commonly Used Defined Terms , page ii

   1.                                                   Please revise your
definition of "China" or the "PRC" to clearly state that the legal and
                                                        operational risks
associated with operating in China also apply to operations in Hong
                                                        Kong and Macau.
       We may not be able to prevent others from unauthorized use of our
intellectual property...., page
       39

   2.                                                   We note the changes you
made to your disclosure appearing in this risk factor as
                                                        compared to your
disclosure in the same risk factor in your IPO registration statement on
                                                        Form F-1 that went
effective March 14, 2023. It is unclear to us that there have been
                                                        changes in the
intellectual property regulatory environment in the PRC since the review of
                                                        your IPO registration
statement that warrants revised disclosure that mitigates the
 Lei Xia
ICZOOM Group Inc.
November 3, 2023
Page 2
       challenges you face. Please restore your disclosures in these areas to
the disclosures as
       they existed in the registration statement as of March 14, 2023.
Risks Related to Doing Business in China, page 49

3.     We note the changes you made to risk factors on pages 49-56 as compared
to your
       disclosure in the same risk factors in your IPO registration statement
on Form F-1 that
       went effective March 14, 2023. These changes include the deletion of
references to
       control, comparisons of the Chinese regulatory regime to other
jurisdictions, the revision
       of terms such as "harm" and "hinder" to less descriptive terms such as
"affect," the
       revision of references to the Chinese regulatory regime having
"uncertainties" and being
       "vague," and the revisions in the description of social and political
changes in China. We
       remind you that, pursuant to federal securities rules, the term
"control" (including the
       terms "controlling," "controlled by," and "under common control with")
as defined in
       Securities Act Rule 405 means "the possession, direct or indirect, of
the power to direct or
       cause the direction of the management and policies of a person, whether
through the
       ownership of voting securities, by contract, or otherwise." Please
restore your disclosures
       in these areas to the disclosures as they existed in the registration
statement as of March
       14, 2023.
        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 Kate Beukenkamp at 202-551-3861 or Lilyanna Peyser at
202-551-3222
with any other questions.



                                                             Sincerely,
FirstName LastNameLei Xia
                                                             Division of
Corporation Finance
Comapany NameICZOOM Group Inc.
                                                             Office of Trade &
Services
November 3, 2023 Page 2
cc:       Arila Zhou
FirstName LastName