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                                February 28, 2022

       Vincent Or
       Executive Director and Chief Financial Officer Nominee
       Junee Ltd
       Studio 20, 11 F, International Plaza, 20 Sheung Yuet Road
       Kowloon Bay, Kowloon, Hong Kong

                                                        Re: Junee Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted January
26, 2022
                                                            CIK No. 0001897087

       Dear Mr. Or:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1 filed
January 26, 2022

       Cover Page

   1.                                                   Please disclose
prominently on the prospectus cover page that you are not a Chinese
                                                        operating company but a
BVI holding company with operations conducted by your
                                                        subsidiary based in
Hong Kong and that this structure involves unique risks to investors.
                                                        Your disclosure should
acknowledge that Chinese regulatory authorities could disallow
                                                        this structure, which
would likely result in a material change in your operations and/or a
                                                        material change in the
value of the securities you are registering for sale, including that it
                                                        could cause the value
of such securities to significantly decline or become worthless.
                                                        Provide a
cross-reference to your detailed discussion of risks facing the company and the
                                                        offering as a result of
this structure.
 Vincent Or
Junee Ltd
February 28, 2022
Page 2
2.       We note your disclosure in the ninth and tenth paragraphs on the
prospectus cover page in
         response to comment 2. Please revise the cover page to disclose that
there are legal and
         operational risks associated with being based in or having the
majority of the company's
         operations in Hong Kong and to disclose these legal and operational
risks. Your
         disclosure should make clear whether these risks could result in a
material change in your
         operations and/or the value of the securities your are registering for
sale or 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.
         Your disclosure should specifically address how recent statements and
regulatory actions
         by China's government, such as those related to data security or
anti-monopoly concerns,
         have or may impact the company's ability to conduct its business,
accept foreign
         investments, or list on a U.S. or other foreign exchange. In addition,
expand the
         discussion on the prospectus cover page regarding the PCAOB to include
whether and
         how the Holding Foreign Companies Accountable Act and related
regulations will affect
         your company.
3.       Clearly disclose how you will refer to the holding company and
subsidiary when
         providing the disclosure throughout the document so that it is clear
to investors which
         entity the disclosure is referencing and which subsidiaries or
entities are conducting the
         business operations. We note in the first paragraph on the prospectus
cover page that you
         define "Junee Limited" as "we" or "us;" however, the second bullet on
page ii defines
         ""Company," "we," "us," or "our" in this prospectus"" to refer to
"Junee Limited...and its
         subsidiary, OPS HK..." Refrain from using terms such as    we    or
our    when describing
         activities or functions of the Hong Kong subsidiary. For example,
disclose, if true, that
         your subsidiary conducts operations in Hong Kong and that the holding
company does not
         conduct operations. Disclose clearly the entity (including the
domicile) in which investors
         are purchasing an interest.
4.       We note your disclosure in response to comment 18 that "[y]our largest
shareholder will
         beneficially own approximately 65% of the aggregate voting power of
our issued and
         outstanding Ordinary Shares as a group." Please revise here and in
your risk factor
         section, to discuss the shareholder ability to control the outcome of
any vote requiring the
         approval of a majority of stockholders.
Prospectus Summary, page 1

5.     We note your disclosure in response to comment 3. Revise the second to
last bullet point
       on page 5 to clarify that trading in your securities may be prohibited
under the Holding
FirstName LastNameVincent Or
       Foreign Companies Accountable Act if the PCAOB determines that it cannot
inspect or
Comapany    NameJunee
       investigate      Ltd your auditor, and that as a result an exchange may
determine to
                   completely
       delist
February  28, your
              2022securities.
                   Page 2
FirstName LastName
 Vincent Or
FirstName
Junee Ltd LastNameVincent Or
Comapany28,
February   NameJunee
            2022     Ltd
February
Page 3 28, 2022 Page 3
FirstName LastName
Summary of Risk Factors, page 2

6.       We note your disclosure in response to comment 4 and reissue the
comment. Revise your
         summary of risk factors to specifically describe the significant
regulatory, liquidity, and
         enforcement risks with cross-references to the more detailed
discussion of these risks in
         the prospectus. For example, specifically discuss risks arising from
the legal system in
         China and Hong Kong, including risks and uncertainties regarding the
enforcement of
         laws and that rules and regulations in China and Hong Kong can change
quickly with little
         advance notice; 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 Hong Kong-based issuers, which could
result in a material
         change in your operations and/or the value of the securities you are
registering for sale.
         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 Hong Kong-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.
Corporate History and Holding Company Structure, page 7

7.       We note your disclosure in response to comment 9. Revise here to also
include a
         discussion of the entities included in your organizational chart,
including a brief
         description of the nature of their business operations, if material.
Transfers of Cash to and from Our Subsidiary, page 8

8.       We note your disclosure in response to comment 5. Expand your
discussion of how cash
         is transferred throughout the organization to describe any
restrictions on foreign exchange
         and your ability to transfer cash between entities, across borders,
and to U.S. investors.
         Describe any restrictions and limitations on your ability to
distribute earnings from the
         company, including your subsidiaries, to the parent company and U.S.
investors. In this
         regard, we note your current disclosure on the prospectus cover page.
Recent Regulatory Developments in the PRC, page 9

9.       We note your disclosure in response to comment 6. Expand your
discussion to 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 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.
         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)
 Vincent Or
Junee Ltd
February 28, 2022
Page 4
         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.
There remain some uncertainties as to whether we will be required to obtain
approval..., page 20

10.      We note your statement on page 21 that "We do not currently expect the
Revised Draft to
         have an impact on our business, operations or the Offering..." 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. In doing so, please address the
applicability of new
         regulations that went effect on February 15 that will require internet
platform operators
         holding data of more than 1 million users to undergo a network
security review.
       You may contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Stacey Peikin at 202-551-6223 or Jennifer L  pez Molina at 202-551-3792
with any other
questions.



FirstName LastNameVincent Or                                   Sincerely,
Comapany NameJunee Ltd
                                                               Division of
Corporation Finance
February 28, 2022 Page 4                                       Office of Trade
& Services
FirstName LastName