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                               September 26, 2022

       Eva Yuk Yin Siu
       Chairlady of the Board & CEO
       Neo-Concept International Group Holdings Ltd
       10/F, Seaview Centre
       No.139-141 Hoi Bun Road
       Kwun Tong
       Kowloon, Hong Kong

                                                        Re: Neo-Concept
International Group Holdings Ltd
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted August
30, 2022
                                                            CIK No. 0001916331

       Dear Ms. Siu:

              We have reviewed your 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.

       Form F-1 Submitted August 30, 2022

       Prospectus Cover Page, page i

   1.                                                   Clearly disclose how
you will refer to the holding company, subsidiaries, and other
                                                        entities 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. Refrain from using terms such as    we    or    our    when
                                                        describing activities
or functions of a subsidiary or other entity. For example, disclose, if
                                                        true, that your
subsidiaries and/or other entities conduct operations in China, that the other
                                                        entity is consolidated
for accounting purposes but is not an entity in which you own
 Eva Yuk Yin Siu
FirstName LastNameEva
            InternationalYuk YinHoldings
                                 Siu
Neo-Concept               Group           Ltd
Comapany 26,
September NameNeo-Concept
              2022           International Group Holdings Ltd
September
Page 2    26, 2022 Page 2
FirstName LastName
         equity, and that the holding company does not conduct operations.
Disclose clearly the
         entity (including the domicile) in which investors are purchasing an
interest.
Prospectus Summary, page 1

2.       Provide a clear description of how cash is transferred through your
organization. Disclose
         your intentions to distribute earnings or settle amounts owed under
your operating
         structure. Quantify any cash flows and transfers of other assets by
type that have occurred
         between the holding company and its subsidiaries, and direction of
transfer. Quantify any
         dividends or distributions that a subsidiary has made to the holding
company and which
         entity made such transfer, and their tax consequences. Similarly
quantify dividends or
         distributions made to U.S. investors, the source, and their 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, 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 as well as the
ability to settle
         amounts owed under applicable agreements.
Risk Factors
Our business is in direct competition with NCH, an affiliated company, page 13

3.       Please revise your disclosure to specify the definition of "Neo
Concept Group."
We rely on two principal suppliers for supplies of raw materials, manufacturing
services and
logistics services, page 25

4.       We note your risk factor that your principal suppliers "terms of
services [...] may be
         susceptible to fluctuations with regard to pricing, timing and
quality." Please update this
         risk factor if recent inflationary pressures have materially affected
your operations. In this
         regard, identify the types of inflationary pressures you are facing
and how your business
         has been affected.
Dilution, page 47

5.       You indicate, in the first introductory paragraph, that net tangible
book value represents
         "total net tangible assets less intangible assets (right-of-use assets
and intangible assets)."
         The parenthetical reference to right of use assets and intangible
assets appears to be
         unnecessary since you have no right of use assets at December 31, 2021
and the reference
         to intangible assets is repetitive. Please remove the parenthetical
disclosure or advise us.
Exclusive Territory and Non-Competition Agreement, page 52

6.       We note your disclosure that the Company and the Parent Group have
entered into an
         Exclusive Territory and Non-Competition Agreement. Please provide
additional
         disclosure detailing what countries/regions constitute the "Protected
Territories," as well
 Eva Yuk Yin Siu
FirstName LastNameEva
            InternationalYuk YinHoldings
                                 Siu
Neo-Concept               Group           Ltd
Comapany 26,
September NameNeo-Concept
              2022           International Group Holdings Ltd
September
Page 3    26, 2022 Page 3
FirstName LastName
         as the specific "businesses currently conducted by us through our
Operating Subsidiaries
         in North America and Europe," that NCH has agreed to not compete with.
Liquidity and Capital Resources
Cash Flow Sufficiency, page 66

7.       Please provide more robust disclosure explaining how you intend to
meet your cash flow
         requirements. In this regard, discuss your plan to meet your debt
obligations and
         operating needs as it appears your obligations that will come due in
twelve months or
         less are greater than cash generated from operations in the periods
presented.
Business
Overview, page 68

8.       We note your disclosure on page 74 that your customer base in Canada
and the U.S.
         accounts for over 95% of total revenues, with one Canadian based
retailer contributing
         approximately 94.5% of revenues. We note, however, that your
disclosure in this section
         appears to give equal weight to your European market and the licensed
brand in the
         UK. Please therefore revise your disclosure in this section to more
specifically explain
         your operations in Canada and the U.S. In addition, given your
apparent dependence on
         one single Canadian retailer, please revise your disclosure throughout
to provide an
         accurate and current discussion of the company's market, focus and
business operations.
Notes to the Consolidated Financial Statements
Organization and reorganization, page F-7

9.       We note your disclosure indicating that the reorganization is
considered a recapitalization
         of entitles under common control. Please expand to discuss the nature
of this accounting
         treatment, including, if true, that the historical carrying values of
the relevant entities will
         be carried forward with no step up in basis of net assets or
recognition of goodwill. Refer
         to ASC 805-50-50-3. Additionally, please disclose how you accounted
for the distribution
         and disposal of Neo-Concept NY in December 2021.
2. Summary of Significant Accounting Policies and Practices, page F-8

10.      Your liquidity discussion on page 63 indicates that you were able to
speed up your
         collection of accounts receivable by way of factoring to strengthen
your cash position and
         liquidity management. Please revise the notes to financial statements
to describe
         your factoring arrangements and how you account for them.
Revenue Recognition, page F-12

11.      You disclose that you derive revenue principally from sales of
private-labelled apparel
         products and sales of own-branded apparel products in your retail
stores. However, your
         disclosures on page 1 indicate that you offer a full suite of services
in the apparel supply
         chain, including market trend analysis, product design and
development, raw material
 Eva Yuk Yin Siu
Neo-Concept International Group Holdings Ltd
September 26, 2022
Page 4
         sourcing, production and quality controls and logistics management.
Please revise this
         note to disclose how you account for the revenue generated from each
of the products
         and services you offer to your customers.
12.      You disclose here that the transaction price for sales of
private-labelled apparel products
         does not include variable consideration provisions for right of return
as you do not have a
         sales return policy and no sales return is offered. However, on page
75 you also indicate
         that where quality issues are concerned, you follow up with your
customers on any claims
         or requests for product return, payment refund, rectification or price
discount. Please
         explain to us how these two statements are consistent with each other,
or as appropriate,
         revise to eliminate the inconsistency.
11. Right-Of-Use Assets and Lease Liabilities, page F-20

13.      You disclose that your right-of-use assets and relevant lease
liabilities originated from
         your rented premises in New York by Neo-Concept NY, and were
eliminated upon the
         disposal of Neo-Concept NY in December 2021. We note, however, from
page 26 that as
         of December 31, 2021 you leased three retail store locations in the UK
under operating
         leases. Please revise to disclose how you accounted for these UK
location leases. Explain
         why no related right-of-use assets and lease liabilities were
reflected on your balance sheet
         at December 31 2021.
Exhibit 23.1, page X-1

14.      Please file an updated consent from your independent registered public
accounting firm,
         with your first live filing, that also consents to the firm being
named in the "Experts"
         section of the filing.
General

15.      Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications. Please contact legal
staff associated with the
         review of this filing to discuss how to submit the materials, if any,
to us for review.
       You may contact Mindy Hooker at 202-551-3732 or Martin James at
202-551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alex King at 202-551-8631 or Erin Purnell at 202-551-3454 with any
other questions.



FirstName LastNameEva Yuk Yin Siu                   Sincerely,
Comapany NameNeo-Concept International Group Holdings Ltd
                                                    Division of Corporation
Finance
September 26, 2022 Page 4                           Office of Manufacturing
FirstName LastName