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                              December 22, 2022

       Wing Wah Cheng
       Chief Executive Officer
       Samfine Creation Holdings Group Limited
       Flat B, 8/F, Block 4
       Kwun Tong Industrial Centre
       436-446 Kwun Tong Road
       Kwun Tong, Kowloon
       Hong Kong

                                                        Re: Samfine Creation
Holdings Group Limited
                                                            Amendment No. 4 to
Draft Registration Statement on Form F-1
                                                            Submitted December
15, 2022
                                                            CIK No. 0001926792

       Dear Wing Wah Cheng:

             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. 4 to Draft Registration Statement on Form F-1

       Risk Factors
       The market price of our Ordinary Shares may be volatile . . . . , page
43

   1.                                                   Please revise your risk
factor to more fully discuss the risks to investors when investing in
                                                        stock where the price
is changing rapidly. Clearly state that rapid and substantial
                                                        price volatility,
including any stock-run up, may be unrelated to your actual or expected
                                                        operating performance
and financial condition or prospects, making it difficult for
                                                        prospective investors
to assess the rapidly changing value of your stock.
 Wing Wah Cheng
FirstName LastNameWing
                 Holdings Wah  Cheng
Samfine Creation          Group  Limited
Comapany22,
December  NameSamfine
              2022       Creation Holdings Group Limited
December
Page 2    22, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies, Judgments and Estimates, page 67

2.       Refer to the Provision for doubtful accounts, and specifically the
last table for the six
         months ended June 30, 2022 on page 69. As all of your provision for
doubtful accounts of
         HK3,172,238 shown in the second to the last table pertains to gross
accounts receivable
         that are greater than 360 days, it is unclear how in the last table
you arrived at 48.87% and
         6.82% in the last two columns, rather than 100% in each column. Please
revise or advise
         accordingly.
Results of Operations
Six Months ended June 30, 2021 compared to six months ended June 30, 2022, page
71

3.       Please revise your MD&A discussion to address the following:
             Under revenue on page 71, clarify that sales of printed book
product actually
             increased for the six months ended June 30, 2022, as we note you
disclose there was
             a decrease both sales of printed book products and novelty
products, and discuss the
             factors that led to the increase.
             Under allowance for doubtful accounts on page 73, provide an
explanation for
             recording an allowance of HK$878,966 during the six months ended
June 30, 2022
             compared to none in the prior comparable period. Explain if the
reason is attributable
             to one or more customers and also to which accounts receivable
aging category(ies)
             this pertained as of December 31, 2021 or June 30, 2022.
             Under other gain and loss, net on page 74, clarify there was an
increase, rather than
             decrease, of HK213,395 for the six months ended June 30, 2022.
             Under capital expenditures on page 85, reconcile the amounts for
the years ended
             December 31, 2021 and 2020 with the respective amounts disclosed
in the Statements
             of Cash Flows on page F-6.
Related Party Transactions, page 127

4.       We note that your disclosure in this section is current as of June 30,
2022. Please revise to
         indicate that the disclosure is current as of the most recent
practicable date. Refer to Item
         7 of Form 20-F.
Experts, page 156

5.       Please expand this section to also reference the review report issued
by WWC, P.C.
         on your unaudited interim financial statements as of June 30, 2022 and
for the six months
         ended June 30, 2022 and 2021. We note you have included at Exhibit
23.1, a letter from
         WWC, P.C. acknowledging awareness of the inclusion of their report.
Give consideration
         instead to revise this letter as Exhibit 15.1 pursuant to Item
601(b)(15) of Regulation S-K.
         A separate Exhibit 23.1 accountants consent from WWC, P.C. should be
filed with respect
         to their opinion rendered on your audited financial statements
pursuant to Item 601(b)(23)
         of Regulation S-K.
 Wing Wah Cheng
Samfine Creation Holdings Group Limited
December 22, 2022
Page 3
Index to Consolidated Financial Statements, page F-1

6.    If your audited financial statements are older than 12 months prior to
this registration
      statement being declared effective, please be advised, since this is an
initial public
      offering of your ordinary shares, you may be required to provide updated
annual financial
      statements and related disclosures pursuant to Item 8.A.4 of Form 20-F
or, if applicable,
      you should provide the representations required by Instruction 2 to Item
8.A.4 in an
      exhibit to the filing.
Report of Independent Registered Public Accounting Firm, page F-28

7.    Refer to the second paragraph under Results of Review of Interim
Financial Statements.
      Please have your auditors clarify in the first sentence that they
previously audited the
      consolidated balance sheet as of December 31, 2021, and the related
statements of income
      and comprehensive income, equity and cash flows for the year then ended.
In this regard,
      revise the plurality form to instead be singular with respect to the year
December 31,
      2021. In addition, expand the disclosure to clarify the auditor's report
is dated June 1,
      2022, except for Note 2, for which the date is July 13, 2022. Reference
is made to the
      auditor's report on page F-2.
       You may contact Beverly Singleton at 202-551-3328 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Angelini at 202-551-3047 or Erin Purnell at 202-551-3454 with
any other
questions.



                                                          Sincerely,
FirstName LastNameWing Wah Cheng
                                                    Division of Corporation
Finance
Comapany NameSamfine Creation Holdings Group Limited
                                                    Office of Manufacturing
December 22, 2022 Page 3
cc:       Ying Li
FirstName LastName