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                              December 13, 2022

       Guy Adrian Robertson
       Chief Executive Officer and Director
       Fitell Corporation
       23-25 Mangrove Lane
       Taren Point, NSW 2229
       Australia

                                                        Re: Fitell Corporation
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed November 29,
2022
                                                            File No. 333-267778

       Dear Guy Adrian Robertson:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Amendment No. 1 to Registration Statement on Form F-1 filed November 29,
2022

       Cover Page

   1.                                                   We note your disclosure
on page 61 about beneficial ownership, including the percentage
                                                        of votes held after
this offering. Please disclose on the cover page the percentage
                                                        ownership of Jieting
Zhao after the offering and the ability to control decisions to be made
                                                        by stockholders.
   2.                                                   With a view toward
disclosure, please tell us whether you will be a controlled company
                                                        under applicable
exchange rules, and, if so, whether that status creates material risks.
 Guy Adrian Robertson
FirstName  LastNameGuy Adrian Robertson
Fitell Corporation
Comapany13,
December   NameFitell
               2022 Corporation
December
Page  2    13, 2022 Page 2
FirstName LastName
Risk Factors, page 14

3.       We note recent instances of extreme stock price run-ups followed by
rapid price declines
         and stock price volatility seemingly unrelated to company performance
following a
         number of recent initial public offerings, particularly among
companies with relatively
         smaller public floats. Revise to include a separate risk factor
addressing the potential for
         rapid and substantial price volatility and any known factors
particular to your offering that
         may add to this risk and discuss the risks to investors when investing
in stock where the
         price is changing rapidly. Clearly state that such 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.
Recent Sales of Unregistered Securities, page II-1

4.       Please disclose the consideration received by you for each issuance of
securities disclosed
         in this section. See Item 701(c) of Regulation S-K.
Exhibits

5.       In Exhibit 5.1, please have counsel revise to remove assumptions that
go to material facts
         that support the opinion, such as Assumption 2(h) which appears to
assume that you have
         sufficient authorized shares.
6.       Please have counsel revise its opinion to remove this assumption or
tell us why they
         believe Assumption 2(k) in Exhibit 5.1 is appropriate.

       You may contact Andi Carpenter, Staff Accountant, at 202-551-3645 or
Andrew Blume,
Senior Accountant, at 202-551-3254 if you have questions regarding comments on
the financial
statements and related matters. Please contact Thomas Jones, Staff Attorney, at
202-551-3602 or
Jay Ingram, Legal Branch Chief, at 202-551-3397 with any other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing
cc:      Mark E. Crone, Esq.