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                              May 11, 2023

       Kin Chung Chan
       Chairman and Chief Executive Officer
       Reitar Logtech Holdings Ltd
       c/o Unit 801, 8th Floor, Tower 2, The Quayside, 77 Hoi Bun Road
       Kwun Tong, Kowloon, Hong Kong

                                                        Re: Reitar Logtech
Holdings Ltd
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted April 24,
2023
                                                            CIK No. 0001951229

       Dear Kin Chung Chan:

             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. Unless we note otherwise, our references to prior comments are
to comments in our
       March 23, 2023 letter.

       Amendment No. 2 to Draft Registration Statement on Form F-1

       Risk Factors
       "We have identified certain areas of inadequacy in our internal control
over financial
       reporting...", page 28

   1.                                                   We note your response
to comment 3 and revised disclosure here and on page 74. Please
                                                        explain to us your
basis for re-categorizing the identified deficiencies in internal control
                                                        over financial
reporting from    material weaknesses    to    certain areas of inadequacy.
 Kin Chung Chan
Reitar Logtech Holdings Ltd
May 11, 2023
Page 2
Reitar Capital Partners Limited
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies and Practices
Revenue Recognition, page F-35

2.    We note your revised disclosure in response to comment 5. Please revise
further to
      explicitly state that you record the utility fees passed through you from
tenants to lessors
      on a net basis with no related amounts reflected on your income
statements.
Notes to the Unaudited Pro Forma Condensed Consolidated Financial Information
Note 1 - Pro forma adjustments, page F-49

3.    We note your response to our comment 7 and your revisions to your filing.
Specifically,
      you state that the carrying amounts of right-of-use assets and operating
lease liabilities are
      approximate to their respective fair values because it is discounted
using an appropriate
      interest rate. Please clarify how you determined such items are
discounted using an
      appropriate interest rate. In this regard, please clarify how you
determined that the
      interest rate is unchanged from when such items were initially recorded
by Reitar Capital
      Partners Limited. Your response should address, but not be limited to,
any changes in
      external interest rates.
       You may contact Frank Knapp at 202-551-3805 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Maryse Mills-Apenteng at 202-551-3457
with any
other questions.



                                                             Sincerely,
FirstName LastNameKin Chung Chan
                                                             Division of
Corporation Finance
Comapany NameReitar Logtech Holdings Ltd
                                                             Office of Real
Estate & Construction
May 11, 2023 Page 2
cc:       William Ho, Esq.
FirstName LastName