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                            March 8, 2024

       Bin Lu
       Chief Executive Officer
       Huachen AI Parking Management Technology Holding Co., Ltd
       No.1018 Haihe Road, Dushangang Town
       Pinghu City, Jiaxing
       Zhejiang Province, China 314205

                                                        Re: Huachen AI Parking
Management Technology Holding Co., Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted March 1,
2024
                                                            CIK No. 0001958399

       Dear Bin Lu:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              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 a comment applies 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 this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional
       comments. Unless we note otherwise, any references to prior comments are
to comments in our
       January 12, 2024 letter.

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

       Cover Page

   1.                                                   We note your response
to our prior comment 2 and reissue in part. Please revise your
                                                        cover page disclosure
to clearly identify your ownership percentage of each PRC
                                                        subsidiary.
 Bin Lu
FirstName
Huachen AILastNameBin  Lu
            Parking Management Technology Holding Co., Ltd
Comapany
March      NameHuachen AI Parking Management Technology Holding Co., Ltd
       8, 2024
March2 8, 2024 Page 2
Page
FirstName LastName
Summary of Risk Factors, page 6

2.       We note your response to our prior comment 6 and reissue in part. In
your Summary of
         Risk Factors, describe the risk that the Chinese government may exert
more control over
         offerings conducted overseas and/or foreign investment in China-based
issuers, which
         could result in a material change in your operations and/or the value
of the securities you
         are registering for sale.
Risk Factors, page 17

3.       We note your response to our prior comment 8. Please include this
information in your
         risk factor disclosure and the section titled "Impact of the COVID-19
Pandemic on the
         Operations and Financial Performance" on page 51. Your disclosure
should describe the
         specific impacts of COVID-19 on your business and results of
operations to date, rather
         than presenting such risks as hypothetical, and include quantification
of amounts where
         possible.
Capitalization, page 47

4.       We note your updated presentation in response to prior comment 12 and
reissue the
         comment in part. Please revise the liabilities line items to only
present your short- and
         long-term indebtedness, broken down by respective classifications
using the same
         captions shown on your balance sheet. Ensure that the revised
subtotals are appropriately
         calculated.
Business, page 65

5.       Data presented in the revenue by product category table on page 65
does not appear
         consistent with the data presented in the table on page F-14. Please
revise your disclosures
         as necessary.
6.       We note your response to our prior comment 17 and reissue it in part.
Please revise the
         introductory text to the revenue ratio tables on pages 75 and 77 to
more clearly describe
         what these tables represent.
Growth Strategies, page 68

7.       We note your response to our prior comment 15. Please revise to
clarify the reference to
         "collaborating" with the external R&D team as well as the charging
station and solar panel
         companies. More fully describe the material terms of your arrangements
with such parties,
         including who will hold ownership and intellectual property rights,
and any ongoing
         obligations or liabilities.
 Bin Lu
FirstName
Huachen AILastNameBin  Lu
            Parking Management Technology Holding Co., Ltd
Comapany
March      NameHuachen AI Parking Management Technology Holding Co., Ltd
       8, 2024
March3 8, 2024 Page 3
Page
FirstName LastName
Notes to Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue recognition
Maintenance services income, page F-13

8.       You state on page F-14 that you consider the sale of products and
services as a single
         performance obligation. Please explain to us how you considered the
guidance in ASC
         606-10-25-19 through 25-21 in reaching your conclusion. In addition,
tell us how your
         conclusion is consistent with the timing of revenue recognition
related to your equipment
         structural parts, cubic parking garages and maintenance services
disclosed in the filing. In
         particular, we note your disclosure on page F-13 that "all maintenance
services were
         separated with the product sales." Ensure you revise your disclosures
for clarity.

       Please contact SiSi Cheng at 202-551-5004 or Andrew Blume at
202-551-3254 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Bradley Ecker at 202-551-4985 or Jennifer Angelini at 202-551-3047 with
any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing