July 17, 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. 2 to Draft Registration Statement on Form F-1
           Submitted July 3, 2024
           CIK No. 0001958399
Dear Bin Lu:

     We have reviewed your amended draft registration statement and have the
following
comment(s).

        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
March 8, 2024 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1
Capitalization, page 47

1.     We note your updated presentation in response to prior comment 4 and
reissue our
       comment. Please limit the liability section of your capitalization table
to only include your
       short- and long-term bank loans.
 July 17, 2024
Page 2
Business, page 65

2.     We note your updated disclosure in response to prior comment 5 and
reissue our
       comment. As your 2022 revenue percentages disclosed in the table on page
65 still appear
       incorrect, please revise your filing accordingly.
General

3.     We note disclosure on page 52 regarding a shift in your business (with
cubic parking
       garage revenues representing 23% in 2023 compared with 81% in 2022, and
equipment
       structural parts revenues representing 75% in 2023 compared with 16% in
2022).
       Please address the following items:

                Revise the business section to more fully describe your
equipment structural parts
              business, providing an analogous level of detail as provided for
your cubic parking
              garage business. Include, without limitation, discussion
regarding manufacturing,
              marketing and sales, and customers for equipment structural
parts.

                Further describe the    real estate policy regulation
disclosed as the reason for your
              business shift, clarifying whether and how the regulation limits
your cubic parking
              garage business.

                Disclose whether the business shift is expected to be
permanent, temporary, or
              variable from period-to-period, identifying and discussing the
main factors that
              influence your decision to scale operations up or down.

                As appropriate, revise disclosure throughout the prospectus
that presents your
              company as a    smart parking solutions provider    to provide a
more balanced
              description as an equipment structural parts provider.

       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