October 1, 2024

Xiaoqiu Zhang
Chief Executive Officer
Park Ha Biological Technology Co., Ltd.
901 & 901-2, Building C
Phase 2, Wuxi International Life Science Innovation Campus
196 Jinghui East Road
Xinwu District, Wuxi, Jiangsu Province
People   s Republic of China 214000

       Re: Park Ha Biological Technology Co., Ltd.
           Amendment No. 1 to Registration Statement on Form F-1
           Filed September 18, 2024
           File No. 333-281783
Dear Xiaoqiu Zhang:

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

       Please respond to this letter by amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments. Unless we
note otherwise,
any references to prior comments are to comments in our September 12, 2024
letter.

Amendment No. 1 to Registration Statement on Form F-1
Prospectus Summary
Our Franchise Model, page 8

1.     We note your revised disclosure on page 2 in response to comment 1,
including that the
       decrease in revenue from franchise fees "was primarily due to a decrease
in the franchise
       fees as a result of (i) a decrease in the number of our franchisees,
(ii) additional franchisee
       incentives such as our offering of discounts on franchise fees to
incentivize renewals, and
       (iii) the change in the franchising model for some of our franchisees,
from regional
       franchisees to single-store franchisees, which led to certain changes in
franchise fees."
       Please revise this section and your description of business beginning on
page 86 to
 October 1, 2024
Page 2

       provide additional detail about your franchise model, including the
types and amount of
       discounts and other incentives you offer to current franchisees for
renewal or to attract
       new franchisees, and, if material, a quantification of historical
discounts or incentives to
       existing franchisees. Please also provide additional detail about the
franchise fees for
       regional compared to singe-store franchisees, including the difference
in fees for these
       two models. In your discussion, clarify the fees received from each type
of model for the
       periods presented in the filing to provide context for your disclosure
that the change in
       model resulted in a decrease in franchise fees for the six months ended
April 30, 2024.
       Finally, please revise your risk factors to discuss the risks, if any,
related to discounts or
       incentives noted in your revised disclosure.
Risk Factors Summary, page 10

2.     We note your revised disclosure in response to prior comment 2. Please
revise your Risk
       Factor Summary section to include the following removed risk factors and
conform the
       cross-references to those present:

             "You may experience difficulties in effecting service of process,
enforcing foreign
           judgments or bringing actions in China against us or our management
named in this
           prospectus based on foreign laws."

             "Our results of operation may be materially and adversely affected
by a change in
           China or the global economy."

             "It may be difficult for overseas shareholders and/or regulators
to conduct cross-
           border investigation in China."

             "Changes in PRC political, economic and governmental policies may
have an adverse
           impact on our business."

             "PRC regulation of loans to and direct investment in PRC entities
by offshore holding
           companies and governmental management of currency conversion may
delay us from
           remitting the proceeds of this offering into China through loans or
additional capital
           contributions to our PRC subsidiaries, thereby diminishing our
ability to fund and
           expand our business."

             "PRC regulations relating to offshore investment activities by PRC
residents may
           limit our PRC subsidiaries    ability to change their registered
capital or distribute
           profits to us or otherwise expose us or our PRC resident beneficial
owners to liability
           and penalties under PRC laws."

             "If the content we produce and distribute through online social
and content platforms,
           or content available on our website, is deemed to violate PRC laws
or regulations, our
           business and results of operations may be materially and adversely
affected."

       Please also include the risk that any actions by the Chinese government
to exert more
 October 1, 2024
Page 3

       oversight and control over offerings that are conducted overseas and/or
foreign
       investment in China-based issuers could significantly limit or
completely hinder your
       ability to offer or continue to offer securities to investors and cause
the value of such
       securities to significantly decline or be worthless.
Exhibits

3.     We note that the opinion of Mourant Ozannes (Cayman) LLP, filed as
Exhibit 5.1,
       assumes that "the Company will have sufficient authorised but unissued
capital to issue
       each Share." Please revise the legal opinion to remove this assumption.
Refer to Section
       II.B.3.a of Staff Legal Bulletin No. 19.
       Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Benjamin Richie at 202-551-7857 or Katherine Bagley at 202-551-2545
with any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Industrial Applications and
                                                             Services
cc:   William S. Rosenstadt