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                            March 1, 2024

       Hoi Lung Chan
       Chief Executive Officer
       Mint Inc Ltd
       503 Park Tower, 15 Austin Road
       Tsim Sha Tsui, Kowloon, Hong Kong


                                                        Re: Mint Inc Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted February
6, 2024
                                                            File No. 377-07022

       Dear Hoi Lung Chan:

            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
       January 23, 2024 letter.

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

       Cover Page

   1.                                                   We note your revised
disclosure pursuant to comment 10 that no dividends or distributions
                                                        were made by your
subsidiaries or by Mint. Please further revise to disclose whether any
                                                        payments (including
transfers, capital contributions and loans) have been made by the
                                                        holding company to the
operating subsidiary and/or your subsidiaries, or by the operating
                                                        subsidiary to the
holding company and/or your subsidiaries. If so, quantify such payments.
                                                        Also revise to state,
if true, that the operating subsidiary's payment of dividends to
                                                        shareholders was
conducted through CKL and Mint (given the process set forth in section
                                                        (ii) of the 24th
paragraph of the cover page). This comment applies to the cover page,
 Hoi Lung Chan
Mint Inc Ltd
March 1, 2024
Page 2
      prospectus summary and cover page of the resale prospectus, as
appropriate.
2.    We note your response to comment 11. Please further revise your
disclosure here and
      throughout the filing as appropriate, including on the resale prospectus
cover page, to
      address the fact that, to the extent assets in the business are in Hong
Kong or a Hong Kong
      entity, the assets may not be available for other use outside of Hong
Kong due to
      interventions in or the imposition of restrictions and limitations on the
ability of you or
      your subsidiaries by the PRC government to transfer assets. On the cover
pages, provide
      cross-references to these other discussions.
3.    We note your disclosure that "the legal and operational risks associated
with operating in
      Mainland China may also apply to our operations in Hong Kong" (emphasis
added). Here,
      on pages 13 and 30, and in the accompanying resale prospectus, please
revise this
      language to state that the legal and operational risks associated with
operating in Mainland
      China do apply to your operations in Hong Kong.
Index to Consolidated Financial Statements, page F-1

4.    Please update your financial statements and corresponding financial
information
      throughout the filing to comply with Item 8.A.5 of Form 20-F.
       Please contact Abe Friedman at 202-551-8298 or Rufus Decker at
202-551-3769 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any
other
questions.



                                                            Sincerely,
FirstName LastNameHoi Lung Chan
                                                            Division of
Corporation Finance
Comapany NameMint Inc Ltd
                                                            Office of Trade &
Services
March 1, 2024 Page 2
cc:       Jason Ye
FirstName LastName