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                              January 23, 2024

       Yuyang Cui
       Chief Executive Officer
       GMTech Inc.
       45 Rockefeller Plaza, 21F
       New York, New York 10111

                                                        Re: GMTech Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed January 16,
2024
                                                            File No. 333-275887

       Dear Yuyang Cui:

            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 January 2, 2024
letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Description of Business, page 18

   1.                                                   Please expand your
disclosure to provide a detailed description of the AI-Development
                                                        Tool you intend to
develop.
       Notes to Consolidated Financial Statements, page F-8

   2.                                                   We note your response
to prior comment 11, specifically bullet point 2 as it relates to your
                                                        principal verses agent
considerations. Further, we note your disclosure on page 20 that 3
                                                        of your 4 service
contracts involved third-party IT service providers. In addition, we note
                                                        your disclosure on page
F-8 that you pay a commission to an agent for sales obtained. We
                                                        repeat our prior
comment to tell us and disclose in sufficient detail your principal verses
                                                        agent considerations
for these contracts. Refer to FASB ASC 606-10-55-36 through 55-
                                                        40, and specifically
55-38.
 Yuyang Cui
GMTech Inc.
January 23, 2024
Page 2
Exhibits to Registration Statement, page II-2

3.     Please file your auditor's consent in the next amendment.
       Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at
202-551-3488 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alexandra Barone at 202-551-8816 or Jeff Kauten at 202-551-3447 with
any other
questions.



                                                            Sincerely,
FirstName LastNameYuyang Cui
                                                            Division of
Corporation Finance
Comapany NameGMTech Inc.
                                                            Office of
Technology
January 23, 2024 Page 2
cc:       Vic Devlaeminck
FirstName LastName