August 8, 2024

Liu Xiaohua
Chief Executive Officer
Star Fashion Culture Holdings Limited
12F, No. 611, Sishui Road
Huli District, Xiamen
People   s Republic of China

       Re: Star Fashion Culture Holdings Limited
           Amendment No. 3 to Registration Statement on Form F-1
           Filed August 2, 2024
           File No. 333-280198
Dear Liu Xiaohua:

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

       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.

Amendment No. 3 to Registration Statement on Form F-1 filed August 2, 2024
Cover Page

1.     Revise to verify your disclosure regarding estimated cash expenses for
the offering, as the
       cover page currently states, "We expect our total cash expenses...to be
approximately
       $[4.50]..."
Underwriting, page 121

2.     Please revise to remove the reference to WestPark Capital, Inc. and to
eliminate
       inconsistencies between the disclosure in this section and the updated
form of
       underwriting agreement on file as Exhibit 1.1 to the registration
statement. For example,
       Section 1.1.1(i) of the form of underwriting agreement states that the
company will issue
 August 8, 2024
Page 2

       "an aggregate of 2,500,000" Class A ordinary shares, and Section 3.11
states that $50,000
       of accountable expenses has been paid, while page 121 of the prospectus
states that
       $70,000 has been paid.
       Please contact Tony Watson at 202-551-3318 or Joel Parker at
202-551-3651 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Rebekah Reed at 202-551-5332 or Dietrich King at 202-551-8071 with any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Jeffrey Yeung