October 4, 2024

Tse Tsz Tun
Chief Executive Officer and Director
Masonglory Ltd
Room 8, 25/F, CRE Centre
889 Cheung Sha Wan
Kowloon, Hong Kong

       Re: Masonglory Ltd
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted August 30, 2024
           CIK No. 0002020228
Dear Tse Tsz Tun:

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

        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
August 24, 2024 letter.

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

1.     We note your revised disclosure in the cover page of resale prospectus
in response to prior
       comment 1. Please also revise the cover page of the IPO prospectus to
clarify that the
       selling stockholders will sell their shares at prevailing market prices
or privately
       negotiated prices after the shares are listed in Nasdaq. Please also
revise the cover page of
       the IPO prospectus to include clear disclosure of order of the
offerings, including when
       shares covered by the resale prospectus may be sold; for instance, if
the selling
       shareholder offering will not commence until after the firm commitment
offering, revise
 October 4, 2024
Page 2

       to so state. Finally, we note that if the application for listing is not
approved, the primary
       offering "may not be completed." To the extent the listing condition may
be waived and
       you may complete the offering without being listed, please revise to
make that clear.
Our Competitive Strengths, page 1

2.     We note your response to prior comment 2. Please revise your summary
section to
       balance your disclosure about your competitive strengths by noting your
reliance on these
       customers and quantify the amount of revenues and accounts receivable
attributable to
       them in the most recently completed fiscal year. In this regard, we note
your revised
       disclosure on page 67 that the aggregate revenue generated by three of
your major
       customers accounted for over 93% of the total revenue generated for the
years ended
       March 31, 2023 and 2024, and that the accounts receivable from such
customers also
       represented 70% of your total assets as of March 31, 2024.
Summary of Key Risks
Risks Relating to our Ordinary Shares, page 8

3.     We note your response to prior comment 6 and your revised disclosure on
page 43. Please
       similarly expand the last summary risk factor on page 9.
Our Customers, page 75

4.     We note your response to prior comment 12. Please revise to fully
identify such
       customers, including their names. Moreover, revise to disclose the
material terms of any
       agreements with these customers.
Related Party Transactions, page 101

5.     We note your response to prior comment 13. Please expand your disclosure
about the
       reorganization with respect to the related party transactions. For
example, we note your
       disclosure on page 2 that "as part of the reorganization for the purpose
of this offering,
       Masonglory acquired, through Masonglory (BVI), all the shares of
Masontech Limited
       from the Controlling Shareholders and became the ultimate holding
company of
       Masonglory (BVI) and the Operating Subsidiary. Subsequently, on June 14,
2024,
       Masonglory allotted and issued 11,499,998 Ordinary Shares, credited as
fully-paid in its
       share capital, to Fung & Tun Limited."
       Please contact Eric McPhee at 202-551-3693 or Mark Rakip at 202-551-3573
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Kibum Park at 202-551-6836 or Mary Beth Breslin at 202-551-3625 with any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Real
Estate & Construction
cc:   Kyle Leung, Esq.