October 4, 2024

Leung Chun Yip
Chief Executive Officer
Everbright Digital Holding Ltd.
Unit 1A, 10/F
C-Bons International Centre
108 Wai Yip Street, Kwun Tong
Hong Kong

       Re: Everbright Digital Holding Ltd.
           Amendment No. 2 to Draft Registration Statement on Form F-1
           Submitted September 16, 2024
           CIK No. 0002024876
Dear Leung Chun Yip:

     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
August 28, 2024 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted September
16, 2024
Risk Factors
Risk Related to Our Business and Industry
We have derived a substantial portion of our revenues from sales..., page 31

1.     We note your response to prior comment 4, including the redaction of the
name of the
       customer, and reissue in part. Specifically, please revise your
disclosure in accordance
       with Item 4.B.6 of Part I of Form 20-F as well as refile Exhibit 10.10
to include the name
       of the customer previously disclosed. In this regard, we note that due
to this exhibit being
       filed without the redaction of its name in the prior round, upon release
of all draft
 October 4, 2024
Page 2

       confidential registration statements, amendments and associated exhibits
and
       correspondence, confidentiality cannot be sought or maintained regarding
this piece of
       information.
Notes to the consolidated financial statements
2. Significant accounting policies
Revenue Recognition, page F-9

2.     We note your disclosure revisions on page F-9 in response to prior
comment 6. Please
       further revise your disclosure to include the requirements in ASC
606-10-50-12(b) and
       50-8 related to the significant payment terms and payments received in
advance of
       recognition.
3.     You state, on page 52, that "[o]n top of the 3D and Augmented reality,
some customers
       would also request other services like design of intellectual property
and websites,
       consultancy and market research; and social media management." Please
clarify your
       policy for allocating the transaction price to performance obligations
when a contract
       contains multiple performance obligations. Refer to ASC 606-10-32-28
through 32-35.
       Please contact Ta Tanisha Meadows at 202-551-3322 or Suying Li at
202-551-3335 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Kate Beukenkamp at 202-551-3861 or Taylor Beech at 202-551-4515 with
any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Yarona L. Yieh