Pitanium Ltd — Regulatory Filings 2025

May 22, 2025

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Pitanium Limited

30F , Gravity , 29 Hing Yip Street,

Kwun Tong , Kowloon , Hong Kong

May 22, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

Attention: Nicholas O’Leary, Esq.

RE :
Registration
Statement on Form F-1
( File
No . 333 - 284998) (the “ Registration Statement ”)

Dear Mr. O’Leary:

The Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4: 15 p.m. on May 27, 2025, or as soon thereafter as practicable.

The Company hereby acknowledges that:

● Should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

● The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

● The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[Signature page follows]

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| Very
truly yours, | |
| --- | --- |
| PITANIUM
LIMITED | |
| By: | /s/
Ying Yeung Wong |
| Name: | Ying
Yeung Wong |
| Title: | Chief
Executive Officer |

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