September 5, 2024

Zhen Fan
Chief Executive Officer
Haoxi Health Technology Ltd
Room 801, Tower C, Floor 8
Building 103
Huizhongli, Chaoyang District
Beijing, China

       Re: Haoxi Health Technology Ltd
           Amendment No. 6 to Registration Statement on Form F-1
           Filed August 28, 2024
           File No. 333-280174
Dear Zhen Fan:

     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. Unless we
note otherwise,
any references to prior comments are to comments in our August 26, 2024 letter.

Amendment No. 6 to Registration Statement on Form F-1, Filed August 28, 2024
Exhibits

1.     We note this amendment does not include updated versions of the Series A
warrant, the
       Series B warrant and the warrant agreement (Exhibits 4.3 to 4.5).
However, it would
       appear that changes to the mechanisms of the warrants results in the
warrants described in
       the registration statement no longer aligning to the exhibits included.
Please file updated
       versions of these exhibits.
 September 5, 2024
Page 2
General

2.     We note your response to prior comment 2 and reissue in part. We
acknowledge the
       amended disclosure for the Series B Warrants disclosing that the maximum
number of
       Series B Warrants will be 16,666,667 shares and an amended version of
the formula for
       obtaining that maximum. However, we note that this formula still
includes the Nasdaq
       Minimum Price as an input, which is one of two potential prices. As a
result, it would
       appear that the volume of shares issuable upon exercise of Series B
Warrants could shift
       between which potential price you choose. Please amend your disclosure
so that at
       effectiveness the volume of shares is known, or please provide a
detailed analysis as to
       why the use in part of the Nasdaq Minimum Price is compliant with Rule
430A.
3.     With reference to prior comment 3 in our letter dated August 8, 2024,
please explain why
       you have decided to employ a mechanism that relies on a formula that
uses 20% of the
       Nasdaq Minimum Price.

       Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at
202-551-8071
with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:   Joan Wu