August 26, 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. 5 to Registration Statement on Form F-1
           Filed August 12, 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 8, 2024 letter.

Amendment No. 5 to Registration Statement on Form F-1 filed August 12, 2024
Risk Factors
Risk Related to this Offering and the Trading Market
You will experience immediate and substantial dilution in the net tangible book
value of Class A
Ordinary Shares purchased. The existing..., page 54

1.     We note your response to prior comment 2, and we reissue it in part.
Please update the
       dilution risk factor with as much specificity as possible. In this
regard, we note the risk
       factor still categorizes dilution as potential rather that likely.
General

2.     We note your response to prior comment 4, and we reissue it in part. If
you intend to rely
 August 26, 2024
Page 2

       on Rule 430A, please disclose a fixed number of securities for each
class of security
       included in the registered transaction such that such numbers are in the
registration
       statement at the time of effectiveness. In this regard, we note it
appears the number of
       shares underlying the Series B warrants will not be known until after
the registration
       statement is effective. Please refer Question 227.02 of our Securities
Act Rules
       Compliance and Disclosure Interpretations.
       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