| Winvest Group Ltd. | 50 West Liberty Street, Suite 880 Reno, NV 89501 |
July 12, 2023
Via Edgar
United State Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, DC 20549
| Attention: | Lyn Shenk |
Doug Jones
Cara Wirth
Dietrich King
Re: Winvest Group Ltd
Amendment No. 6 to Registration Statement on Form S-1
Filed June 28, 2023
File No. 333-267006
Dear Sir or Madam:
Winvest Group Ltd. (the “Company”) is hereby responding to your recent review letter addressed to Jeffrey Wong Kah Mun, Chief Executive Officer of the Company, dated July 6, 2023 (the “SEC Letter”). We are filing Amendment No. 7 to our Form S-1/A (the “Amendment”) in response. This response letter addresses the concern you have expressed. The following numbered response correspond to the comment number in the SEC Letter.
Amendment No. 6 to Registration Statement on Form S-1 Filed June 28, 2023
Certain Relationships and Related Transactions, page 52
1. We note your amended disclosure in response to comment 5, and we reissue it in part. Please revise to include the approximate dollar value of the full amount initially loaned to the company by each related party for the periods presented. Please refer to Item 404(d)(1) of Regulation S-K and Item 404(a)(3) of Regulation S-K.
We have added the dollar amounts loaned for each applicable period.
Please direct your correspondence regarding this matter to the undersigned.
Very truly yours,
/s/ Jeffrey Wong Kah Mun
Jeffrey Wong Kah Mun
