August 1, 2022
VIA EDGAR
Division of Corporation Finance
Office of Manufacturing
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE: Graphex Group Limited
Registration Statement on Form F-1/A
Amendment No. 6 filed July 25, 2022
Registration No. 333-263330
Ladies and Gentlemen:
On behalf of our client, Graphex Group Limited, a Cayman Islands exempted company (the “Company”), we advise the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that the Company has filed an amendment to the Company’s Registration Statement on Form F-1 referred to above (the “Registration Statement”) on even date of this letter. The Amendment reflects updated disclosure regarding the use of the net proceeds of the offering under “Use of Proceeds” section and provides certain additional exhibits.
Please do not hesitate to contact me at rmorris@wilsonwilliams.com, if you have any questions regarding the foregoing or if I can provide any additional information.
Very truly yours,
| /s/ Richard M. Morris | |
| Richard M. Morris, Partner |
Enclosure
cc: Andross Chan