November 26, 2019

Fong Kheong
Chief Executive Officer
Phoenix Plus Corp.
17/F, The Workstation, 43-45, Lyndhurst Terrace
Central, Hong Kong

       Re: Phoenix Plus Corp.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed November 12, 2019
           File No. 333-233778

Dear Mr. Kheong:

      We have reviewed your amended registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our October 31,
2019 letter.

Amendment no. 2 to Form S-1 filed November 12, 2019

Major Contracts, page 18

1.     Please file your agreements with Rooframes Metal Tech Sdn Bhd and WWB
Corporation
       as exhibits to your registration statement. Refer to Item 601(b)(10) of
Regulation S-K.
Solar Power System Design and Installation, page 18

2.     Please revise to complete your disclosure in the third paragraph.

       You may contact Tracie Mariner (Staff Accountant) at (202) 551-3744 or
Terence
O'Brien (Accounting Branch Chief) at (202) 551-3355 if you have questions
regarding
comments on the financial statements and related matters. Please contact Sherry
Haywood (Staff
 Fong Kheong
Phoenix Plus Corp.
November 26, 2019
Page 2

Attorney) at (202) 551-3345 or Asia Timmons-Pierce (Special Counsel) at (202)
551-3754 with
any other questions.



FirstName LastNameFong Kheong                            Sincerely,
Comapany NamePhoenix Plus Corp.
                                                         Division of
Corporation Finance
November 26, 2019 Page 2                                 Office of
Manufacturing
FirstName LastName