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                            October 7, 2021

       Tin Lung David Leung
       President and Chief Executive Officer
       New Momentum Corp.
       150 Cecil Street, #08-01
       Singapore 069543

                                                        Re: New Momentum Corp.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed September 27,
2021
                                                            File No. 333-257302

       Dear Mr. Leung:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Amendment No. 2 to Registration Statement on Form S-1 filed September
27, 2021

       Prospectus Cover Page, page 3

   1.                                                   We note your response
to comment 1, as well as your amended disclosure regarding the
                                                        "risks associated with
having the majority of [y]our operations in Hong Kong . . . ."
                                                        Please also disclose
that you are based in Hong Kong, as you disclose on page 7.
       Emerging risks for us being based in and having the majority of our
operations in Hong Kong,
       China., page 7

   2.                                                   We note your response
to comment 2, as well as your amended disclosure that the PRC
                                                        government "may exert
more control over offerings conducted overseas and/or foreign
                                                        investment in Hong
Kong-based issuers, which could result in a material change in our
                                                        operations and/or the
value of our common stock." Please also specifically address the
 Tin Lung David Leung
New Momentum Corp.
October 7, 2021
Page 2
      risk that such exertion of control could significantly limit or
completely hinder your
      ability to offer or continue to offer securities to investors and cause
the value of such
      securities to significantly decline or be worthless.
3.    We note your amended disclosure that "Hong Kong   s legislature adopts
laws that are
      congruent with PRC government policies, laws and regulations" and that
"legal
      developments in the PRC will significantly affect [y]our business . . .
.." Please
      specifically also address the risk arising from the uncertainty arising
from the possible
      enforcement of China's laws in Hong Kong, including the recent
implementation of the
      National Security Law in Hong Kong.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Brian Fetterolf at 202-551-6613 or Dietrich King at
202-551-8071 if
you have any questions.



                                                             Sincerely,
FirstName LastNameTin Lung David Leung
                                                             Division of
Corporation Finance
Comapany NameNew Momentum Corp.
                                                             Office of Trade &
Services
October 7, 2021 Page 2
cc:       Thomas E. Puzzo, Counsel
FirstName LastName