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                              September 22, 2023

       Channing Au
       Chief Financial Officer
       Value Exchange International, Inc.
       Unit 602, Block B, 6 Floor, Shatin Industrial Centre
       5-7 Yuen Shun Circuit
       Shatin, N.T., Hong Kong SAR

                                                        Re: Value Exchange
International, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            File No. 000-53537

       Dear Channing Au:

               We have reviewed your August 25, 2023 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 10-K for Fiscal Year Ended December 31, 2022

       General

   1.                                                   We note your statement
that you reviewed public filings and material contracts as well as
                                                        your representation
relating to the absence of foreign government representation on your
                                                        board of directors in
connection with your required submission under paragraph
                                                        (a). Please
supplementally describe any additional materials that were reviewed and
                                                        explain your diligence
with respect to your representation relating to the absence of
                                                        foreign government
representation on your board of directors. In addition, please tell us
                                                        whether you relied upon
any legal opinions or third party certifications such as affidavits
                                                        as the basis for your
submission.
 Channing Au
Value Exchange International, Inc.
September 22, 2023
Page 2

      Please contact Jennifer Gowetski at 202-551-3401 or Jennifer Thompson at
202-551-
3737 with any questions.



                                                        Sincerely,
FirstName LastNameChanning Au
                                                        Division of Corporation
Finance
Comapany NameValue Exchange International, Inc.
                                                        Disclosure Review
Program
September 22, 2023 Page 2
cc:       Paul Richter
FirstName LastName