Exhibit 5.2

Partners:

Wilbert NEO, Joyce S.C. NG, Arthur J. CHAN, Kelvin K.H. SIU

Your reference:

Our reference: WN/24053

[Date]

BY EMAIL AND BY POST

Ultra High Point Holdings Limited

Harneys Fiduciary (Cayman) Limited,

4^th Floor, Harbour Place,

103 South Church Street,

P.O. Box 10240,

Grand Cayman KY1-1002, Cayman Islands

Strictly Private and Confidential

Dear Sirs

Re: Ultra High Point Limited (“Ultra High Point”), Grandwon International Limited (“Grandwon”), Sun Pacific Link Limited (“Sun Pacific”), Thingsocket Solutions Limited (“Thingsocket”) and Clinic First Limited (“Clinic First”) (collectively, the “Companies”)

We are a firm of lawyers qualified to practise law in the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). We have been requested by Ultra High Point Holdings Limited (“Listco”) to provide a legal opinion on the Companies in relation to the proposed listing of the shares of the Listco on the Nasdaq Capital Market.

Please note that unless the context requires otherwise or the contrary is stated, all references to dollars in this opinion shall mean Hong Kong dollars.

We have been asked to provide this legal opinion on the laws of Hong Kong to covering various aspects concerning the each of the Companies, including, among others, certain corporate matters, licence, insurance, litigation (including winding-up proceedings), employment, tax filing and compliance with Hong Kong laws of each of the Companies from 1 April 2023 up to 30 June 2025 (the “Track Record Period”).

We are qualified to advise on matters of Hong Kong law and our opinion relates solely to Hong Kong law in force as at the date hereof and as currently applied by the Hong Kong courts and relevant authorities in Hong Kong. We have made no investigation of the laws of any other jurisdiction, and we do not express or imply any opinion as to any other law. We express no opinion as to matters of fact and express no opinion with respect to the commercial terms of the arrangement and transactions being the subject of this opinion. If a question arises in relation to a cross-border transaction, it may not be the Hong Kong courts which decide that question and Hong Kong law may not be used to settle it. We express no opinion on, and have taken no account of, the laws of any jurisdiction other than Hong Kong.  In particular, we express no opinion on the effect of the Transaction Documents.

Our opinion is limited to the matters expressly stated in part E, and it is not to be extended by implication.  In particular, we express no opinion on the accuracy of the assumptions contained in part D.  Each statement which has the effect of limiting our opinion is independent of any other such statement and is not to be impliedly restricted by it.  Paragraph headings are to be ignored when construing this opinion.

We expressly disclaim any obligations to advise you of facts, circumstances, events or developments which we are not aware of and may hereafter be brought to our attention and which would alter, affect or modify the opinion expressed herein.

This opinion is limited to the matters stated herein and does not extend to and is not to be read as extending by implication to any other matter in connection with each of the Companies or otherwise.

For the purpose of preparing this opinion, we have reviewed and examined the documents set out in the Schedule hereto (the “Documents” or “HK Law Documents”). In addition to the Documents, we have reviewed and examined the following:-

(The searches above are collectively referred to herein as the “Searches”.)

This opinion should not be relied upon in any other manner other than for the purpose of giving an opinion to the Companies. Other than the Listco, no other person or entity may use or rely on this opinion and we do not owe a duty of care (whether by contract, tort, equity or otherwise) to any other person in respect of it other than the Listco.

This opinion is not a thorough investigation and review of every aspect of the operations of the Companies, of every term of each contract to which any of the Companies is a party and of every matter, word or representation that is contained or may be deduced from the Documents, and, as such, should not be treated and relied on as revealing or capable of revealing all necessary information and matters, in particular all legal issues and problems to which the Companies may be subject.

We endeavoured to plan our due diligence exercise so that we had a reasonable expectation of detecting any irregularities or unusual items in the Documents, if anything unusual did come to our notice or attention during the course of our review of the Documents which we think should be brought to your attention, we shall draw your attention to it in this opinion.

Our legal review has been undertaken on the following basis:-

Subject to the assumptions and the qualifications as stated in this legal opinion, and based on the register of members of each of the Companies, the register of directors of each of the Companies and the Searches, the particulars of each of the Companies are set out hereinbelow:-

The current corporate structure of Ultra High Point Limited is as follows:

The current corporate structure of Grandwon International Limited is as follows:

The current corporate structure of Sun Pacific Link Limited is as follows:

The current corporate structure of Thingsocket Solutions Limited is as follows:

The current corporate structure of Clinic First Limited is as follows:

Based solely on the Documents, the articles of association were duly registered with the Companies Registry of Hong Kong upon incorporation. The articles of association have not been amended since Ultra High Point’s incorporation.

Subject to the Companies Ordinance (Chapter 622 of the Laws of Hong Kong) (“Companies Ordinance”), the articles of association of Ultra High Point do not contain any unusual provisions that affect the voting rights of its shareholders.

Pursuant to section 11 of the Companies Ordinance, inter alia, a private company must by its articles restrict a member’s right to transfer shares. In this respect, article 2(a) of the articles of association provides that no invitation shall be issued to the public to subscribe for any shares or debentures of Ultra High Point; and article 4 provides that the directors may in their absolute discretion refuse to register the transfer of a share. Accordingly, transfer of shares in Ultra High Point by its shareholders shall be approved by its directors.

Subject to the requirements under the Companies Ordinance, the articles of association of Ultra High Point do not contain any unusual provision that affects the declaration of, or payment of dividends to, shareholders.

Ultra High Point has the corporate power to carry on its business in the manner as currently conducted by it within the scope permitted under their articles of association and business licences, if any.

Based solely on the Documents, the articles of association were duly registered with the Companies Registry of Hong Kong upon incorporation. The articles of association have not been amended since Grandwon’s incorporation.

Subject to the Companies Ordinance, the articles of association of Grandwon do not contain any unusual provisions that affect the voting rights of its shareholders.

Pursuant to section 11 of the Companies Ordinance, inter alia, a private company must by its articles restrict a member’s right to transfer shares. In this respect, article 2(a) of the articles of association provides that no invitation shall be issued to the public to subscribe for any shares or debentures of Grandwon; and article 6 provides that the directors may in their absolute discretion refuse to register the transfer of a share. Accordingly, transfer of shares in Grandwon by its shareholders shall be approved by its directors.

Subject to the requirements under the Companies Ordinance, the articles of association of Grandwon do not contain any unusual provision that affects the declaration of, or payment of dividends to, shareholders.

Grandwon has the corporate power to carry on its business in the manner as currently conducted by it within the scope permitted under their articles of association and business licences, if any.

Based solely on the Documents, the articles of association were duly registered with the Companies Registry of Hong Kong upon incorporation. The articles of association have not been amended since Sun Pacific’s incorporation.

Subject to the Companies Ordinance, the articles of association do not contain any unusual provisions that affect the voting rights of its shareholders.

Pursuant to section 11 of the Companies Ordinance, inter alia, a private company must by its articles restrict a member’s right to transfer shares. In this respect, article 2(1)(c) of the articles of association provides that no invitation shall be issued to the public to subscribe for any shares or debentures of Sun Pacific; and articles 2(2) and 55 provide that the directors may in their absolute discretion refuse to register the transfer of a share. Accordingly, transfer of shares in Sun Pacific by its shareholders shall be approved by its directors.

Subject to the requirements under the Companies Ordinance, the articles of association do not contain any unusual provision that affects the declaration of, or payment of dividends to, shareholders.

Sun Pacific has the corporate power to carry on its business in the manner as currently conducted by it within the scope permitted under their articles of association and business licences, if any.

Based solely on the Documents, the articles of association were duly registered with the Companies Registry of Hong Kong upon incorporation. The articles of association have not been amended since Thingsocket’s incorporation.

Subject to the Companies Ordinance, the articles of association do not contain any unusual provisions that affect the voting rights of its shareholders.

Pursuant to section 11 of the Companies Ordinance, inter alia, a private company must by its articles restrict a member’s right to transfer shares. In this respect, article 8(c) of the articles of association provides that no invitation shall be issued to the public to subscribe for any shares or debentures Thingsocket; and article 36 provides that the directors may in their absolute discretion refuse to register the transfer of a share. Accordingly, transfer of shares in Thingsocket by its shareholders shall be approved by its directors.

Subject to the requirements under the Companies Ordinance, the articles of association do not contain any unusual provision that affects the declaration of, or payment of dividends to, shareholders.

Thingsocket has the corporate power to carry on its business in the manner as currently conducted by it within the scope permitted under their articles of association and business licences, if any.

Based solely on the Documents, the articles of association were duly registered with the Companies Registry of Hong Kong upon incorporation. The articles of association have not been amended since Clinic First’s incorporation.

Subject to the Companies Ordinance, the articles of association do not contain any unusual provisions that affect the voting rights of its shareholders.

Pursuant to section 11 of the Companies Ordinance, inter alia, a private company must by its articles restrict a member’s right to transfer shares. In this respect, article 2(1)(c) of the articles of association provides that no invitation shall be issued to the public to subscribe for any shares or debentures of Clinic First; and articles 2(2) and 55 provide that the directors may in their absolute discretion refuse to register the transfer of a share. Accordingly, transfer of shares in Clinic First by its shareholders shall be approved by its directors.

Subject to the requirements under the Companies Ordinance, the articles of association do not contain any unusual provision that affects the declaration of, or payment of dividends to, shareholders.

Clinic First has the corporate power to carry on its business in the manner as currently conducted by it within the scope permitted under their articles of association and business licences, if any.

Based on the Searches, Ultra High Point is a company with limited liability duly incorporated and validly existing under the laws of Hong Kong and is in continuing registration with the Companies Registry of Hong Kong. Ultra High Point can sue and be sued in its own name in the courts of Hong Kong and under the laws of Hong Kong to the extent that the courts of Hong Kong have or assume jurisdiction and the Hong Kong courts do not exercise their discretion to stay any such proceedings.

Based on the Searches, Grandwon is a company with limited liability duly incorporated and validly existing under the laws of Hong Kong and is in continuing registration with the Companies Registry of Hong Kong. Grandwon can sue and be sued in its own name in the courts of Hong Kong and under the laws of Hong Kong to the extent that the courts of Hong Kong have or assume jurisdiction and the Hong Kong courts do not exercise their discretion to stay any such proceedings.

Based on the Searches, Sun Pacific is a company with limited liability duly incorporated and validly existing under the laws of Hong Kong and is in continuing registration with the Companies Registry of Hong Kong. Sun Pacific can sue and be sued in its own name in the courts of Hong Kong and under the laws of Hong Kong to the extent that the courts of Hong Kong have or assume jurisdiction and the Hong Kong courts do not exercise their discretion to stay any such proceedings.

Based on the Searches, Thingsocket is a company with limited liability duly incorporated and validly existing under the laws of Hong Kong and is in continuing registration with the Companies Registry of Hong Kong. Thingsocket can sue and be sued in its own name in the courts of Hong Kong and under the laws of Hong Kong to the extent that the courts of Hong Kong have or assume jurisdiction and the Hong Kong courts do not exercise their discretion to stay any such proceedings.

Based on the Searches, Clinic First is a company with limited liability duly incorporated and validly existing under the laws of Hong Kong and is in continuing registration with the Companies Registry of Hong Kong. Clinic First can sue and be sued in its own name in the courts of Hong Kong and under the laws of Hong Kong to the extent that the courts of Hong Kong have or assume jurisdiction and the Hong Kong courts do not exercise their discretion to stay any such proceedings.

Based solely on our review of the Documents [and Ultra High Point’s confirmation provided to us], at the commencement of the Track Record Period, Ultra Hight Point was held as to 28% by Mr. Yu Chi Tat Dennis (2,800,000 shares) and 72% by Century (Hong Kong) International Limited (7,200,000 shares). On 21 July 2023, Century (Hong Kong) International Limited transferred its 7,200,000 shares in Ultra High Point to JL Investments Capital Limited. On 24 July 2023, Mr. Yu Chi Tat Dennis transferred his 2,800,000 shares in Ultra High Point to Maxway Enterprises Limited. Also on 24 July 2023, JL Investments Capital Limited transferred its 7,200,000 shares in Ultra High Point to Maxway Enterprises Limited. On 2 May 2025, Maxway Enterprises Limited transferred its entire shareholding in Ultra High Point to CareQuartz Limited. As of the date of this opinion, Ultra High Point is wholly-owned by CareQuartz Limited, a company incorporated in the British Virgin Islands with limited liability.

Based solely on our review of the register of members dated [*] of Ultra High Point, the abovenamed shareholder is the current registered holder and the current legal owner of all the issued shares in Ultra High Point and is entitled to the equity of Ultra High Point and the rights and interests attached thereto.

Based solely on our review of the Documents [and Ultra High Point’s confirmation provided to us], the shareholder’s interest in Ultra High Point is free from any encumbrances such as mortgage, lien, pledge, charge, title retention, right to acquire, security interest, option, pre-emptive or other similar right, right of first refusal, third-party right, instruction or any other encumbrance or condition whatsoever as at the date of this opinion.

[Based solely on Ultra High Point’s confirmation provided to us], Ultra Hight Point as charger has recorded several charges over securities and deposits in favour of The Hongkong and Shanghai Baking Corporation Limited.

Based solely on our review of the Documents, there is only one class of shares for Ultra High Point, i.e. ordinary shares with the same voting rights. There is no nominee, voting or trust arrangements in relation to the shares of Ultra High Point.

Based solely on our review of the Documents [and Grandwon’s confirmation provided to us], at the commencement of the Track Record Period, Grandwon was wholly-owned by Mr. Yu Chi Tat Dennis. On 20 March 2024, Mr. Yu Chi Tat Dennis transferred his entire 10,000 shares in Grandwon to Mr. Kwan Wai Lim. On 27 March 2024, Mr. Kwan Wai Lim transferred his entire 10,000 shares in Grandwon to Ultra High Point. As of the date of this opinion, Grandwon is wholly-owned by Ultra High Point.

Based solely on our review of the register of members dated [*] of Grandwon, the abovenamed shareholder is the current registered holder and the current legal owner of all the issued shares in Grandwon and is entitled to the equity of Grandwon and the rights and interests attached thereto.

[Based solely on Grandwon’s confirmation provided to us], the shareholder’s interest in Grandwon is free from any encumbrances such as mortgage, lien, pledge, charge, title retention, right to acquire, security interest, option, pre-emptive or other similar right, right of first refusal, third-party right, instruction or any other encumbrance or condition whatsoever as at the date of this opinion.

Based solely on our review of the Documents, there is only one class of shares for Grandwon, i.e. ordinary shares with the same voting rights. There is no nominee, voting or trust arrangements in relation to the shares of Grandwon.

Based solely on our review of the Documents [and Sun Pacific’s confirmation provided to us], throughout the Track Record Period, Sun Pacific was wholly-owned by Ultra High Point. As of the date of this opinion, Sun Pacific is wholly-owned by Ultra High Point.

Based solely on our review of the register of members dated [*] of Sun Pacific, the abovenamed shareholder is the current registered holder and the current legal owner of all the issued shares in Sun Pacific and is entitled to the equity of Sun Pacific and the rights and interests attached thereto.

Based solely on Sun Pacific’s confirmation provided to us], the shareholder’s interest in Sun Pacific is free from any encumbrances such as mortgage, lien, pledge, charge, title retention, right to acquire, security interest, option, pre-emptive or other similar right, right of first refusal, third-party right, instruction or any other encumbrance or condition whatsoever as at the date of this opinion.

Based solely on our review of the Documents, there is only one class of shares for Sun Pacific, i.e. ordinary shares with the same voting rights. There is no nominee, voting or trust arrangements in relation to the shares of Sun Pacific.

Based solely on our review of the Documents [and Thingsocket’s confirmation provided to us], at the commencement of the Track Record Period, Thingsocket was wholly-owned by Future Dimension Holdings Limited, a company incorporated in the British Virgin Islands. On 14 July 2023, Future Dimension Holdings Limited transferred its 98,000 shares to Maxway Enterprises Limited. On 28 March 2024, Future Dimension Holdings Limited transferred its remaining 102,000 shares in Thingsocket to Ultra High Point. As of the date of this opinion, Thingsocket is owned as to 49% by Maxway Enterprises Limited and 51% by Ultra High Point.

Based solely on our review of the register of members dated [*] of Thingsocket, the abovenamed shareholders are the current registered holders and the current legal owners of all the issued shares in Thingsocket and are entitled to the equity of Thingsocket and the rights and interests attached thereto.

[Based solely on Thingsocket’s confirmation provided to us], the shareholders’ interest in Thingsocket is free from any encumbrances such as mortgage, lien, pledge, charge, title retention, right to acquire, security interest, option, pre-emptive or other similar right, right of first refusal, third-party right, instruction or any other encumbrance or condition whatsoever as at the date of this opinion.

Based solely on our review of the Documents, there is only one class of shares for Thingsocket, i.e. ordinary shares with the same voting rights. There is no nominee, voting or trust arrangements in relation to the shares of Thingsocket.

Based solely on the Documents and [Ultra High Points’s Confirmation], save as disclosed in the prospectus to be issued by the Listco, the parent company of the Companies, in relation to its proposed listing on the Nasdaq Capital Market, no other dividends have been declared or made by any of the Companies during the Track Record Period. Based on the articles of association of each of the Companies, none of them is currently prohibited from paying or declaring any dividends or other distribution or any withholding tax.

Under Hong Kong laws, all dividends and other distributions declared and payable on the shares of the company in accordance with the Companies Ordinance may be paid or distributed to holders of such shares, and such dividends and other distribution made to holders of such shares are, as of the date hereof, not subject to withholding or other taxes and are otherwise free and clear of any other duty, withholding or deduction under the laws of Hong Kong, and may be paid without obtaining any approval from any governmental authority in Hong Kong. Save and except that a distribution may only be made by each of the Companies out of profits in accordance with the Companies Ordinance and the articles of association, there is no general restriction against payment of dividends, making of distributions, repayment of loans, or transfer of property and assets to any third party by each of the Companies under the laws of Hong Kong or the articles of association. Dividends or distributions may be paid in Hong Kong dollars and may be converted into other foreign currency and transferred out of Hong Kong. There is no exchange control legislation under Hong Kong laws.

Based solely on our review the register of charges of Ultra High Point, the Searches and [Ultra High Point’s confirmation] provided to us, there are registered charges over the receivables of Ultra High Point in favour of The Hongkong and Shanghai Banking Corporation Limited.

Based solely on our review the register of charges of Grandwon, the Searches and [Grandwon’s confirmation] provided to us, there is no registered charges over the securities or assets of Grandwon.

Based solely on our review the register of charges of Sun Pacific, the Searches and [Sun Pacific’s confirmation] provided to us, there is no registered charges over the securities or assets of Sun Pacific.

Based solely on our review the register of charges of Thingsocket, the Searches and [Thingsocket’s confirmation] provided to us, there is no registered charges over the securities or assets of Thingsocket.

Ultra High Point has obtained the following business registration certificates during the Track Record Period for its business carried out in Hong Kong. Details of the business registration certificates during the Track Record Period are as follows:

Based solely on our review of the Documents, save for the business registration in accordance with the Business Registration Ordinance (Chapter 310 of the Laws of Hong Kong) (“Business Registration Ordinance”), with which Ultra High Point has duly complied in all material respects, Ultra High Point is not required to obtain any other material permit, licence or approval in Hong Kong in order to engage in the provision of system and solution and consultancy businesses.

Based solely on our review of the Documents, the current business registration certificate covering the period from 6 April 2024 to 5 April 2025 is valid and has not expired, been varied or revoked and remains in full force and effect.

Grandwon has obtained the following business registration certificates during the Track Record Period for its business carried out in Hong Kong. Details of the business registration certificates during the Track Record Period are as follows:

Based solely on our review of the Documents, save for the business registration in accordance with the Business Registration Ordinance, with which Grandwon has duly complied in all material respects, Grandwon is not required to obtain any other material permit, licence or approval in Hong Kong in order to engage in the provision of trading of electronic products and provision of services.

Based solely on our review of the Documents, the current business registration certificate covering the period from 23 March 2024 to 22 March 2026 is valid and has not expired, been varied or revoked and remains in full force and effect.

Sun Pacific has obtained the following business registration certificates during the Track Record Period for its business carried out in Hong Kong. Details of the business registration certificates during the Track Record Period are as follows:

Based solely on our review of the Documents, save for the business registration in accordance with the Business Registration Ordinance, with which Sun Pacific has duly complied in all material respects, Sun Pacific is not required to obtain any other material permit, licence or approval in Hong Kong in order to engage in the provision of system and solution and consultancy services.

Based solely on our review of the Documents, the current business registration certificate covering the period from 17 November 2023 to 17 November 2025 is valid and has not expired, been varied or revoked and remains in full force and effect.

Thingsocket has obtained the following business registration certificates during the Track Record Period for its business carried out in Hong Kong. Details of the business registration certificates during the Track Record Period are as follows:

Based solely on our review of the Documents, save for the business registration in accordance with the Business Registration Ordinance, with which Thingsocket has duly complied in all material respects, Thingsocket is not required to obtain any other material permit, licence or approval in Hong Kong in order to engage in the provision of system and solution and consultancy services.

Based solely on our review of the Documents, the current business registration certificate covering the period from 1 April 2024 to 31 March 2025 is valid and has not expired, been varied or revoked and remains in full force and effect.

Clinic First has obtained the following business registration certificates during the Track Record Period for its business carried out in Hong Kong. Details of the business registration certificates during the Track Record Period are as follows:

Based solely on our review of the Documents, save for the business registration in accordance with the Business Registration Ordinance, with which Clinic First has duly complied in all material respects, Clinic First is not required to obtain any other material permit, licence or approval in Hong Kong in order to engage in the provision of system and solution and consultancy services.

Based solely on our review of the Documents, the current business registration certificate covering the period from 20 February 2024 to 19 February 2025 is valid and has not expired, been varied or revoked and remains in full force and effect.

Based solely on our review of the Documents and the Searches and according to the best of our knowledge, there are:

According to the IP Search Results on trademarks, patents and designs, Ultra High Point and Thingsocket have respectively registered or applied for the registration of the following trademarks and patents in Hong Kong under the Intellectual Property Department:

Applicant / Registered owner		Trademark		Trademark number		Class		Status
Ewell Hong Kong Limited				306574014		42		Registered
Ewell Hong Kong Limited				306582286		42		Registered
UniNet InfoSystem Limited				305610924		9		Registered

The sample employment contract of Ultra High Point that is reviewed by us conforms with the requirements under the Employment Ordinance (Chapter 57 of the Laws of Hong Kong) (“Employment Ordinance”).

Retirement Pension Scheme

Based solely on the monthly notice of payment for the mandatory provident fund issued Manulife Provident Funds Trust Company Limited (“Manulife”) during the Track Record Period, Ultra High Point has enrolled its Hong Kong employees with the mandatory provident scheme provided by Manulife in compliance with the Mandatory Provident Fund Schemes Ordinance (Chapter 485 of the Laws of Hong Kong) (“Mandatory Provident Fund Schemes Ordinance”).

Based solely on search conducted on the website of the Mandatory Provident Fund Schemes Authority, there was no criminal conviction and civil award/judgement records against any of the Companies as of 23 September 2025.

Compulsory Employees’ Compensation Insurance

According to section 40 of the Employees’ Compensation Ordinance (Chapter 282 of the Laws of Hong Kong) (“Employees’ Compensation Ordinance”), no employer shall employ any employee in any employment unless there is in force a policy of insurance to cover their liabilities both under the Employees’ Compensation Ordinance and at common law for injuries at work in respect of all their employees, irrespective of the length of employment contract or working hours, full-time or part-time employment. If an employer fails to comply with the Employee’s Compensation Ordinance to secure an insurance cover, the employer commits an offence and is liable on conviction upon indictment to a maximum fine of HK$100,000 and imprisonment for two years; or on summary conviction to a maximum fine of HK$100,000 and imprisonment for 1 year.

Based solely on our review of the Documents and [Ultra High Point’s confirmation], Ultra High Point has taken out and maintained a valid employees’ compensation insurance for its employees during [the Track Record Period and up to the date of this Opinion.]

Based solely on [Ultra High Point’s confirmation], there were no claim made by any of its employees in respect of injuries sustained by the employees as a result of accident(s) arising out of and in the course of employment, or in respect of occupational diseases specified in the Employees’ Compensation Ordinance suffered by the employees during the Track Record Period.

Ultra High Point recorded net profits for the tax year ended 31 March 2024 and filed the profits tax return. As of the date of this opinion, Ultra High Point recorded net profits for the tax year ended 31 March 2024 and pending the assessment from the Inland Revenue Department.

Based solely on the [Grandwon’s confirmation], Grandwon has obtained exemption for filing profits tax returns dated 8 February 2022 as it recorded a loss for profits tax computation purpose for the tax year ended 31 March 2021. Since then, [Grandwon continued to record a net loss for tax purpose and did not file any tax notice to the Inland Revenue Department.]

Based solely on the [Sun Pacific’s confirmation], Sun Pacific has obtained exemption for filing profits tax returns dated 28 November 2022 as it recorded a loss for profits tax computation purpose for the tax year ended 31 March 2022. Since then, [Sun Pacific continued to record a net loss for tax purpose and did not file any tax notice to the Inland Revenue Department.]

As of the date of this opinion, Thingsocket recorded net profits for the tax year ended 31 March 2024 and pending the assessment from the Inland Revenue Department.

Without reviewing the relevant resolutions or conducting any further investigation or search and based solely on our review of the Documents and [Ultra High Point’s confirmation], Ultra High Point has entered into following tenancy agreements which are governed under the laws of Hong Kong for its premises in Hong Kong:

Without reviewing the relevant resolutions or conducting any further investigation or search and based solely on our review of the Documents and [Grandwon’s confirmation], Grandwon has not entered into any tenancy agreements

Without reviewing the relevant resolutions or conducting any further investigation or search and based solely on our review of the Documents and [Sun Pacific’s confirmation], Sun Pacific has not entered into any tenancy agreements

Without reviewing the relevant resolutions or conducting any further investigation or search and based solely on our review of the Documents and [Thingsocket’s confirmation], Thingsocket has entered into following tenancy agreements which are governed under the laws of Hong Kong for its premises in Hong Kong:

The statements in the Prospectus under the captions “Regulatory Environment” in so far as they purport to summarise the provisions of the laws of Hong Kong (save for those in relation to the provisions of the laws of the People’s Republic of China), are accurate in all material respects as at the date of this legal opinion and nothing material has been omitted from such statements which would make the same misleading in any material respect.

Ultra High Point is an indirect wholly-owned subsidiary of the Listco upon the completion of the reorganisation. As the public offering of the shares in the Listco is not in Hong Kong, and the Listco is not a company incorporated in Hong Kong, no permission or approval in Hong Kong is required for the share offering as at the date of this opinion.

c.

in insolvency proceedings, the law governing those proceedings may override the law governing the contract.

This opinion shall be governed by and construed in accordance with the laws of Hong Kong.

This opinion is addressed to you for your own use solely for the purpose stated at the beginning of this opinion. Without our prior written consent, this opinion may not be:

In connection with the above opinion, we hereby consent to the filing of this opinion as an exhibit to the Registration Statement of the Listco and to the reference made to this firm in the Registration Statement. In giving such consent, we do not thereby admit that we come within the category of persons whose consent is required under Section 7 of the U.S. Securities Act of 1933, as amended, or the Rules and Regulations of the Commission thereunder.

NEO SOLICITORS LLP

SCHEDULE I – LIST OF DOCUMENTS REVIEWED