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February 5, 2024
Sun Lei
Chief Executive Officer
JX Luxventure Ltd.
Bin Hai Da Dao No. 270
Lang Qin Wan Guo Ji Du Jia Cun Zong He Lou
Xiu Ying District
Haikou City, Hainan Province 570100
People’s Republic of China
Re:JX Luxventure Ltd
Form 20-F for Fiscal Year Ended December 31, 2022
Filed May 12, 2023
Amendment No. 4 to Form 20-F for Fiscal Year Ended December 31, 2022
Filed January 17, 2024
File No.001-35715
Dear Sun Lei:
            We have reviewed your January 17, 2024 response to our comment letter and have the
following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our January 2, 2024
letter.
Amendment No. 4 to Form 20-F for Fiscal Year Ended December 31, 2022
Critical Accounting Policies
Revenue Recognition
Revenue from reselling of airline ticket, page 81
1.We note you recognize revenue at a point in time, once the air-tickets are issued to
passengers. We also note that your return and replacement guarantees are valid up until
the point of departure. Please tell us why you believe revenue should be recognized at the

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 February 5, 2024 Page 2
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JX Luxventure Ltd.
February 5, 2024
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time the air-tickets are issued as opposed to the point of departure. Specifically address:
•How you considered the return and replacement guarantees as separate performance
obligations under IFRS 15.
•How you considered whether the transactions should be considered a sale with a right
of return under IFRS 15 B22-27.
•Specifically address how you considered the need to estimate a liability for losses on
returns as described in paragraph B25 of IFRS 15.
•If you consider this a sale with right of return, please tell us how your current
accounting is in accordance with paragraph B21 of IFRS 15. Specifically address
why you have not estimated the liability associated with returned air-tickets at the
time of recognition under your current policy.
•Please tell us in your response the range and average length of time between ticket
issuance and departure date.
Notes to Consolidated Financial Statements
9. Cost of Revenues, page F-29
2.We note your response to our previous comment 5. Please revise your tabular presentation
of cost of revenues to separately present the net impact to cost of revenues of value of
returned tickets not refunded to you by the airlines. In this regard, the revised table should
show the $965,000 and $917,000 separately from the line item, "Outsourced service cost."
3.As a related matter, please provide to us in your response a table showing the calculation
of the net charge to cost of revenues related to airline ticket returns for each period an
income statement is presented. Specifically, this table should detail gross value of airline
tickets refunded to customers, gross value received by you from airlines for airline tickets
returned, and the resulting net value included in cost of revenue.
19. Loss Per Share, page F-33
4.As requested in our previous comment 13, please revise disclosures throughout your filing
to retrospectively restate the number of shares to reflect the reverse split. Refer to the
guidance in SAB Topic 4C and FASB ASC 505-10-S99-5. Specifically, the calculation of
basic and diluted weighted average shares outstanding presented in this table does not
reflect the 1:10 reverse stock split that occurred on April 26, 2023.

 FirstName LastNameSun Lei
 Comapany NameJX Luxventure Ltd.
 February 5, 2024 Page 3
 FirstName LastName
Sun Lei
JX Luxventure Ltd.
February 5, 2024
Page 3
            Please contact Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380 if you have
questions regarding comments on the financial statements and related matters. Please contact
Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services