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CORRESP
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    Mark Crone

    Managing Partner

    mcrone@cronelawgroup.com

    Eleanor Osmanoff

    Partner

    eosmanoff@cronelawgroup.com

VIA EDGAR

January 17, 2024

THE UNITED STATES SECURITIES

AND EXCHANGE COMMISSION

Office of Trade and Services

Division of Corporation Finance

Washington, D.C. 20549

    Attn:
    Amy Geddes, Lyn Shenk, Rucha Pandit and Donald Field

    Re:

    Re: JX Luxventure Ltd

    Form 20-F for Fiscal Year Ended December 31,
    2022

    Filed May 12, 2023

    File No. 001-35715

Ladies and Gentlemen:

On
behalf of our client, JX Luxventure Limited (the “Company”), we are responding to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in the letter dated January 2, 2024 (the “Comment
Letter”), relating to the above-referenced annual report on Form 20-F for the year ended December 31, 2022, as amended by Amendment
No. 1, dated May 15, 2023, Amendment No. 2, dated August 31, 2023, and Amendment No. 3, dated October 31, 2023 (collectively, the “Annual
Report”). Concurrently with the submission of this letter, the Company is filing Amendment No. 4 to the Annual Report (“Amendment
No. 4”).

Set
forth below are the Company’s responses to the Staff’s comments. The Staff’s comments are repeated below in bold and
are followed by the Company’s responses. All references in this response letter to the Annual Report include the references
to Amendment No. 4 to the Annual Report. Unless we provide express references to page numbers in
Amendment No. 4, the page references in the text of this response letter correspond to the page numbers stated in the Comment Letter.

Amendment No. 3 to Form 20-F for Fiscal
Year Ended December 31, 2022

Item 3. Key Information, page 1

1. We note the revised disclosure in response
to comment 5, specifically that you have concluded that the company and its PRC subsidiaries “have obtained all necessary licenses
and approvals required for our operations in China” after “consulting [y]our PRC legal counsel.” We also note your representation
on page 22 that, based “on the advice of PRC counsel,” you “are not subject to the review or prior approval of the CAC
or the CSRC.” Please clarify whether “consulting [y]our PRC legal counsel” and relying on the “advice” of counsel
is the same as relying on the “opinion” of counsel. If so, please revise in all applicable areas to specifically state that
the company has relied on the opinion of counsel. If not, please state as much and explain why such an opinion was not obtained.

Response: In response
to this Staff’s comment, the Company revised its disclosure on page 1 of Item 3, as well as on page 22, stating that we are relying
on the opinion of its PRC counsel in concluding that the Company and its PRC subsidiaries have obtained all necessary license and approvals
required for its operations in China.

United States Securities and Exchange Commission

January 17, 2024

Page 2

Critical Accounting Policies

Revenue Recognition

Revenue from selling of airline-ticket, page
81

2. Please revise your disclosure either here,
in your comparative discussion of operating results, and/or in the footnotes to your financial statements to include a disaggregation
of revenue based on the categories detailed in your response to our previous comment 7. Specifically address the relationship between
the disaggregated revenue and revenue information that is disclosed for each reportable segment. Refer to the guidance in paragraphs 114-115
of IFRS 15. In the alternative, please revise to disclose that tourism packages and Model B sales are insignificant to revenues.

Response: In response
to this Staff’s comment, the Company revised the disclosures in our comparative discussion of operating results as presented in
Page 73 of Amendment No. 4 and Note 8 of the financial statements, which included revenue for each reportable segment of the Company.
As shown on the table of Note 8, based on our determination of potential trends, the revenue for tickets purchased and revenue recorded
from sales of tourism packages are insignificant compared to the Company’s total travel service revenue.

3. As requested in our previous comment 9, please quantify for us in
your response the cost of sales associated with revenues earned from Customer A.

Response: In response
to this Staff’s comment, the Company states that the cost of sales associated with revenues earned from Customer A was US$73.78
million during the year ended December 31, 2022.

4. The following comments pertain to what
we have previously referred to as Model A airline ticket sales, which comprise almost the entirety of your Tourism revenues. We note your
response to comments 10 and 11. Please tell us whether your return and replacement guarantees are provided on all airline ticket sales
and whether you charge an additional fee for guaranteed return or replacement. Please tell us the terms of the return and replacement
guarantees that you provide to your customers including:

 ● the conditions in which your customers are able to return
or replace their tickets;

 ● what each of the return and replacement guarantees provide
to customers;

 ● when customers are able to obtain a return or replacement;
and

 ● any other relevant terms.

Please also tell us what happens to returned or
replaced air tickets.

Response: In response
to this Staff’s comment, the Company provides the following explanation:

Using Model A, the Company
operates as a supplier of airline tickets to our business customers (travel agencies that are operators of online airline ticket platforms).
First, we purchase the tickets and acquire control over the tickets from airlines. Then, we sell these tickets and transfer these rights
to the customers of travel agencies who are end customers This model allows us to offer our business customers the service of dealing
directly with our Company with respect to the airline tickets, instead of dealing with the airlines, and this service includes ticket
returns. We provide return and replacement guarantees on all airline ticket sales without charging an additional fee for guaranteed return
or replacement.

Below are details of the terms of our
return and replacement guarantees that we provide to our customers:

Return terms:

    The conditions in which your customers are able to return or replace their tickets

 ü Our
                                            business customers are permitted to return the tickets at any time prior
                                            to departure, and we accept all returns without additional conditions attached.

    What each of the return and replacement guarantees provide to the customers

 ü We guarantee our business customers a refund,
prior to the flight departure.

United States Securities and Exchange Commission

January 17, 2024

Page 3

    When customers are able to obtain a return or replacement?

 ü Our customers are able to obtain a return immediately
upon request from the end customers.

    ●
    Prior to the flight departure, passengers (the end customers of the platform operated by our business customers) can request a return of their tickets through our business customers. Since we maintain control over the airline tickets, we provide the service of ticket return (additional service of offering different and better return policy compared to airline company offered) to our business customers. Consequently, our business customers cannot interact directly with the airlines, and the airlines do not accept requests from our customers regarding the airline ticket.

 ● The refund amount received by the end customers
depends on the lead time, which is the duration between the ticket return request and the flight’s departure time. Generally, the
closer the request is made to the departure time, the smaller the refund amount. This policy aligns with many Chinese airline companies,
where a shorter lead time results in a lesser refund amount. During the refund process, the end customers, through our business customers,
interact directly with the Company, instead of interacting with airlines.

    ●
    If these passengers are unable to board the flight due to special circumstances such as illness, emergencies, or other force majeure events, they will receive the full amount of the original purchase cost. Our full refund policy offers better return than those provided by Chinese airline companies. During such a refund process, the end customers, through our business customers, interact directly with the Company instead of interacting with airlines.

    ●
    Our business customers are required to provide a security deposit. Such a deposit is needed in order to provide refunds to the end customers when such customers request such refunds. We are maintaining a minimum amount of such security deposit. Using this arrangement, the end customers receive the ticket refund immediately upon request.

 When we refund our business
customers, we may receive a lesser amount of the refund from airlines than the amount we refund our business customers due to the following
reasons:

    1
    We guarantee our business customers the full refund of the ticket’s purchase price when their end customer (the passenger) is unable to travel due to illness, emergencies, or force majeure events. While we provide them with the full refund, we may not receive an equivalent refund amount from airlines because the airlines treat these tickets as standard returns, which could result in a lesser amount of the refund than what we initially paid. Under standard returns terms, when we request a ticket return from the airline close to the departure time, the refund amount we receive from the airline decreases. Consequently, we incur a loss as part of this guaranteed return policy.

    2
    Our business customers initially return the tickets to us. We then return these same tickets back to the airline. This sequence creates a time gap between when we receive the ticket and when we submit the return to the airline. This time gap could result in the Company receiving less than the reimbursement offered to our customers or not receiving any refund at all from the airline. Airlines have a specific time window for accepting returned tickets. If we miss this window, we are unable to return the ticket. Consequently, there are instances when, after we have refunded our customers, we are unable to claim any cash from the airline companies because we missed the last effective claim time.

    3.
    When tickets are returned to the airline within the time window, the closer the return request is made to the departure time, the smaller the refund amount we receive from the airline. Due to the time gap between when we receive the ticket and when we submit the return to the airline, it shortens the time for us to make refund request to the airline. As such, the refund amount we receive may not equate to the amount we reimburse our business customers, resulting in a loss. We are a company in the airline ticket supply chain that bears the cost of this return policy.

United States Securities and Exchange Commission

January 17, 2024

Page 4

 We offer our business customers
a full refund policy compared to services of airlines, which we believe is one of our competitive advantages. Our business customers do
not interact directly with the airlines and the airlines do not accept any request from our business customers. They prefer to work with
us because they can deal with us directly, eliminating complications associated with dealing with airlines. Our favorable return policy
enables our business customers to provide a superior product and experience to their end customers, the passengers. However, this business
practice does expose us to inventory risks and potential losses from returns.

 If an airline cancels flights,
it will replace the airline tickets, and we will extend the same service to our business customers. During fiscal year ended 2022 and
2021, we have not charged additional fee and have not incurred additional cost for ticket replacements. As a result, both our revenue
and costs associated with the replacement of airline tickets were zero.

5. You state you recognized $965,000 and $917,000
“as losses” in 2022 and 2021, respectively, related to these guarantees. Please tell us:

 ● the portion of these amounts related to returns and replacements
separately;

 ü the losses were only related to returns; we do
not have any replacement losses

 ● where these amounts were classified on your statements of
comprehensive loss;

 ü these amounts were recorded on our statements
as deductions of revenue and deductions of cost of revenue as a net effect;

 ● the journal entries you recognize for a return and for a replacement;

 ü When we accept returns from our customers, we
recognize them using the following abbreviation:

 o Debit. revenue AA

 o Credit. Accounts receivable: AA

 ü When we apply returns from airlines, we recognize
it as follows:

 o Debit. Accounts payable: BB

 o Credit. Cost of revenue: BB

As explained in our response to Comment 4, we incurred losses
on a net basis. For illustration purposes, $965,000 loss in fiscal year 2022 represents the amount of AA-BB.

 ● whether there were any amounts received or recognized as credits
to your statements of comprehensive loss that had the effect of offsetting the amounts of losses you incurred (such as refunds from airlines
or travel agencies and their end customers); and

 ü We did not receive or recognize any amounts as
credits to our statements of comprehensive loss that to offset the amounts of losses we incurred.

 ● whether the amounts above include a provision for expected
losses or whether these amounts were actual losses.

 ü These amounts were actual losses without any
provision for expected losses.

Response: In response
to this Staff’s comment, please see responses from the Company to each question of the Staff directly below each such question.

6. We note your response to comment 11. In response
to comment 8, you state that the travel agencies provide you with only the flight number and date when soliciting you for a bid. Please
clarify for us, if correct, that you are then bidding against other airline ticket suppliers for the same ticket on the same flight. In
your response, you reference prices suggested by the airlines and that you make a determination on the viability of that price and may
adjust it. Please tell us whether your evaluation process is automated or performed manually.

Response: In response
to the Staff’s comment, the Company provides the following explanation:

The Company is bidding against
other airline ticket suppliers for the same ticket on the same flight. We manually set the amount of the discount on our system, but the
bidding process will the automated. For example, we manually set a 1% discount on the reference price in our system, and once it is set,
all bid price is automatically 1% less than reference price provided by our business customer.

United States Securities and Exchange Commission

January 17, 2024

Page 5

7. You state that the travel agency customers
ask ticket suppliers for a bid when they receive a customer bid. Please tell us the nature of the end consumer’s “bid,”
including whether the bid states a “bid” price and, if so, how the end consumer’s bid price is determined.

Response: In
response to this Staff’s comment, please find the following explanation from the Company:

The more accurate description
of a bid is a price quote request. Once our business customers, travel agencies, receive a price quote request from their customers, they
ask ticket suppliers like we are to submit a bid. To be best of our knowledge, the price quote request from the end customers is usually
based upon the reference price quoted by airlines. When we decide to participate in order