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CORRESP
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CORRESP

 125 Broad Street

New York, NY 10004-2498

 TELEPHONE: 1-212-558-4000

FACSIMILE: 1-212-558-3588

LOS ANGELES • PALO ALTO • WASHINGTON, D.C.

 WWW.SULLCROM.COM

FRANKFURT • LONDON • PARIS

BEIJING • HONG KONG • TOKYO

MELBOURNE • SYDNEY

 July 12, 2017

VIA EDGAR AND HAND DELIVERY

 United States Securities and
Exchange Commission,

 Division of Corporation Finance,

100 F. Street, N.E.,

Washington, D.C. 20549.

 Attention:
Ms. Pamela Long, Assistant Director

Re:
Zamalight plc; Praxair, Inc.; Linde AG;

Registration Statement on Form S-4 filed on June 5, 2017

(File No
333-218485)

Dear Ms. Long:

 On behalf of Zamalight plc
(the “Company”), enclosed please find a copy of Amendment No. 1 (“Amendment No. 1”) to the Registration Statement on Form S-4 (the
“Registration Statement”), as filed with the Securities and Exchange Commission (the “Commission”) on EDGAR on the date hereof, marked to show changes from the Registration Statement filed with the Commission on
June 5, 2017.

 The changes reflected in Amendment No. 1 include those made in response to the comments of the staff of the
Commission (the “Staff”) set forth in the Staff’s letter of June 29, 2017 (the “Comment Letter”). Amendment No. 1 also includes other changes that are intended to update, clarify and render more
complete the information contained therein.

 The numbered responses that follow relate to the questions set forth in the Comment Letter,
which are reproduced below in bold print. The responses follow each reproduced comment. All references to page numbers and captions (other than those in the Staff’s comments) correspond to the page numbers and captions in Amendment No. 1.

 * * * *

Ms. Long

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 General

1.
Please provide us supplementally with copies of any board books or similar materials prepared by the financial advisors and shared with the boards of directors and their representatives.

In response to the Staff’s comment, a copy of the discussion materials prepared by Credit Suisse Securities (USA) LLC that were reviewed
and discussed with the board of directors of Praxair, Inc. in connection with the rendering of its opinion on May 31, 2017, are being provided to the Staff on a supplemental basis under separate cover by Alston & Bird LLP, counsel to
Credit Suisse Securities (USA) LLC, requesting confidential treatment pursuant to Rule 418 (“Rule 418”) promulgated under the Securities Act of 1933, as amended (the “Securities Act”), and pursuant to the provisions
of 17 C.F.R. §200.83 (“Rule 200.83”). In response to the Staff’s comment, copies of the discussion materials prepared by the financial advisors to Linde AG in connection with their opinions presented to the supervisory
board or the executive board of Linde AG, are being provided by Freshfields Bruckhaus Deringer US LLP, counsel to Bank of America Merrill Lynch International Limited, Latham & Watkins LLP, counsel to Goldman Sachs AG, Latham &
Watkins LLP, counsel to Morgan Stanley Bank AG, and Davis Polk & Wardwell LLP, counsel to Perella Weinberg Partners, to the Staff on a supplemental basis under separate cover requesting confidential treatment pursuant to Rule 418 and
pursuant to the provisions of Rule 200.83. The Company has been advised by each of Alston & Bird LLP, Freshfields Bruckhaus Deringer US LLP, Latham & Watkins LLP and Davis Polk & Wardwell LLP that, in accordance with Rule
418, such counsel have requested that the materials provided be returned promptly following completion of the Staff’s review thereof.

 Summary,
page 10

 The Exchange Offer, page 12

2.
Please disclose the minimum acceptance condition percentage.

 In response to the
Staff’s comment, the Company has revised the disclosure on page 14 of Amendment No. 1.

 The Exchange Offer, page 13

Treatment of Linde Equity Awards, page 14

Ms. Long

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3.
In the second paragraph, it is stated that each Linde stock option and each Linde matching share right will be terminated in exchange for a cash payment. The third paragraph states that the former holders of Linde
stock options and Linde matching share rights will receive replacement equity awards. It is unclear whether the Linde stock options and Linde matching share rights will be both terminated for cash and also replaced with new equity awards from Linde
plc. Please advise and revise your disclosures as appropriate.

 In response to the Staff’s comment, the Company has
revised the disclosures on pages 14 and 15 of Amendment No. 1.

 Settlement of the Exchange Offer, page 14

4.
Here or in a separate section in the Summary, clarify when tendering Linde AG shareholders will receive their Linde plc shares in the exchange offer. Clarify when this will occur with reference to both shares
tendered during the acceptance period and those tendered during the additional acceptance period. Where you reference a date after the publication of the results of the acceptance period (such as at the bottom of page 13), revise to clarify when
this will occur with reference to the expiration of the acceptance period.

 In response to the Staff’s comment, the
Company has revised the disclosures on pages 13, 14, 215, 218, ALT-6, ALT-7, ALT-32, and ALT-33 of Amendment No. 1.

Termination Fees, page 15

5.
Please clarify in the second bullet point whether Praxair is only obligated to pay the termination fee if its shareholders do not vote in favor of the merger and the Praxair board changed its recommendation on the
merger.

 In response to the Staff’s comment, the Company has revised the disclosures on pages 15 and 201 of
Amendment No. 1.

 Potential Post-Closing Reorganization Regarding Linde, page 17

6.
 We note the disclosure at the top of page 18 that “in addition to acquiring Linde shares in the exchange
offer, Linde plc may, subject to applicable law, purchase additional Linde shares in the open market or otherwise.” If you mean to state that such outside purchases could occur from the date of announcement of the exchange offer through the end
of the offer, in your response letter, provide an analysis of the facts supporting your ability to

Ms. Long

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make outside purchases, consistent with Rule 14e-5. If you are referencing purchases occurring after the exchange offer terminates, please revise your
disclosure here to clarify.

 With certain exceptions, Rule 14e-5 promulgated
under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), prohibits a “covered person” from directly or indirectly purchasing or arranging to purchase any securities to be acquired in a tender offer for
equity securities or any securities immediately convertible into, exchangeable for or exercisable for such securities, except pursuant to such offer. The duration of the prohibition under Rule 14e-5 under the
Exchange Act continues from the time of the public announcement of the offer until the date that the offer expires. In the present case, any purchases of additional Linde shares in the open market or otherwise, but outside of the exchange offer,
will be structured to comply with one of the exceptions to Rule 14e-5 under the Exchange Act until the date that the offer expires. In particular,
Rule 14e-5(b)(12)(i) under the Exchange Act permits purchases or arrangements to purchase securities subject to a tender offer by an offeror or its affiliates to be made in accordance with the laws of the
subject company’s home jurisdiction, subject to certain conditions. While the Company does not currently intend to make any purchases of Linde shares outside the exchange offer either directly or through any advisor, broker or other financial
institution acting as their agent pursuant to Rule 14e-5(b)(12) under the Exchange Act, should it decide to do so in the future, the Company respectfully submits that such purchases would be subject to, and
comply with, the conditions of such rule:

(a)
Linde AG qualifies as a “foreign private issuer” as defined in Rule 405 under the Securities Act and Rule 3b-4(c) under the Exchange Act.

(b)
 The Company reasonably expects that the exchange offer meets the conditions for reliance on the Tier II
cross-border exemptions set forth in Rule 14d-1(d) under the Exchange Act (the “Tier II Exception”). Linde AG and Praxair, Inc. conducted the calculation of U.S. ownership of the Linde shares
pursuant to Instruction 3 to paragraphs (c) and (d) of Rule 14d-1 (the “Alternate Test”), which is available if the bidder is unable to conduct the “look-through” analysis
provided under Instruction 2 to paragraphs (c) and (d) of Rule 14d-1. Linde AG and Praxair, Inc. made a good faith effort to perform a “look-through” analysis by obtaining a shareholder
identification from NASDAQ OMX, a third party information provider retained by Linde AG, which indicated that approximately 30.8% of Linde AG’s outstanding shares were owned by U.S. holders as of December 31, 2016 (a date no more than 60
days before and no more than

Ms. Long

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30 days after the public announcement of the exchange offer on December 20, 2016). This amounts to a U.S. ownership percentage of approximately 31.6%, assuming all Linde ADRs outstanding as
of such date (representing approximately 0.8% of outstanding Linde shares) were owned by U.S. holders. However, because Linde shares are in bearer form (auf den Inhaber lautende Stammaktien ohne Nennbetrag) and held at custodian banks, which
under German law, in general, are prohibited from providing third parties, including public authorities, personal and account information about their customers, Linde AG and Praxair, Inc. were unable to conclusively conduct a
“look-through” analysis as defined in Instruction 2 to paragraphs (c) and (d) of Rule 14d-1.1 Under the Alternate Test, a bidder may
proceed on the presumption that U.S. ownership does not exceed 40% unless (i) the average daily trading volume of the subject securities in the United States for a recent twelve-month period exceeds 40% of the average daily trading volume of
that class of securities on a worldwide basis, (ii) the subject company has disclosed a higher level of U.S. ownership in its most recent annual report; (iii) the bidder otherwise knows or has reason to know, before the public announcement
of the offer, that the level of U.S. ownership exceeds such percentage; or (iv) the bidder otherwise knows, or has reason to know, that the level of U.S. ownership exceeds such percentage. Accordingly, the Company conducted the Alternate Test
as follows:

 The Company believes, based on market share data from Bloomberg Finance, that the average daily trading volume
of the Linde shares in the United States is insignificant. Linde shares are not listed and/or traded on a stock exchange in the United States.

Linde AG’s annual report for the fiscal year ended December 31, 2015, the most recent annual report published before the public
announcement of the exchange offer, estimates that, based on identifiable institutional

1
 The Staff stated in The Commission Guidance and Revisions to
Cross-Border Tender Offer, Exchange Offer, Rights Offerings, and Business Combination Rules and Beneficial Ownership Reporting Rules for Certain Foreign Institutions, Release Nos. 33-8957; 34-58597 (Dec. 8, 2008) that “an acquiror generally will be unable to conduct the required look-through analysis in the manner prescribed by our revised rules
when the subject securities are in bearer form. In addition, in certain foreign jurisdictions, nominees may be prohibited by law from disclosing information about the beneficial owners on whose behalf they hold. Where this prohibition extends to the
country of residence of the beneficial owners of the subject securities, we believe the alternate test for determining eligibility should be available.”

Ms. Long

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investors which accounted for approximately 76% of the outstanding Linde shares as of December 31, 2015, the percentage of shares held by U.S. holders amounted to approximately 38% of such
shares held by such institutional investors. That figure represented approximately 28% of the total Linde shares outstanding as of December 31, 2015.

Based on information provided by third parties and beneficial ownership reports relating to Linde AG publicly available to the Company, the
Company did not know or have reason to know, before the public announcement of the exchange offer on December 20, 2016, that the level of U.S. ownership exceeded 40% of the Linde shares. In particular, based on shareholder ownership data from
Bloomberg Finance, the overall percentage of Linde shares owned by U.S. holders was approximately 26.7% before the public announcement of the exchange offer on December 20, 2016.

The Company does not know and has no reason to know that the level of U.S. ownership exceeds 40% of Linde shares.

(c)
No purchases or arrangements to purchase Linde shares except pursuant to the exchange offer will be made in the United States.

(d)
The Registration Statement discloses prominently on pages 17, 219, and ALT-94 of Amendment No. 1 the possibility of purchases or arrangements to purchase Linde shares outside
of the exchange offer and the manner in which information regarding such purchases will be disseminated.

(e)
There will be public disclosure in the United States, to the extent that such information is made public in Linde AG’s home jurisdiction of Germany, of information regarding all purchases by the Company of Linde
shares and related securities otherwise than pursuant to the exchange offer from the time of public announcement of the exchange offer until the exchange offer expires.

(f)
Purchases or arrangements to purchase Linde shares outside the exchange offer by the Company and its affiliates will satisfy the following additional condition: the exchange offer price will be increased to match any
consideration paid outside of the exchange offer that is greater than the exchange offer price.

Ms. Long

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 Purchases or arrangements to purchase Linde shares outside the exchange offer by an affiliate of
a financial advisor will satisfy the additional conditions set forth in Rule 14e-5(b)(12)(i)(G) under the Exchange Act. Except as otherwise exempted, the Company will comply with
Rule 14e-5 under the Exchange Act.

 In addition to Rule
14e-5 under the Exchange Act, any purchases of Linde shares outside of the exchange offer will be regulated by German securities laws. The German Takeover Act allows the Company to make such purchases, subject
to certain conditions. The Company will be required to make available to all holders of Linde shares subject to the exchange offer any more favorable terms, including price terms, agreed to in connection with any purchases of Linde shares by the
Company outside the exchange offer. Under Section 31(4) of the German Takeover Act, the Company would be obligated to increase the exchange offer price to the level of any higher purchase price outside the exchange offer. In addition, any such
purchases by the Company prior to the commencement of the exchange offer must be disclosed in the exchange offer document. Finally, pursuant to Section 23(2) of the German Takeover Act, any such purchase by the Company during the exchange offer
must be reported to BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht) and announced publicly immediately following such purchase.

Regulatory Approvals, page 20

7.
Please disclose the specific waiting periods for the FTC and Department of Justice.

 In
response to the Staff’s comment, the Company has revised the disclosures on pages 21 and 164 of Amendment No. 1.

 Interests of Directors,
Board Members, and Executive Officers in . . . (see page [—]), page 22

8.
Please quantify the interests of the directors and officers. Please also quantify these amounts in your related risk factor on page 40.

In response to the Staff’s comment, the Company has revised the disclosures on pages 23, 42 and 173 of Amendment No. 1.

Ms. Long