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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 28, 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:
Linde 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 Linde plc (formerly known as Zamalight plc) (the “Company”), enclosed please find a copy of Amendment No. 2
(“Amendment No. 2”) 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 Amendment No. 1 to the Registration Statement filed with the Commission on July 12, 2017.

The changes reflected in Amendment No. 2 include those made in response to the comments of the staff of the Commission (the
“Staff”) set forth in the Staff’s letter of July 20, 2017 (the “Comment Letter”). Amendment No. 2 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. 2.

* * * *

Ms. Long

 Summary, page 10

The Exchange Offer, page 13

 Treatment of
Linde Equity Awards, page 14

1.
We note the expanded disclosure you provided in response to comment 3. Please further expand this disclosure to explain how it will be determined whether the Linde equity award is paid out in cash versus replaced
with Linde plc equity awards.

 In response to the Staff’s comment, the Company respectfully submits that the
criteria used to determine the portion of Linde equity awards paid out in cash versus replaced with Linde plc equity awards is described in the disclosures set forth on pages 14, 15, 180, 181, 186, ALT-175 and
ALT-176 of Amendment No. 2. As indicated in the disclosures, the extent to which each Linde equity award will be paid out in cash versus replaced with Linde plc equity awards will be based on the extent
to which the respective award’s four-year waiting period has elapsed as of consummation of the exchange offer.

 Interests of Directors, Board
Members, and Executive Officers . . . (see page [—]), page 23

2.
We note your response to comment 8 and we re-issue our comment. Please quantify the pecuniary 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, 24, 42, 43, 175, 176, 177, 180, ALT-174 and ALT-175 of Amendment No. 2.

Summary Selected Historical Consolidated Financial Information of Linde, page 32

3.
We note your response to comment 58. As previously requested, please revise the title of the non-IFRS measure, group operating profit from continuing operations, so that it is
obvious to investors that the measure is that of a non-IFRS measure. An example would be to rename the non-IFRS measure to segment group operating profit from continuing
operations. Please refer to Item 10(e)(1)(ii)(e) of Regulation S-K for guidance.

 -2-

Ms. Long

 In response to the Staff’s comment, the Company has revised the disclosures on pages 34,
404, 408, 409, 412, 420, 436, 437, F.3-83 and ALT-20 of Amendment No. 2.

Risk Factors, page 36

 Praxair and Linde are
subject to anti-corruption laws in the jurisdictions …, page 59

4.
In your response to comment 10 you discuss Linde’s sales to Syria and Sudan. As we requested in comment 10, please tell us the nature of Linde’s contacts with Syria and Sudan, including the services or
products provided. As we requested in comment 11, please tell us the approximate dollar amount of Linde’s revenues from Syria and Sudan for the past three fiscal years and subsequent interim period.

(a)
Linde

 Syria

In response to the Staff’s comment, Linde respectfully submits that, in the period comprising the last three fiscal years and subsequent
interim period, Linde has sold cylinders and a test gas mixture to one customer located in Syria, a supplier of surgical consumables to physicians and therapeutic and diagnostic equipment for clinics, refractive centers and operating rooms, which
sales represent a de minimis portion of Linde’s aggregate sales.

 Linde respectfully submits to the Staff that Linde’s
revenues from Syria were approximately €60,000 in each of the three prior fiscal years and the first half of 2017.

 Sudan

In response to the Staff’s comment, Linde respectfully submits that, in the period comprising the last three fiscal years and the
subsequent interim period, Linde has made sales to Sudan through a French subsidiary that specializes in the supply of equipment for industrial gases, clean power generation and liquid natural gas and hydrocarbon applications. In fiscal year 2014,
Linde delivered an ECO 90 turbine for industrial gas application to Sudan at the direction of a Chinese customer (the ECO 90 turbine was sold in fiscal year 2013). In fiscal year 2016, Linde sold and delivered spare parts of an ECO 90 turbine for
industrial gas application to Sudan at the direction of an Italian customer. In Q2 2017, Linde performed remedial

 -3-

Ms. Long

works, repairs and spare part installations for a turbo-compressor installed in Sudan for a Sudanese customer that manufactures and supplies industrial and healthcare gases in Sudan. The revenues
from the sales of these goods and services represent a de minimis portion of Linde’s aggregate revenues.

 Linde respectfully
submits to the Staff that Linde’s revenues from Sudan were approximately €150,000 in each of the three prior fiscal years and the first half of 2017.

(b)
Praxair

 Further to Praxair’s responses on July 12, 2017 to the Staff’s
comments 10, 11 and 12 in its letter dated June 29, 2017, Praxair respectfully submits the following supplementary information. One of Praxair’s joint ventures (the “Joint Venture”), in which Praxair holds a minority 34%
interest, has had limited exports to Sudan and Syria over the period covered by the Staff’s questions. While Praxair has minority representation on the Board of Directors of the Joint Venture, Praxair personnel are not represented in the
management of the Joint Venture and Praxair does not otherwise control the Joint Venture. The Joint Venture, which is majority-owned by a third party non-U.S. shareholder, is incorporated in Italy and
primarily operates in Europe but also exports certain products internationally. In connection with this export business, the Joint Venture has generated limited revenues from end customers in Sudan and Syria in the three prior fiscal years, as
described below. To the best of Praxair’s knowledge, after inquiry of the management of the Joint Venture, the Joint Venture has not generated revenues from Sudan or Syria during the interim period in 2017. Revenue figures below are the total
sales of the Joint Venture with counterparties in Sudan and Syria.

 Sudan

2016

2015

2014

 Total sales of Joint Venture (€)

537,304

46,988

3,411,150

 The Sudan revenues derived from the 2014 sale of an air separation plant used in the steelmaking industry
(which accounts for substantially all of the 2014 sales) and the sale of spare parts for such plant, as well as from the sale of PET compressors, which are used in bottling plants for soft drinks, and the sale of spare parts for PET compressors.

 Syria

2016

2015

2014

 Total sales of Joint Venture (€)

18,801

—

49,291

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Ms. Long

 The Syria revenues derived from the sale of spare parts for PET compressors to one
counterparty.

 To the best of Praxair’s knowledge, the Joint Venture does not have any agreements, commercial arrangements or other
contracts with the governments of Sudan or Syria, nor does it have any contacts with the governments of Sudan or Syria. To the best of Praxair’s knowledge, the Joint Venture does not have any agreements, commercial arrangements or other
contracts with entities controlled by the governments of Sudan or Syria, nor does it have any contacts with entities controlled by the governments of Sudan or Syria. The Joint Venture does not currently maintain, nor has it in the past maintained,
any physical presence in Sudan or Syria. The Joint Venture does not have any assets or liabilities in Sudan or Syria.

 In addition, to the
best of Praxair’s knowledge, the products that the Joint Venture exported to Sudan and Syria are not considered “dual-use” products under applicable law. To the best of Praxair’s knowledge,
the products exported to customers in Sudan and Syria were not put to military uses.

 Materiality

Praxair does not believe that its interest in the Joint Venture’s de minimis revenues and the Joint Venture’s sales of
products to end-users in Syria and Sudan constitute a material investment risk for Praxair’s security holders (or for the future security holders of the Company), taking into account both quantitative and
qualitative factors that a reasonable investor would consider important in making an investment decision.

 Praxair’s interest in the
Joint Venture’s sales into Syria and Sudan are quantitatively immaterial considering Praxair’s total revenues, representing less than 0.01% of Praxair’s total revenues in the relevant periods.

Praxair also believes that the Joint Venture’s exports to Syria and Sudan are immaterial from a qualitative perspective. Praxair
respectfully submits that its compliance programs are designed and implemented to comply with applicable laws of all relevant jurisdictions, in particular applicable sanctions laws and regulations implemented by the United States and applicable non-U.S. jurisdictions (collectively, “Sanctions Laws”). The Joint Venture also has compliance programs that are designed and implemented to comply with applicable Sanctions Laws. No U.S. persons
and no Praxair employees were

 -5-

Ms. Long

involved in such transactions. Praxair believes that reasonable investors would expect that non-U.S. companies such as the Joint Venture will engage in
business with customers in Sudan and Syria that is in compliance with applicable law and involving products that do not have military uses.

Praxair is subject to numerous laws and regulations, including Sanctions Laws. The failure to comply with such laws and regulations, including
if such failure to comply occurred at an affiliate of Praxair, may harm Praxair’s reputation and adversely impact its business or results of operations. For a more fulsome discussion of this risk, Praxair respectfully refers the Staff to the
risk factor contained on pages 60 and 61 of Amendment No. 2. Praxair does not believe that the Joint Venture’s sales to Syria and Sudan in the applicable periods present any additional risks in this respect that have not already been
disclosed.

 Accordingly, Praxair believes the Joint Venture’s sales into Syria and Sudan would not be material to a reasonable
investor in making an investment decision and would not materially affect Praxair’s or the Company’s reputation and share value. Praxair recognizes that certain U.S. investors have adopted divestment initiatives regarding investment in
companies that engage in certain business with countries sanctioned by OFAC, such as Syria and Sudan, even if that business does not violate any Sanctions Laws. Praxair and the Company do not expect any potential actions arising from such
initiatives as a result of such sales by the Joint Venture to materially affect the share value of Praxair or the Company.

 Background of the
Business Combination, page 92

5.
We note your response to comment 15 and we re-issue our comment in part. Please elaborate on the role of the financial advisors, including which financial advisors participated
in these feasibility evaluations on behalf of each company and how they were selected. Please also elaborate on the outcome of the feasibility evaluations, including any potential issues and recommendations raised by each company and its advisors.

 In response to the Staff’s comment, the Company has revised the disclosures on pages 94 and 95 of Amendment
No. 2.

6.
Please revise your disclosure to discuss the “serious concerns” raised by the individual members of the Linde executive board and key managers.

In response to the Staff’s comment, the Company has revised the disclosure on page 95 of Amendment No. 2.

 -6-

Ms. Long

7.
We note your response to comment 19 and your references to “other factors” that justified a higher valuation. Please revise your disclosure to discuss such “other factors.”

In response to the Staff’s comment, the Company has revised the disclosure on page 96 of Amendment No. 2.

Opinion of Goldman Sachs, Financial Advisor to the Linde Supervisory Board, page 127

8.
We note your revised disclosure in response to comment 30 that no fees were paid to Goldman Sach’s investment banking division. Please revise to disclose all fees paid to Goldman Sachs during the past two years.
See Item 1015(b)(4)(i) of Regulation S-K.

 In response to the Staff’s
comment, the Company has revised the disclosure on page 134 of Amendment No. 2.

 Unaudited Pro Forma Condensed Combined Financial Information,
page 231

9.
Please expand your disclosures regarding the identification of Praxair as the accounting acquirer to provide the specific facts and circumstances considered, how those facts and circumstances led to your conclusion,
and how any variability in the facts and circumstances may impact your conclusion once the merger transaction has been completed.

In response to the Staff’s comment, the Company has revised the disclosures on pages 233 and 234 of Amendment No. 2.

10.
We note your response to comment 40. Regarding your analysis of the guidance in ASC 805-10-25-5
and ASC 810-10-15-8 followed by ASC 805-10-55-12a, your assumptions regarding the percentage of Linde shares tendered in the exchange offer here versus other aspects of your pro forma financial information appear inconsistent. Please
revise your presentation throughout to clarify how the assumptions regarding the percentage of Linde shares to be tendered in the exchange offer are consistent. Please also explain how a change in this assumption would impact the conclusions reached
and the pro forma financial information and disclosures provided. Please also provide a discussion of how your plans for Linde AG after the exchange offer will impact this assumption as well.

 -7-

Ms. Long

 In response to the Staff’s comment, the Company has revised the disclosures on pages 233
and 241 of Amendment No. 2.

 The Company respectfully advises the Staff that it believes that the 100% tender rate assumption in the
section “Unaudited Pro Forma Condensed Combined Financial Information” of Amendment No. 2 is appropriate because (a) the exchange offer will be made for 100% of the Linde shares, (b) it is the Company’s objective to
acquire 100% of the Linde shares in the exchange offer, (c) if 90% or more of the Linde shares are tendered in the exchange offer, the Company will (either directly or indirectly through its wholly-owned subsidiary Linde Holding GmbH) be able
to, and intends to, acquire the untendered Linde shares promptly following completion of the exchange offer using the available squeeze-out transaction under German law and (d) even if less than 90% of
the Linde shares are tendered an