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UPLOAD Filing

ORIENTAL RISE HOLDINGS Ltd
Date: July 1, 2025 · CIK: 0001964664 · Accession: 0000000000-25-006957

Regulatory Compliance Risk Disclosure Financial Reporting

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File numbers found in text: 333-288292

Date
July 1, 2025
Author
Division of
Form
UPLOAD
Company
ORIENTAL RISE HOLDINGS Ltd

Letter

Re: Oriental Rise Holdings Limited Registration Statement on Form F-1 Filed June 24, 2025 File No. 333-288292 Dear Dezhi Liu:

July 1, 2025

Dezhi Liu Chief Executive Officer Oriental Rise Holdings Limited No. 48 Xianyu Road Shuangcheng Town, Zherong County Ningde City, Fujian Province People s Republic of China, 355399

We have conducted a limited review of your registration statement and have the following comment.

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 28, 2025 letter.

Registration Statement on Form F-1 General

1. We note your response to prior comment 2. Please revise to reinstate the reference to "sudden or unexpected" changes in laws and regulations in the heading of the risk factor on page 44. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. July 1, 2025 Page 2

Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Please contact Juan Grana at 202-551-6034 or Margaret Sawicki at 202-551-7153 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services
cc: Joe Laxague, Esq.

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 July 1, 2025

Dezhi Liu
Chief Executive Officer
Oriental Rise Holdings Limited
No. 48 Xianyu Road
Shuangcheng Town, Zherong County
Ningde City, Fujian Province
People s Republic of China, 355399

 Re: Oriental Rise Holdings Limited
 Registration Statement on Form F-1
 Filed June 24, 2025
 File No. 333-288292
Dear Dezhi Liu:

 We have conducted a limited review of your registration statement and
have the
following comment.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our March 28,
2025 letter.

Registration Statement on Form F-1
General

1. We note your response to prior comment 2. Please revise to reinstate the
reference to
 "sudden or unexpected" changes in laws and regulations in the heading of
the risk
 factor on page 44.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 July 1, 2025
Page 2

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Juan Grana at 202-551-6034 or Margaret Sawicki at
202-551-7153
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Joe Laxague, Esq.
</TEXT>
</DOCUMENT>