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UPLOAD Filing

ORIENTAL RISE HOLDINGS Ltd
Date: July 15, 2025 · CIK: 0001964664 · Accession: 0000000000-25-007439

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-288292

Date
July 15, 2025
Author
Finance
Form
UPLOAD
Company
ORIENTAL RISE HOLDINGS Ltd

Letter

Re: Oriental Rise Holdings Limited Amendment No. 1 to Registration Statement on Form F-1 Filed July 8, 2025 File No. 333-288292 Dear Dezhi Liu:

July 15, 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 reviewed your amended 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.

Amendment No. 1 to Registration Statement on Form F-1 Exhibits

1. We note the references throughout the filing to the opinion of your PRC counsel, Jingtian & Gongcheng. Please file the consent of PRC counsel as an exhibit. Refer to Item 601(b)(23) of Regulation S-K. July 15, 2025 Page 2

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
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 15, 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
 Amendment No. 1 to Registration Statement on Form F-1
 Filed July 8, 2025
 File No. 333-288292
Dear Dezhi Liu:

 We have reviewed your amended 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.

Amendment No. 1 to Registration Statement on Form F-1
Exhibits

1. We note the references throughout the filing to the opinion of your PRC
 counsel, Jingtian & Gongcheng. Please file the consent of PRC counsel as
an exhibit.
 Refer to Item 601(b)(23) of Regulation S-K.
 July 15, 2025
Page 2

 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>