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CORRESP Filing

ORIENTAL RISE HOLDINGS Ltd
Date: July 8, 2025 · CIK: 0001964664 · Accession: 0001213900-25-062091

Regulatory Compliance Risk Disclosure Offering / Registration Process

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File numbers found in text: 333-288292

Referenced dates: July 1, 2025

Date
July 8, 2025
Author
THE CRONE LAW GROUP, P.C.
Form
CORRESP
Company
ORIENTAL RISE HOLDINGS Ltd

Letter

Division of Corporation Finance Office of Industrial Applications and Services Re: ORIENTAL RISE HOLDINGS LIMITED Registration Statement on Form F-1 Filed June 24, 2025 File No. 333-288292

Dear Mr. Grana:

On behalf of Oriental Rise Holdings Limited, a Cayman Islands corporation (the "Company"), we write in response to comments by the staff (the "Staff") of the Securities and Exchange Commission (the "Commission") in its letter dated July 1, 2025, with reference to the Company's Registration Statement on Form F-1 filed with the Commission on June 24, 2025, (the "Registration Statement"). We also simultaneously file with the Commission an amended Registration Statement on Form F-1 in response to such comments.

For the convenience of the Staff, each of the Staff's comments is included and is followed by the corresponding response of the Company.

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.

Response : In response to the Staff's comment, we have revised the heading of the subject risk factor on page 44 as requested.

We thank the Staff for its review of the foregoing and believe the Registration Statement and the responses herein address the Staff's comments. If we can provide any further assistance, please do not hesitate to contact the undersigned.

Sincerely yours,
THE CRONE LAW GROUP, P.C.

Show Raw Text
CORRESP
 1
 filename1.htm

 July 8, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Industrial Applications and Services

 100 F Street, N.E.

 Washington, DC 20549

 Attn:
 Juan Grana

 Margaret Sawicki

 Re:
 ORIENTAL RISE HOLDINGS LIMITED

 Registration Statement on Form F-1

 Filed June 24, 2025

 File No. 333-288292

 Dear Mr. Grana:

 On behalf of Oriental Rise
Holdings Limited, a Cayman Islands corporation (the "Company"), we write in response to comments by the staff (the "Staff")
of the Securities and Exchange Commission (the "Commission") in its letter dated July 1, 2025, with reference to the Company's
Registration Statement on Form F-1 filed with the Commission on June 24, 2025, (the "Registration Statement"). We also simultaneously
file with the Commission an amended Registration Statement on Form F-1 in response to such comments.

 For the convenience of the
Staff, each of the Staff's comments is included and is followed by the corresponding response of the Company.

 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.

 Response : In response
to the Staff's comment, we have revised the heading of the subject risk factor on page 44 as requested.

 We thank the Staff for its
review of the foregoing and believe the Registration Statement and the responses herein address the Staff's comments. If we can
provide any further assistance, please do not hesitate to contact the undersigned.

 Sincerely yours,

 THE CRONE LAW GROUP, P.C.

 /s/ Joe Laxague

 Joe Laxague

 cc:
 Dezhi Liu

 Chief Executive Officer

 ORIENTAL RISE HOLDINGS LIMITED

 420 Lexington Avenue, Suite 2446, New York, NY 10170
| 646-861-7891

 1 East Liberty St., Suite 600, Reno, NV 89501 |
775-234-5221