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    Li He

    Partner

    +852 2533 3306

    li.he@davispolk.com

    Davis Polk & Wardwell

    Hong Kong Solicitors

    The Hong Kong Club Building

    3A Chater Road

    Hong Kong

    davispolk.com

    Resident
    Hong Kong Partners

    Karen Chan **

    Yang Chu **

    James C. Lin *

    Gerhard Radtke *

    Martin Rogers **

    Miranda So *

    James Wadham **

    Xuelin Wang *

    Hong Kong Solicitors

    * Also Admitted in New York

    ** Also Admitted in England and Wales

February 1, 2024

    Re:
    XCHG Ltd (CIK: 0001979887)

Responses to the Staff’s Comments on the Amendment No. 4 to Draft Registration Statement on Form F-1 Submitted October 6, 2023

Confidential

Stephany Yang

Jean Yu

Patrick Fullem

Asia Timmons-Pierce

Division of Corporation Finance

Office of Manufacturing

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

On behalf of XCHG Limited
(the “Company”), a company incorporated under the laws of the Cayman Islands, we are submitting to the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) this letter setting forth the Company’s responses
to the comments contained in the Staff’s letter dated October 17, 2023 on the Company’s draft registration statement on Form
F-1 confidentially submitted on October 6, 2023 (the “Draft Registration Statement”). Concurrently with the submission
of this letter, the Company is filing its registration statement on Form F-1 (the “Registration Statement”) and certain
exhibits via EDGAR to the Commission. The Company is, concurrently with the Registration Statement, filing the draft registration statement
on Form F-1 initially confidentially submitted on June 2, 2023 and all amendments thereto that were previously submitted for the non-public
review of the Staff. The Company confirms that its securities have not been previously sold pursuant to an effective registration statement
under the Securities Act of 1933, as amended (the “Securities Act”). The Company plans to file an amendment to the Registration Statement containing the estimated price range and offering size, and to launch
the roadshow no earlier than 15 days after the date hereof.

The Company has responded
to all of the Staff’s comments by revising the Draft Registration Statement to address the comments, by providing an explanation
if the Company has not so revised the Draft Registration Statement, or by providing supplemental information as requested. The Staff’s
comments are repeated below in bold, followed by the Company’s response to such comments. We have included page numbers to refer
to the location in the Registration Statement where the language addressing a particular comment appears.

Davis Polk includes Davis Polk & Wardwell LLP and its associated entities.

*        *        *       *

Amendment No. 4 to Draft Registration Statement on Form F-1 submitted
October 6, 2023

General

 1. We note your response to prior comment 1. We also note the risk factors section has not been fully
restored to the existing disclosure as contained in the July 26, 2023 registration statement. Please restore your disclosure in the risk
factor section.

In response to the Staff’s comments,
the Company has revised disclosure on pages 30, 31 and 34 of the Registration Statement.

Related Party Transactions, page 120

 2. We note your disclosure that you have certain amounts due to Mr. Rui Ding that will be fully repaid
in September 2023. Please update this disclosure in a future amendment.

In response to the Staff’s comments,
the Company has revised disclosure on page 126 of the Registration Statement.

*        *        *        *

If you have any questions
regarding this submission, please contact Li He at +86-186-1110-6922 (li.he@davispolk.com) or Ran Li at +86-186-0006-9077 (ran.li@davispolk.com).

Thank you again for your time
and attention.

    Yours sincerely,

    /s/ Li He

    Li He

    cc:
    Ms. Xiaoling Song (Xiaoling@xcharge.com), Chief Financial Officer

    XCHG Limited

    Mr. Allen Wang, Esq., Partner

    Latham & Watkins LLP

    Mr. Johnny Lei, Partner

    KPMG Huazhen LLP