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    Davis Polk & Wardwell

                           Hong Kong Solicitors

                           The Hong Kong Club Building

                           3A Chater Road

                           Hong Kong

                           davispolk.com

    Resident Hong Kong Partners

    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

    August 16,
    2024

    Re:
    XCHG Ltd (CIK:
    0001979887)

    Amendment No. 2 to Registration Statement on Form F-1 Filed July 29, 2024

    File No. 333-276802

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 August 2, 2024 on the Company’s
registration statement on Form F-1 publicly filed on July 29, 2024 (the “Registration Statement”). Concurrently
with the submission of this letter, the Company is publicly filing its revised registration statement on Form F-1 (the “Revised
Registration Statement”) via EDGAR to the Commission for review in accordance with the procedures of the Commission. 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 has responded to all of the Staff’s comments by revising the Registration Statement to address the comments, by providing
an explanation if the Company has not so revised the 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 Revised Registration Statement where the language addressing a particular comment appears.

Subject
to the Staff's review and market conditions, the Company currently expects to price the offering as early as after market closes on August 29,
2024. The Company would greatly appreciate the Staff's assistance in meeting its desired timetable for the offering.

August
16, 2024

*	     *	     *	     *

Amendment
No. 2 to Registration Statement on Form F-1 filed on July 29, 2024

Notes to the Unaudited Condensed
Consolidated Financial Statements

16. Subsequent Events, page F-60

 1. We
                                            note your disclosure that you considered subsequent events through July 12, 2024, which
                                            was the date the unaudited condensed consolidated financial statements were issued. Please
                                            explain why the subsequent events were evaluated through July 12, 2024 when the registration
                                            statement was filed on July 29, 2024.

In response
to the Staff’s comment, the Company has revised the disclosure on page F-60 of the Registration Statement to clarify that
the subsequent events were evaluated through July 29, 2024, which was the date the unaudited condensed consolidated financial statements
were issued.

*	     *	     *	     *

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August
16, 2024

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

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