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August 31, 2023
Jison Lim
Director and Chairman
Ten-League International Holdings Ltd
16 Gul Drive
Singapore 629467
Re:Ten-League International Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted August 14, 2023
CIK No. 0001982012
Dear Jison Lim:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1, Submitted August 14, 2023
If we fail to implement and maintain an effective system of internal controls, we may be unable
to accurately or timely report our..., page 29
1.We note your response to comment 7 and reissue in part. We acknowledge the additional
language that discloses the risks posed by your personnel not having sufficient knowledge
of U.S. GAAP and SEC reporting requirements, but note that you have added mitigating
language suggesting that you will be successful in mitigating this risk.  Please revise to
clearly present the risk to investors and refrain from suggesting that risk is lesser or will
no longer exist based on the mitigation.

 FirstName LastNameJison Lim
 Comapany NameTen-League International Holdings Ltd
 August 31, 2023 Page 2
 FirstName LastName
Jison Lim
Ten-League International Holdings Ltd
August 31, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Year on Year Comparison of Our Results of Operations, page 48
2.We note your response to comment 10 and reissue the comment, in part.  When several
factors contributed to material fluctuations in your results, please revise to quantify each
factor cited so that investors may understand the magnitude and relative impact of each
factor.  You provided sales volume metrics which show increased number of units sold.
Please clarify if significant sales were to existing customers or new customers and address
any known or expected trends and uncertainties.  We note page F-26 shows sales to a
major customer went down from 18% in 2021 to 10% in 2022.  Refer to Item 5.D of Form
20-F, including the related Instructions.
Notes to the Consolidated Financial Statements
Note 12 Bank Borrowings, page F-19
3.We note your response to comment 19 and reissue the comment, in part.  Please provide
the significant terms of this financing facility.
Exhibits
4.We note your response to comment 20 that the agreements with Major Supplier were
entered into in the ordinary course of business and do not fall into any of the categories
under Item 601(b)(10)(ii) of Regulation S-K. Please tell us why you believe these
agreements do not fall under Item 601(b)(10)(ii)(B), which requires any contract upon
which you are substantially dependent to be filed as an exhibit. In this regard, we note
your disclosure that "substantially all" of your heavy equipment is purchased from Major
Supplier, and your disclosure that Major Supplier represented 71.3% and 60.4% of your
costs of revenue for the years ended December 31, 2021 and 2022. In the alternative,
please file your agreements with Major Supplier, including the distribution agreement(s),
service-dealer agreement(s), and dealership agreement(s) as exhibits to the registration
statement.
General
5.We note your response and revisions in response to comment 23.  Given your disclosure
that no sales of the resale shares will occur until the ordinary shares sold in the initial
public offering begin trading on Nasdaq, please tell us under what circumstance the resale
shares will be sold at the IPO price.  If the resale shares will not be sold until the shares
are trading on Nasdaq, it seems that the resale shares will only be sold at prevailing
market prices or in privately negotiated prices.  Please clarify and revise as necessary.

 FirstName LastNameJison Lim
 Comapany NameTen-League International Holdings Ltd
 August 31, 2023 Page 3
 FirstName LastName
Jison Lim
Ten-League International Holdings Ltd
August 31, 2023
Page 3
            You may contact Nasreen Mohammed at 202-551-3773 or Lyn Shenk at 202-551-3380 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louise L. Liu