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CORRESP
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Morgan,
Lewis & Bockius

c/o
19th Floor,

Edinburgh
Tower, The Landmark

15
Queen’s Road Central, Hong Kong

Direct:
+852.3551.8500

Fax:
+852.3006.4346

www.morganlewis.com

WRITER’S
DIRECT LINE

+852.3551.8688

WRITER’S
EMAIL

louise.liu@morganlewis.com

March
6, 2024

Confidential

Ms.
Nasreen Mohammed

Ms.
Lyn Shenk

Mr.
Nicholas Nalbantian

Ms.
Erin Jaskot

Division
of Corporation Finance

Office
of Trade & Services

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Re:
    Ten-League
                                            International Holdings Limited (CIK No. 0001982012)

    Registration
    Statement on Form F-1 (File No. 333-275240)

Dear
Ms. Mohammed, Ms. Shenk, Mr. Nalbantian, Ms. Jaskot:

On
behalf of our client, Ten-League International Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands
(the “Company”), we submit 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 March 4, 2024 on the Company’s amendment No. 3 to the Company’s registration statement on Form F-1 filed on
February 23, 2024 (the “Registration Statement”).

Concurrently
with the submission of this letter, the Company is filing herewith amendment No. 4 (“Amendment No. 4”) to the Registration
Statement via EDGAR to the Commission.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Amendment No. 4 where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the Amendment No. 4.

    Partners:

    Edwin
    Luk, June Chan, Connie Cheung, Keith Cheung*#, William Ho, David Liao, Charles Mo, Billy Wong and Yan Zeng

    Registered
    Foreign Lawyers:

    Eli
    Gao (New York), Maurice Hoo (California), Alice Huang (California), Mathew Lewis (New York), Louise Liu (New York), Vivien Yu (New
    South Wales), and Ning Zhang (New York)

    *China-Appointed
    Attesting Officer

    #Notary
    Public of Hong Kong

    19th
                                            Floor

    Edinburgh
    Tower, The Landmark

    15
    Queen’s Road Central

    Hong
    Kong

    ☐ +852.3551.8500

    ☐
    +852.3006.4346

Consolidated
Statements of Changes in Shareholders’ Equity, page F-5

    1.
    We
    note your disclosure here and elsewhere in your filing that 27,796,502 shares are outstanding from January 1, 2021 to prior to the
    offering. We also noted you retrospectively adjusted for the February 16, 2024 stock split and share surrender transaction. Please
    provide your calculation of how you computed the revised outstanding shares and the guidance you relied upon to support your accounting.

The Company respectfully submits that
the calculation and computation of the revised outstanding shares of the Company in Amendment No. 4 was based on:

 1. The Company’s 1,000 shares issued
                                            at its incorporation on March 17, 2023.

 2. An additional share issuance of 999,000
                                            shares to the then existing shareholders of the Company pro rata to their then shareholdings
                                            in the Company on February 16, 2024. The total number of outstanding shares of the Company
                                            after the additional share issuance was 1,000,000 shares.

 3. A forward split on the basis of 40 shares for every one share of the Company on February 16,
                                                                     2024. The total number of outstanding shares of the Company after the forward split was 40,000,000 shares.

 4. The surrender of 10,409,585 shares by
                                            Ten-League Corp, 597,971 shares by LJSC Holdings, 597,971 shares by Undersea Capital and
                                            597,971 shares by Jules Verne on February 16, 2024. The total number of outstanding shares
                                            of the Company after the surrender is 27,796,502 Shares.

The figure presented in Amendment No.
4 corresponds to the final number of outstanding shares listed as per point 4 above.

The guidance the Company had relied
on is based on the SEC’s Codification of Staff Accounting Bulletins, Topic 4: Equity Accounts, C. Change in Capital Structure,
whereby the interpretive response suggested by the SEC is that changes in the capital structure must be given retroactive effect in the
balance sheet. An appropriately cross-referenced note should disclose the retroactive treatment, explain the change made and state the
date the change became effective. In addition, the Company also relied on ASC 260-10-55-21, which states that in cases where the number
of common shares outstanding increases due to a stock dividend or stock split (as outlined in Subtopic 505-20), or decreases due to a
reverse stock split, the computations of basic and diluted earnings per share (EPS) should be adjusted retroactively for all periods
presented to reflect the change in capital structure. The above paragraphs correspond with SEC suggested responses as the corporate actions
adopted fall within the definition of capital structure changes.

If you have
any questions regarding the Registration Statement, please contact the undersigned by phone at +852.3551.8688 or via e-mail at louise.liu@morganlewis.com.

    Very
    truly yours

    By:
    /s/
    Louise L. Liu

    Louise
    L. Liu

    Partner

    cc:
    Jison
    Lim, Director and Chairman, Ten-League International Holdings Limited

    Lim
    Boon Ping, Chief Financial Officer, Ten-League International Holdings Limited

    Henry
    F. Schlueter, Esq., Schlueter & Associates, P.C.