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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

July
15, 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

    Response
    to the Staff’s Comments on

    Amendment
    No. 5 to Registration Statement on Form F-1

    Filed
    on June 4, 2024

    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 are filing herewith the Company’s registration statement on Form F-1 (the “Registration
Statement”) and certain exhibits via EDGAR to the Securities and Exchange Commission (the “Commission”).

Concurrently
with the filing of the Registration Statement, the Company is hereby in this letter setting forth the Company’s responses to the
comments contained in the letter from the staff of the Commission (the “Staff”) dated June 17, 2024 on the Company’s
Registration Statement filed on June 4, 2024.

The
Company respectfully advises the Staff that, subject to market conditions, it plans to launch the road show for the proposed offering
as soon as possible. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed
timetable for the offering.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined
herein have the meanings set forth in the Registration Statement.

    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

Amendment
No. 5 to Registration Statement on Form F-1, Filed June 4, 2024

Capitalization,
page 36

    1.
    The
    column heading shows the capitalization table is presented in US dollars. However, the “Actual” balances appear to be
    in Singapore $ as of December 31, 2023. Please revise or advise.

In
response to the Staff’s comment, the Company has revised the disclosure on page 36 of the Registration Statement.

    2.
    We
    note the “As adjusted” column in your capitalization table. Please explain how you computed “As adjusted”
    additional paid-in capital balance of $10,096,000 considering $7 million offering proceeds after deducting expenses on page 35. Please
    revise or advise.

In
response to the Staff’s comment, the Company has revised the disclosure on page 36 of the Registration Statement.

Liquidity
and Capital Resources, page 50

    3.
    We
    note gross accounts receivables increased approximately S$8.3 million or 49% but the allowance for doubtful accounts decreased S$0.6
    million or 14% for the year ended December 31, 2023. We also note the aging of accounts receivables specifically over 120 days increased
    S$2.5 million or 54%. Given the significance of accounts receivables over 120 days, please consider expanding your schedule (such
    as past due 180, 360 and over 360 days, as applicable). Also in your working capital discussion, please discuss the underlying reasons
    for the increase in the days accounts receivables remain outstanding.

In
response to the Staff’s comment, the Company has revised the disclosure on page 52 of the Registration Statement.

Principal
and Selling Shareholders, page 112

    4.
    Please
                                                         include an address for each person listed. We note that you previously included an address at 16 Gul Drive, but this section is now
                                                         blank.

In
response to the Staff’s comment, the Company has revised the disclosure on page 112 of the Registration Statement.

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

    Very
    truly yours

    By:
    /s/
    Louise Liu

    Louise
    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.