SecProbe.io

CORRESP
1
filename1.htm

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

October
25, 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 October 24, 2024 on the Company’s amendment No. 7 to the Company’s registration statement on Form F-1 filed
on October 18, 2024 (the “Registration Statement”).

Concurrently
with the submission of this letter, the Company is filing herewith amendment No. 8 (“Amendment No. 8”) 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. 8 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. 8.

    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

Management's
Discussion and Analysis of Financial Condition and Results of Operations Six Months Comparison of Our Results of Operations, page 48

    1.
    We
                                            note you deleted the Year-on-Year Comparison of your Results of Operations for the year ended
                                            December 31, 2023, and 2022 when you updated for the six months ended June 30, 2024. Please
                                            expand your discussion to also include the results of operations comparison for the year
                                            ended December 31, 2023 and 2022. Refer to Item 5 of Form 20-F.

In
response to the Staff’s comment, the Company has revised pages 49, 50 and 53 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 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.