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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

November
7, 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. 8 to Registration Statement on Form F-1

    Filed
    on October 25, 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 October 28, 2024 on the Company’s
Registration Statement filed on October 25, 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. 8 to Registration Statement on Form F-1, Filed October 25, 2024

Exhibits

    1.
    We
    note counsel’s opinion that the statements under the caption “Material Tax Considerations” in the prospectus forming
    part of the Registration Statement, to the extent that they constitute statements of Cayman Islands law, are accurate in all material
    respects. This statement fails to identify the specific tax issue on which counsel is opining. Please have counsel revise to opine
    on the tax consequences of the offering, not the manner in which they are described in the prospectus. Refer to Section III.C.2.
    of Staff Legal Bulletin No. 19 (CF) located at our web-site.

In
response to the Staff’s comment, counsel’s opinion letter in Exhibit 5.1 has been revised accordingly.

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.