SecProbe.io

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Ross
Law Group, pllc

1430 Broadway, Suite 1804

New York, NY 10018

United States

+1 212 884 9333

www.RossLawGroup.co

December 19, 2023

Mr. Jay Ingram

Division of Corporation Finance

Office of Manufacturing

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    Semilux International Ltd.

    Registration Statement on Form F-4

    Filed on December 1, 2023

    File No. 333-275857

Dear Mr. Jay Ingram:

The undersigned, on behalf
of Semilux International Ltd. (the “Company”), respectfully submits this correspondence to the staff (the “Staff”)
of the Securities and Exchange Commission in response to its letter dated December 14, 2023, relating to the Company’s Registration
Statement on Form F-4 filed on December 1, 2023 (the “Registration Statement”). On behalf of the Company,
we are concurrently filing an Amendment No. 1 to the Registration Statement (“Amendment No. 1”), which reflects
the Company’s responses to the comments received by the Staff and certain updated information. Capitalized terms used herein but
not defined herein have the definitions assigned to them in Amendment No. 1.

To facilitate the Staff’s
review, we have included in this letter the caption and comment from the Staff’s comment letter in bold text and have provided the
Company’s response immediately following each comment including, where applicable, a cross-reference to the location in Amendment
No. 1 of changes made in response to the Staff’s comment.

Registration Statement on Form F-4

Unaudited Pro Forma Condensed Consolidated
Financial Information

Introduction, page 156

1. In the third paragraph you state that the “unaudited pro forma condensed combined balance sheet
as of September 30, 2023, gives pro forma effect to the Transactions as if they had been consummated as of January 1, 2022, the beginning
of the earliest period presented.” Please revise this statement and the related pro forma adjustments, as applicable, to reflect
that the pro forma balance sheet as of September 30, 2023 gives pro forma effect to the transactions as if they were consummated on September
30, 2023.

Response: In response to the Staff’s comments, the Company
has revised the disclosure on page 156 of Amendment No. 1.

Semilux International Ltd.

December 19, 2023

Page 2 of 2

Unaudited Pro Forma Combined Balance Sheet Adjustments, page 161

2. We refer to footnotes (2) and (3). Please ensure that amounts appearing in your footnotes agree to the corresponding adjustment
amounts on the pro forma balance sheet.

Response: In response to the Staff’s comments, the Company
has revised the disclosure on pages 160 and 161 of Amendment No. 1.

3. We refer to footnote (4). In the last sentence of your description of scenario 2, you refer to $78.36 million to be paid out of
the trust account for redemptions. Please remove this sentence or tell us how this statement applies to scenario 2.

Response: In response to the Staff’s comments, the Company
has revised the disclosure on page 161 of Amendment No. 1.

Company Management’s Discussion and Analysis of Financial
Condition and Results of Operations

Components of Results of Operations Revenue, page 205

4. It appears that total revenue for the nine months ended September 30, 2023 and September 30, 2022 is NTD 23,168,000 and NTD 80,322,000,
respectively. Please revise your table as appropriate.

Response: In response to the Staff’s comments, the Company
has revised the disclosure on page 205 of Amendment No. 1.

If the Staff has any questions
or comments concerning the foregoing, or if it requires any further information, please contact me at gary@rosslawgroup.co or by telephone
at (212) 884-9333.

    Very truly yours,

    ROSS LAW GROUP, PLLC

    /s/ Gary J. Ross

    Gary J. Ross

    cc:
    Yung-Peng Chang, Semilux International Ltd.

    Francis Chang, Landi Law Firm

    Joel Rubinstein, White & Case LLP

    Jessica Zhou, White & Case LLP