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 August 19, 2025

ChiPing Cheung
Chief Executive Officer
Aureus Greenway Holdings Inc
2995 Remington Boulevard
Kissimmee, Florida 34744

 Re: Aureus Greenway Holdings Inc
 Registration Statement on Form S-1
 Filed August 4, 2025
 File No. 333-289229
Dear ChiPing Cheung:

 We have conducted a limited review of your registration statement and
have the
following comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1
Risk Factors
Risks Related to this Offering by the Selling Stockholders
Sales of a substantial number of our securities in the public market by the
selling
stockholder..., page 10

1. You state that "[t]he selling stockholders can sell, under this
prospectus, up to
 92,045,975 shares of common stock, constituting approximately 86.3% of
our
 outstanding shares of common stock (assuming and after giving effect to
the exercise
 of the pre-funded warrant shares, the common warrant shares A and common
warrant
 shares B, and placement agent warrants), as of July 31, 2025." Please
revise to state
 what percentage of your outstanding shares of common stock the resale
shares
 represent, and what percentage of your public float the resale shares
represent, in each
 case without giving effect to the exercise of the pre-funded warrant
shares, the
 August 19, 2025
Page 2

 common warrant shares A and common warrant shares B, and placement agent
 warrants. Revise to include similar disclosure in the risk factor on
page 27 as well.
Certain existing stockholders, including the selling stockholders, purchased or
may
purchase..., page 10

2. We note your disclosure that the selling stockholders "may" experience a
positive rate
 of return. We also note the selling stockholders paid $0.87 for one
share of common
 stock (or pre-funded warrant in lieu thereof), one common warrant A, and
one
 common warrant B, with exercise prices of $1.00 and $1.25, respectively.
Given your
 recent trading prices, it appears likely that the selling stockholders
will be able to
 purchase the Company's common stock at a significant discount. Please
revise this
 risk factor to more accurately address this risk.
General

3. Please provide us with a detailed legal analysis as to why the resale
transaction
 contemplated by the registration statement should not be categorized as
an indirect
 primary offering. In this regard, we note that:
 the Private Placement, under which the securities subject to resale
and related
 transactions were issued and sold to the selling stockholders,
closed on July
 25, 2025;
 you are registering for resale of up to 92,045,975 shares of common
stock, while
 you only had 14,608,988 shares of common stock outstanding, the
majority of
 which are owned by directors, officers, and/or related parties, as
of August 1,
 2025; and
 one selling stockholder, American Ventures LLC, Series XVI AGH,
holds up to
 89,655,171 out of 92,045,975 of the shares being registered for
resale.

 In your response, please also describe the relationship between the
Company and
 American Ventures and whether American Ventures is involved in the
business of
 underwriting securities. If the selling stockholders are engaged in an
indirect primary
 offering, revise to identify them as underwriters in the prospectus and
to set a fixed
 price for this offering. For guidance, please refer to Question 612.09
of our Securities
 Act Rule Compliance and Disclosure Interpretations.
 August 19, 2025
Page 3

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Eddie Kim at 202-551-8713 or Taylor Beech at 202-551-4515
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: William S. Rosenstadt
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