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 April 11, 2025

Junjie Zhang
Chief Executive Officer
Chagee Holdings Limited
Tower B, Hongqiao Lianhe Building
No. 99 Kaihong Road
Changning District, Shanghai
People s Republic of China, 200051

 Re: Chagee Holdings Limited
 Amendment No. 2 to Registration Statement on Form F-1
 Filed April 10, 2025
 File No. 333-286081
Dear Junjie Zhang:

 We have reviewed your amended registration statement and have the
following
comment(s).

 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.

Amendment No. 2 to Registration Statement on Form F-1 filed April 10, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Estimates
Fair value of our ordinary shares, page 98

1. Please provide us an analysis with quantified explanations for the
difference between
 the recent valuation of your ordinary shares used for your share-based
compensation
 awards on November 27, 2024 leading up to the IPO and the estimated
offering price.
Exhibit Index, page II-4

2. Please file a revised legal opinion that includes the specific number of
securities being
 registered, consistent with the prospectus cover page and filing fee
table.
 April 11, 2025
Page 2

 Please contact Stephen Kim at 202-551-3291 or Suying Li at 202-551-3335
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rebekah Reed at 202-551-5332 or Taylor Beech at 202-551-4515 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Li He
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