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CORRESP
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 Davis Polk &
 Wardwell
 Hong Kong Solicitors
 The Hong
 Kong Club Building
 3A Chater Road
 Hong Kong
 davispolk.com

 Resident Hong Kong Partners

 James C. Lin *
Martin Rogers **
Miranda So *

 James Wadham
 **
 Xuelin Wang
 *

 Hong Kong Solicitors
* Also Admitted in New York
** Also Admitted in England and Wales

 April 3, 2025

 Re:
 Chagee Holdings Limited (CIK: 0002013649) Responses to the Staff's Comments on the Registration Statement on Form F-1 filed March 25, 2025

 Stephen Kim

 Suying Li

 Rebekah Reed

 Taylor Beech

 Division of Corporation Finance

 Office of Trade & Services

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Ladies and Gentlemen:

 On behalf of our client, Chagee Holdings Limited (the "Company"),
a company incorporated under the laws of the Cayman Islands, we are filing herewith the Company's amendment No. 1 to the registration
statement on Form F-1 (the "Amendment No. 1 to the Registration Statement") and certain exhibits via EDGAR with
the Securities and Exchange Commission (the "Commission").

 Concurrently
with the filing of the Registration Statement, the Company is hereby in this letter submitting its responses to the comments contained
in the letter from the staff of the Commission (the "Staff") dated April 2, 2025 on the Company's registration
statement on Form F-1 filed on March 25, 2025 (the "Registration Statement"). The Company has responded to the Staff's
comments by revising the Registration Statement. The Staff's comments are repeated below in bold, followed by the Company's
response to such comments. The Company has included page numbers to refer to the location in the Amendment No. 1 to the Registration
Statement where the language addressing a particular comment appears.

 The
Company plans to file an amendment to the Registration Statement containing the estimated price range and launch the road show as early
as April 9, 2025 and request effective time on April 16, 2025, subject to market conditions. The Company, together with the
underwriters, will file joint acceleration requests in time before the requested effective time once outstanding comments are resolved.
The Company would greatly appreciate the Staff's continuing assistance in meeting the proposed timetable.

 * * * *

 Davis
Polk includes Davis Polk & Wardwell LLP and its associated entities.

 Registration
Statement on Form F-1 filed March 25, 2025

 Description of Share Capital

 Ordinary Shares

 Conversion Rights, page 156

 1. Please disclose the circumstances under which conversion of
the Class B ordinary shares into Class A ordinary shares is mandatory, as set forth in Section 59(d)(ii) of the Fourth
Amended and Restated Memorandum and Articles of Association. Provide this disclosure where you discuss the dilution risks associated
with your dual-class share structure at page 66 as well.

 The Company respectfully advises the Staff that the Company
has disclosed the circumstances under which conversion of the Class B ordinary shares into Class A ordinary shares is mandatory
on pages 66 and 157.

 Notes to the Consolidated Financial Statements

 2. Significant Accounting Policies

 (hh) Segment Reporting, page F-26

 2. You state on page F-27 that you have adopted ASU 2023-07 in the consolidated financial statements for the year ended December 31,
2024. Please tell us your consideration for disclosing the information required in ASC 280-10-50-20 through 50-31.

 The
Company respectfully advises the Staff that the Company has evaluated each of the disclosure requirements in ASC280-10-50-21 through
50-31, as follows, by either referencing to the Company's disclosure or explaining why such disclosure requirement is not applicable
to the Company. In addition, the Company has further expanded the disclosure on Pages F-26.

 Required disclosures
 The Company's disclosure

 General information [280-10-50-21]

 Factors used to identify reportable segments

 See below disclosure extracted from Note 2(hh)

 The Group's CODM reviews the consolidated results when
making decisions about allocating resources and assessing performance of the Group as a whole and hence, the Group operates and manages
its business as a single operating and reportable segment.

 Types of products and services by segment
 See Note 14.

 Title and position of the CODM

 See below disclosure extracted from Note 2(hh)

 Based on the criteria established by ASC 280, the Group's CODM has been identified as the founder, chairman of the board of directors
 and chief executive officer of the Group.

 Information about segment profit or loss and assets [280-10-50-22 – 50-29]

 Profit or loss measure, with additional measures permitted under certain conditions

 See below disclosure added to Note 2(hh) in response to the Staff's
 comment.

 The Group's CODM uses consolidated net (loss)/income
as the measure of profit or loss to monitor budget versus actual results and decide where to allocate and invest additional resources
to continue growth.

 April 3, 2025 2

 Significant expenses and other segment items

 See below disclosure added to Note 2(hh) in response to the Staff's
comment.

 Significant segment expenses and other segment items are consistent
with the financial information included on the consolidated statements of operations and comprehensive (loss)/income.

 Other quantitative profit or loss information
 Other quantitative profit and loss information, including revenues from external customers, interest income, interest expense, depreciation and amortization, income tax expense (benefit), share-based compensation and other significant noncash items, are consistent with the financial information included in the consolidated financial statements.

 Asset information, including a segment assets measure and quantitative information about segment assets

 See below disclosure added to Note 2(hh) in response to the Staff's
comment.

 The measure of segment assets is reported on the consolidated
balance sheet as total assets.

 Qualitative measurement disclosures about profit or loss and assets

 Since the Group operates and manages its business as a single
operating and reportable segment, the disclosure requirements of ASC280-10-50-29(a)-(e) are not applicable. In addition, the below
disclosure was added to Note 2(hh) in response to the Staff's comment.

 The Group's CODM uses consolidated net (loss)/income as
 the measure of profit or loss to monitor budget versus actual results and decide where to allocate and invest additional resources
 to continue growth.

 Reconciliations (to corresponding consolidated amount) [280-10-50-30 – 280-10-50-31]

 Total reportable segment revenues
 Since the Group operates and manages its business as a single operating and reportable segment and the measurements of segment profit or loss and segment assets are reported on the consolidated financial statements, such disclosure requirements on reconciliations are not applicable.

 Total reportable segment amount for each profit or loss measure

 Total reportable segment assets

 Total reportable segment amounts for other significant items disclosed, except significant segment expenses and other segment items

 * * * *

 April 3, 2025 3

 If
you have any questions regarding this submission, please contact Li He at +852 2533-3306 ( li.he@davispolk.com ) and Kevin
Zhang at +852 2533-3384 ( kevin.zhang@davispolk.com ).

 Thank you again for your time
and attention.

 Yours sincerely,

 /s/ Li He

 Li
He

 cc:
 Mr. Junjie Zhang, Chief Executive Officer

 Chagee Holdings Limited

 Ms. Shuang Zhao, Partner

 Cleary Gottlieb Steen & Hamilton LLP

 Mr. Allen Lu, Partner

 KPMG Huazhen LLP

 April 3, 2025 4