SecProbe.io

April 14, 2025
Hui Xu
Chief Executive Officer
Texxon Holding Ltd.
703, Block A, 1799 Wuzhong Road
Minhang District
Shanghai, China, 200335
Re:Texxon Holding Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed March 31, 2025
File No. 333-281530
Dear Hui Xu:
            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. Unless we note
otherwise, any references to prior comments are to comments in our August 27, 2024 letter.
Amendment No. 1 to Registration Statement on Form F-1 filed March 31, 2025
Risk Factors
Risks Related to Our Business and Industry
Pending or future litigations, arbitrations, governmental investigations and other legal
proceedings..., page 49
1.Revise to address the arbitration proceeding brought by Shanghai Kuanyu Digital
Technology Co., Ltd. in January 2025, including relief sought. In this regard, we note
that your disclosure at page 111 suggests that this proceeding could have a material
adverse effect on your business or financial condition.

April 14, 2025
Page 2
Business
Material Contracts, page 108
2.You state that pursuant to the Polystyrene Factory Construction Agreement entered
into April 2022, construction "is required to be completed within 24 months" and that
the Land Use Rights Transfer Agreement contemplates that construction be "complete
before January 28, 2025." As you suggest that construction of the polystyrene factory
will be completed "in the second quarter of 2025," please clarify whether you have
missed any applicable deadlines under these agreements. If so, disclose any penalties
that you face and whether such deadlines can or have been extended. Update your
related risk factor disclosure as appropriate.
Related Party Transactions, page 132
3.For each related party loan, revise to also disclose the amount due to such related
party as of the most recent practicable date. Refer to Item 7.B of Form 20-F.
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue recognition, page F-9
4.We have reviewed your response to prior comment 3. Please revise your accounting
policy disclosures here, and on page 93, to include the factors and judgements
reflected in your response. Additionally, your current disclosure states the selling
price is determined "by adding a certain gross profit to the purchase price" whereas
your correspondence states you provide a quotation to the customer and your
purchase price "is negotiated independently of the customer contract." Please review
your disclosure to ensure it is consistent with the company's policy. Refer to ASC
235-10-50-3
Exhibit Index, page II-6
5.We note your footnote disclosure to Exhibits 10.15, 10.17, and 10.18. To the extent
you are relying on Item 601(b)(10)(iv) of Regulation S-K to omit certain information
(as opposed to Item 601(a)(6) of Regulation S-K), please include a prominent
statement on the first page of the redacted exhibits that certain identified information
has been excluded from the exhibit because it is both not material and is treated as
private or confidential and include brackets indicating where the information is
omitted from the filed version of the exhibits. Refer to Item 601(b)(10)(iv) of
Regulation S-K.

April 14, 2025
Page 3
            Please contact Abe Friedman at 202-551-8298 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rebekah Reed at 202-551-5332 or Donald Field at 202-551-3680 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Wei Wang