SecProbe.io

August 13, 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. 4 to Registration Statement on Form F-1
Filed August 11, 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.
Amendment No. 4 to Registration Statement on Form F-1 filed August 11, 2025
Exhibit Index, page II-6
1.Please file a revised legal opinion as Exhibit 5.1 that includes the specific number of
securities being registered. Please also file a revised opinion of Hong Kong counsel
that includes counsel's consent to being named in the prospectus and the filing of
the opinion.

August 13, 2025
Page 2
            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