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CORRESP
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Graubard
Miller

The
Chrysler Building

405
Lexington Avenue

New
York, N.Y. 10174-4499

(212)
818-8800

    Facsimile

    direct
    dial number

    (212)
    818-8881

    (212)
    818-8602

    email
    address

    eschwartz@graubard.com

August
1, 2024

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Manufacturing

100
F Street, NE

Washington,
D.C. 20549

    Re:
    Elong
    Power Holding Ltd.

    Registration
    Statement on Form F-4

    Filed
    June 27, 2024

    File
    No. 333-280512

Ladies
and Gentlemen:

On
behalf of Elong Power Holding Limited (the “Company”), we hereby respond as follows to the comment letter from the
staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) dated July 10, 2024,
relating to the above-referenced Registration Statement on Form F-4 (the “Registration Statement”). Captions and page
references herein correspond to those set forth on the amended Registration Statement.

Capitalized
terms used but not defined herein have the meanings ascribed to them in the Registration Statement.

Registration
Statement on Form F-4 filed June 27, 2024

Summary
of the Proxy Statement/Prospectus

PRC
Approvals of and the Filing Required for the Business Combination, page 32

    1.
    We
    note your revisions in response to prior comment 2 and reissue in part. Please revise to state that the PRC government may intervene
    in or influence your operations at any time.

We
have revised the disclosure in the Registration Statement as requested.

Recent
Developments, page 170

    2.
    We
    note your disclosure stating that subsidiaries of Elong have entered into an energy storage equipment sales agreement with Nengjian
    Henan Urban Construction Engineering Co. on May 18, 2024, and a battery pack sales agreement with Beijing Xinyuanhengyuan Technology
    Development Co., Ltd., on June 12, 2024. Please revise your disclosure to describe the material terms of these agreements. In addition,
    if Elong considers these agreements to be material to your business and operations, include them as exhibits to this registration
    statement or tell us why you are not required to do so.

We
have revised the Registration Statement to disclose the material terms of the above-referenced agreements as requested.

We
respectfully submit, however, that the agreements are not required to be filed as exhibits to the Registration Statement. The agreements
are for the sale of high-power lithium-ion batteries for EV charging and large-capacity lithium-ion batteries for an energy storage system.
As a developer, manufacturer and seller of lithium-ion batteries, each agreement is “such as ordinarily accompanies the kind of
business conducted by” Elong and its subsidiaries, as described in Item 601(b)(10)(ii) of Regulation S-K.

Furthermore,
Elong’s business is not “substantially dependent” on the agreements, as described in Item 601(b)(10)(ii)(B) of Regulation
S-K. Elong does not depend on either agreement operationally, technologically or otherwise. In addition, the agreements do not constitute
“continuing contracts to sell the major part of” Elong’s products. First, each agreement is short term in nature. Elong
expects that the contracts will be fulfilled before the end of the calendar year. Accordingly, Elong is not relying on either contract
to generate a substantial portion of its revenue over an extended period of time. Second, Elong expects to sign numerous similar agreements
with its customers. As Elong’s business continues to ramp up in coming quarters, Elong expects that revenues attributable to each
of these agreements will increasingly account for a relatively less significant part of its overall revenues. For these reasons, Elong
does not believe that the overall success of its business will be “substantially dependent” on any either of these agreements
or on any one sales agreement of this type.

For
the foregoing reasons, Elong has concluded that Item 601(b)(10) of Regulation S-K does not require that the agreements be filed as exhibits
to the Registration Statement.

*************

If
you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

    Sincerely,

    /s/
    Eric T. Schwartz

    Eric
    T. Schwartz

    cc:
    Xiaodan
    Liu, Chief Executive Officer