SecProbe.io

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

September 11, 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.

    Amendment
    No. 1 to Registration Statement on Form F-4

    Filed
    August 1, 2024

    File
    No. 333-280512

Ladies
and Gentlemen:

On
behalf of Elong Power Holding Ltd. (the “Company”), we hereby respond as follows to the comment letter from the staff of
the Securities and Exchange Commission (the “SEC”) dated August 8, 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 in Amendment
No. 2 to the Registration Statement. Capitalized terms used but not defined herein have the meanings ascribed to them in the Registration
Statement.

Amendment
No. 1 to Registration Statement on Form F-4 General

1. Please
                                            revise to fill in all blank and bracketed information in a pre-effective amendment to the
                                            proxy statement/prospectus.

We
have revised the Registration Statement, as requested, to include information available at this time. We intend to file a further amendment
to the Registration Statement to complete the remaining blanks (which primarily relate to the record and meeting dates and the
meeting location, along with associated information), prior to effectiveness of the Registration Statement.

PIPE
Financing, page 86

2. Please
                                            refer to prior comment 12 of our letter dated April 12, 2024. We note your response dated
                                            May 24, 2024 that you will update the disclosure to provide the requested information if
                                            and when the parties enter into subscription agreements with PIPE investors. We note further
                                            that you continue to discuss the PIPE financing throughout the proxy statement/prospectus
                                            and that you have a placeholder for PIPE Investors in the table on page 4. However, you have
                                            not updated your disclosure to date. Please revise to provide information regarding existing
                                            or potential PIPE agreements or consider whether such disclosure should be removed from the
                                            registration statement.

We
have revised the Registration Statement to included information about the PIPE, as requested.

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

GRAUBARD
MILLER

Securities
and Exchange Commission

September 11, 2024

Page
2

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