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Correspondence 0001013762-25-002603 from Delixy Holdings Ltd (DLXY)

Delixy Holdings Ltd
Date: March 26, 2025 · CIK: 0002025218 · Accession: 0001013762-25-002603

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File numbers found in text: 333-283248

Date
March 26, 2025
Author
Delixy Holdings Limited
Form
CORRESP
Company
Delixy Holdings Ltd

Letter

VIA EDGAR Division of Corporation Finance Office of Trade & Services Re: Delixy Holdings Limited Amendment No. 6 to Registration Statement on Form F-1 Filed March 19, 2025 File No. 333-283248

Dear Madam:

This letter is in response to your letter of March 25, 2025, in which you provided comments to Amendment No. 6 to the Registration Statement on Form F-1 of Delixy Holdings Limited (the "Company") filed with the U.S. Securities and Exchange Commission on March 19, 2025 ("Form F-1/A6"). We set forth below the comment in your letter relating to Form F-1/A6 followed by our response to the comment. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, Amendment No. 7 to the Registration Statement on Form F-1 ("Form F-1/A7") for filing with the Commission, which has been revised to reflect the Staff's comments.

Amendment No. 6 to Registration Statement on Form F-1 filed March 19, 2025

Exhibit Index, page II-4

1. Please obtain and file an updated consent from your independent registered public accounting firm (i.e., Exhibit 23.1).

RESPONSE : We note the Staff's comment, and in response hereto, respectfully advise the Staff that we have filed an updated consent from our independent registered public accounting firm as Exhibit 23.1 to Form F-1/A7.

We hope this response has addressed all of the Staff's concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact the Company's securities counsel William S. Rosenstadt, Esq. or Mengyi "Jason" Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or jye@orllp.legal.

Very truly yours,
Delixy Holdings Limited

Show Raw Text
CORRESP
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 filename1.htm

 Delixy Holdings Limited

 883 North Bridge Road

 #04-01 Southbank

 Singapore 198785

 March 26, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Attn:
 Ms. Rebekah Reed

 Re:
 Delixy Holdings Limited

 Amendment No. 6 to Registration Statement on Form F-1

 Filed March 19, 2025

 File No. 333-283248

 Dear Madam:

 This letter is in response to your letter of March
25, 2025, in which you provided comments to Amendment No. 6 to the Registration Statement on Form F-1 of Delixy Holdings Limited (the
"Company") filed with the U.S. Securities and Exchange Commission on March 19, 2025 ("Form F-1/A6"). We set forth
below the comment in your letter relating to Form F-1/A6 followed by our response to the comment. Concurrently with the submission of
this letter, we hereby transmit, via EDGAR, Amendment No. 7 to the Registration Statement on Form F-1 ("Form F-1/A7") for
filing with the Commission, which has been revised to reflect the Staff's comments.

 Amendment No. 6 to Registration Statement on
Form F-1 filed March 19, 2025

 Exhibit Index, page II-4

 1.
 Please obtain and file an updated consent from your independent registered public accounting firm (i.e., Exhibit 23.1).

 RESPONSE : We note the Staff's comment,
and in response hereto, respectfully advise the Staff that we have filed an updated consent from our independent registered public accounting
firm as Exhibit 23.1 to Form F-1/A7.

 We hope this response has addressed all of the
Staff's concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact the Company's securities counsel William S. Rosenstadt, Esq. or Mengyi "Jason" Ye, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal or jye@orllp.legal.

 Very truly yours,

 Delixy Holdings Limited

 /s/ Xie, Dongjian

 Name:
 Xie, Dongjian

 Title:
 Chairman and Chief Executive Officer