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
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CORRESP
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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