SecProbe.io

CORRESP
1
filename1.htm

September
26, 2025

VIA
EDGAR

Securities
and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    RE:
    ELC
    Group Holdings Ltd. (the “Company”)

    Registration
    Statement on Form F-1, as amended

    (File
    No. 333-285524) (the “Registration Statement”)

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended (the “Securities Act”),
D. Boral Capital LLC, as representative of the underwriters of the offering, hereby joins the request of the Company that the effective
date of the above-captioned Registration Statement be accelerated so as to permit it to become effective on Tuesday, September 30, 2025,
at 4:00 p.m., ET, or as soon thereafter as practicable.

Pursuant
to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act, we, acting on behalf
of the several underwriters, wish to advise you that, through September 26, 2025, we distributed to each underwriter or dealer, who is
reasonably anticipated to be invited to participate in the distribution of the security, as many copies, as well as “E-red”
copies of the Preliminary Prospectus dated August 25, 2025, as appears to be reasonable to secure adequate distribution of the preliminary
prospectus. We have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934,
as amended.

    Very truly yours,

    D. Boral Capital LLC

    By:
    /s/
    Stephanie Hu

    Name:
    Stephanie
    Hu

    Title:
    Co-Head
    of Investment Banking