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    Loeb
                                            & Loeb LLP

    901
    New York Avenue, N.W.

    Washington,
    D.C. 20001

    345
    Park Avenue

    New
    York, NY 10154

    Main 202.618.5000

    Fax 202.217.2554

Main 212.407.4000

Fax 212.407.4990

September
30, 2025

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

  Attn:
  Abe Friedman

Lyn
Shenk

Alyssa
Wall

Taylor
Beech

  Re:
  Barentsz Capital Limited

Registration
Statement on Form F-1

Submitted
September 8, 2025

File
No. 333-290094

Dear
Messrs. Friedman, Shenk, Wall, and Beech:

On
behalf of our client, Barentsz Capital Limited (the “Company”), we hereby provide a response to the comments issued
in a letter dated September 29, 2025 (the “Staff’s Letter”) regarding the Company’s Registration
Statement on Form F-1. Contemporaneously, we are filing the Amendment No. 1 to the Registration Statement on Form F-1 via Edgar (the
“Amendment No. 1”).

In
order to facilitate the review by the staff of the Securities and Exchange Commission (the “Staff”) of the Amendment
No. 1 we have responded, on behalf of the Company, to the comments set forth in the Staff’s Letter on a point-by-point basis. The
numbered paragraphs set forth below respond to the Staff’s comments and correspond to the numbered paragraph in the Staff’s
Letter.

Los
Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com

     United States Securities and Exchange Commission

September 30, 2025

page2

For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.

Registration
Statement on Form F-1

Dilution,
page 45

1. Please
                                            revise your dilution table to present your net tangible book value as of April 30, 2025 on
                                            a per share basis.

Response:
The Company notes the Staff’s comment and in response thereto has revised the disclosures on page 45.

Financial
Statements, page F-1

2. Please
                                            tell us your consideration of giving retroactive effect to your financial statements to reflect
                                            the share reorganization that occurred on July 16, 2025. Refer to SAB Topic 4C.

Response:
The Company respectfully advises that in accordance with SAB Topic 4C and ASC Topic 260, which require that changes in capital structure
such as recapitalizations and stock splits be reflected retroactively in financial statements, the Company has retrospectively adjusted
the number of shares outstanding for all periods presented in the accompanying consolidated financial statements. The computation of
net income (loss) per share, weighted average shares outstanding, and other relevant share-based metrics have been adjusted to reflect
the post-reorganization share structure as if the share issuance had occurred at the beginning of the earliest period presented. The
Company notes the Staff’s comment and in response thereto has also revised the disclosure on pages F-3, F-4, F-5, F-16 and F-18

The
Amendment No. 1 also updates the cover page, “Corporate and Company Structure,” “Summary of Risk Factors,” “The
Offering,” “Risk Factors,” “Use of Proceeds,” “Capitalization,” “Dilution,” “Principal
Shareholders,” “Description of Securities,” “Shares Eligible for Future Sale,” “Underwriting,”
and “Expenses,” the “Exhibit Index” and the “Signatures” on pages 3-4, 7, 10,22-23, 29,
40-45, 76, 85, 91-92 and 98, respectively.

Please
call me at 212-407-4050 if you would like additional information with respect to any of the foregoing. Thank you.

Sincerely,

  /s/
  Erik Mengwall, Esq.

  Erik
  Mengwall, Esq.

  Partner

cc:
Wei Xiao, Chief Executive Officer of Barentsz Capital Limited