United States securities and exchange commission logo





                               May 17, 2024

       Taylor Zhang
       Chief Financial Officer
       TenX Keane Acquisition
       420 Lexington Ave Suite 2446
       New York, NY 10170

                                                        Re: TenX Keane
Acquisition
                                                            Amendment No. 2 to
Registration Statement on Form S-4
                                                            Filed May 3, 2024
                                                            File No. 333-275506

       Dear Taylor Zhang:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies to your
facts and circumstances
       or do not believe an amendment is appropriate, please tell us why in
your response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our February 13,
2024 letter.

       Amendment No. 2 to Registration Statement on Form S-4

       Risk Factors and Risk Factors Summary
       If TenX is deemed to be an investment company under the Investment
Company Act..., page 92

   1.                                                   We note your response
to our prior comment 4 regarding the risks associated with being
                                                        deemed to be an
unregistered investment company. Please also state that if you are
                                                        deemed to be an
unregistered investment company you may be required to change your
                                                        operations and that
with respect to the consequences to investors any TenX Rights would
                                                        expire worthless.
       The TenX Board's Discussion of Valuation and Reasons for the
Approval..., page 142

   2.                                                   We note that SpinCo
agreed to transfer the patent rights immediately after it is
                                                        commercially able to do
so. Please clarify if there is an agreement in place. If so, please
                                                        discuss all material
terms and file such agreement as an exhibit or otherwise advise.
 Taylor Zhang
TenX Keane Acquisition
May 17, 2024
Page 2
LYMPHIR (denileukin diftitox-cdxl)
Phase 3 Trial (E7777-G000-302) Design, page 193

3.    You make several assertions regarding the safety and efficacy of your
lead candidate
      LYMPHIR. Please revise your disclosure to eliminate suggestions of safety
and efficacy
      as those determinations are solely within the authority of the FDA or
comparable foreign
      regulators. Note that you may present clinical trial end points and
objective data without
      concluding efficacy and you may state that your product is well
tolerated, if accurate. For
      instance, and without limitation, we note the following statements:
          "the primary and secondary endpoints of Study E7777-G000-302
demonstrated safety
           and efficacy of 9   g/kg/day LYMPHIR...";
          "per protocol, LYMPHIR was considered efficacious..."; and
          "FDA accepted the Study E7777-G000-302 data which demonstrated both
safety and
           efficacy...".

       Please contact Christine Torney at 202-551-3652 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Doris Stacey Gama at 202-551-3188 or Tim Buchmiller at 202-551-3635
with any other
questions.



                                                           Sincerely,
FirstName LastNameTaylor Zhang
                                                           Division of
Corporation Finance
Comapany NameTenX Keane Acquisition
                                                           Office of Life
Sciences
May 17, 2024 Page 2
cc:       Tammara Fort, Esq.
FirstName LastName