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                              September 26, 2023

       Dezhi Liu
       Chief Executive Officer
       Oriental Rise Holdings Limited
       No. 48 Xianyu Road
       Shuangcheng Town, Zherong County
       Ningde City, Fujian Province
       People   s Republic of China

                                                        Re: Oriental Rise
Holdings Limited
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted September
1, 2023
                                                            CIK No. 0001964664

       Dear Dezhi Liu:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 2 to Draft Registration Statement on Form F-1 submitted
September 1, 2023

       Commonly Used Defined Terms, page ii

   1.                                                   We note your response
to previous comment 2 and re-issue the comment in part. Please
                                                        revise your definition
of "China" or the "PRC" to clarify that it includes the Hong Kong
                                                        and Macau Special
Administrative Regions. Additionally, please also state that the legal
                                                        and operational risks
associated with having substantially all of your operations in China
                                                        would apply to any
future operations in Hong Kong or Macau.
 Dezhi Liu
FirstName  LastNameDezhi   Liu
Oriental Rise Holdings Limited
Comapany 26,
September  NameOriental
               2023      Rise Holdings Limited
September
Page 2     26, 2023 Page 2
FirstName LastName
Our Business Strategy
Purchase of an automatic production line for production of refined tea, page 7

2.       We note your response to previous comment 5 and re-issue the comment.
The prospectus
         refers to anticipated purchases of (i) four automatic production lines
for production of
         primarily-processed white tea and (ii) one additional production line
for the production of
         refined tea. The existing disclosure you referenced regarding the
US$0.73 million (RMB
         4.90 million) purchase appears to relate only to the four production
lines for primarily-
         processed white tea. If known, please also provide an estimated cost
for the planned
         purchase of the fifth automatic production line for the production of
refined tea and note if
         you intend to make this purchase using the expected net proceeds from
the offering. If the
         estimated US$0.73 million purchase price includes all five production
lines, please revise
         the disclosure to clarify.
Description of Share Capital, page 136

3.       We see that in response to our prior comment 10 your indicate that the
9,599,900 shares
         were issued at $0.001 which appears to be consistent with your
disclosure on page II-1,
         however, your disclosure in footnote 17 indicates that they were
issued at $0.01. Please
         advise.
4.       Please refer to our prior comment 11. Please explain to us in further
detail how you
         determined the fair value of the common stock underlying your equity
issuances during
         the last twelve months, and provide us with the significant reasons
for the differences
         between the recent valuations of your common stock leading up to the
IPO and the
         estimated offering price.
Differences in Corporate Law
Shareholders' Suits, page 141

5.       We note your statement that "[o]ur post-offering articles of
association contains a
         provision by which our shareholders waive any claim or right of action
that they may
         have, both individually and on our behalf, against any director in
relation to any action or
         failure to take action by such director in the performance of his or
her duties with or for
         our Company, except in respect of any fraud, willful default or
dishonesty of such
         director." Please disclose whether this provision applies to actions
arising under the
         Securities Act or Exchange Act. If so, please also state that there is
uncertainty as to
         whether a court would enforce such provision and state that investors
cannot waive
         compliance with the federal securities laws and the rules and
regulations
         thereunder. Please add a risk factor disclosing this provision and
discussing the related
         risks, including that this provision may discourage claims and limit
shareholders' ability to
         bring claims.
 Dezhi Liu
FirstName  LastNameDezhi   Liu
Oriental Rise Holdings Limited
Comapany 26,
September  NameOriental
               2023      Rise Holdings Limited
September
Page 3     26, 2023 Page 3
FirstName LastName
General

6.       We note the changes you made to your disclosure appearing on the cover
page, Summary
         and Risk Factor sections relating to legal and operational risks
associated with operating
         in China and PRC regulations. It is unclear to us that there have been
changes in the
         regulatory environment in the PRC since the amendment that was filed
on July 7, 2023,
         warranting revised disclosure to mitigate the challenges you face and
related disclosures.
         The Sample Letters to China-Based Companies sought specific disclosure
relating to the
         risk that the PRC government may intervene in or influence your
operations at any time,
         or may exert control over operations of your business, which could
result in a material
         change in your operations and/or the value of the securities you are
registering for sale.
         We remind you that, pursuant to federal securities rules, the term
control    (including the
         terms    controlling,       controlled by,    and    under common
control with   ) as defined in
         Securities Act Rule 405 means    the possession, direct or indirect,
of the power to direct or
         cause the direction of the management and policies of a person,
whether through the
         ownership of voting securities, by contract, or otherwise.    The
Sample Letters also sought
         specific disclosures relating to uncertainties regarding the
enforcement of laws and that
         the rules and regulations in China can change quickly with little
advance notice. We do
         not believe that your revised disclosure conveys the same risk. Please
restore your
         disclosures in these areas to the disclosures as they existed in the
registration statement as
         of July 7, 2023.
       You may contact Julie Sherman at 202-551-3640 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-7153
with any other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Industrial Applications and
                                                                Services
cc:      Joe Laxague, Esq.