United States securities and exchange commission logo





                             December 27, 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
Registration Statement on Form F-1
                                                            Filed December 14,
2023
                                                            File No. 333-274976

       Dear Dezhi Liu:

            We have reviewed your amended registration statement and have the
following
       comment(s).

              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 December 1, 2023
letter.

       Amendment No. 2 to Registration Statement on Form F-1 filed December 14,
2023

       Cover Page

   1.                                                   We note that the cover
page states: "Up to 1,000,000 Ordinary Shares may be offered for
                                                        resale or otherwise
disposed of by each shareholder named in this prospectus (the "Selling
                                                        Shareholders")." Please
revise to clarify this is a separate prospectus.
       General

   2.                                                   We note your revised
disclosure in response to previous comment 6 and reissue the
                                                        comment. Please restore
your disclosures to the disclosures as they existed in the
                                                        registration statement
as of July 7, 2023.
 Dezhi Liu
Oriental Rise Holdings Limited
December 27, 2023
Page 2
3.    We note the Selling Shareholders section was removed from the Public
Offering
      Prospectus, please revise to reinstate this section in the Public
Offering Prospectus so that
      investors in the public offering have this information as well.
Resale Prospectus Cover Page, page Alt-i

4.    We note that you have included separate pages for the resale prospectus.
Please revise the
      cover page of the resale prospectus to include the information from the
cover page of the
      public offering prospectus, including the disclosure related to your
organizational
      structure, risks related to operations in China and Hong Kong, how you
will refer to the
      holding company and subsidiaries and how cash is transferred in your
organization.

       Please 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 Sawicki at 202-551-7153 with
any other
questions.



                                                             Sincerely,

FirstName LastNameDezhi Liu                                  Division of
Corporation Finance
                                                             Office of
Industrial Applications and
Comapany NameOriental Rise Holdings Limited
                                                             Services
December 27, 2023 Page 2
cc:       Joe Laxague, Esq.
FirstName LastName