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                             August 3, 2023

       Jison Lim
       Director and Chairman
       Ten-League International Holdings Ltd
       16 Gul Drive
       Singapore 629467

                                                        Re: Ten-League
International Holdings Ltd
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted July 7,
2023
                                                            CIK No. 0001982012

       Dear Jison Lim:

              We have reviewed your 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.

       Draft Registration Statement on Form F-1 Submitted July 7, 2023

       Cover Page

   1.                                                   We note your disclosure
that Ten-League Corp will own a percentage of your outstanding
                                                        shares such that you
will be a controlled company. Please revise this disclosure to state
                                                        that Mr. Lim controls
Ten-League Corp and therefore Mr. Lim will have the ability to
                                                        determine all matters
requiring approval by stockholders.
       Prospectus Summary
       Overview, page 4

   2.                                                   Provide prominent
disclosure about the legal and operational risks associated with being
                                                        reliant on a majority
of the company   s supplies coming from a supplier in China. Your
 Jison Lim
FirstName
Ten-LeagueLastNameJison     Lim
             International Holdings Ltd
Comapany
August      NameTen-League International Holdings Ltd
        3, 2023
August
Page  2 3, 2023 Page 2
FirstName LastName
         disclosure should make clear whether these risks could result in a
material change in your
         operations and/or the value of the securities you are registering for
sale. Please include
         similar disclosure in the risk factors and business sections, as
appropriate.
3.       We note at several points in the registration statement you refer to
your "predecessor
         companies." Please clarify what entities you are referring to as
"predecessor entities" and
         disclose how they form a part of the development of your business.
Refer to Item 4.A.4 of
         Form 20-F, as incorporated by Item 4.a of Form F-1.
Risk Factors
Risks Related to Our Business and Industry
We are dependent on Major Supplier. There can be no assurance that we will be
able to renew
our distribution agreements with..., page 10

4.       We note that you rely on Major Supplier for a majority of your
purchases. Please disclose
         the risks of this reliance and any supply chain disruptions you have
experienced due to
         such reliance.
We are dependent on the level of activities in the construction..., page 13

5.       You disclose that your business may be negatively impacted by supply
chain disruptions.
         Please revise to discuss whether you have or expect to suspend the
production, purchase,
         sale or maintenance of certain items; experience higher costs due to
constrained capacity,
         or experience surges or declines in consumer demand for which you are
unable to
         adequately adjust your supply. If so, explain whether you have
undertaken efforts to
         mitigate the impact.
We face risks related to heightened inflation, recession, financial and credit
market disruptions
and other economic conditions., page 20

6.       Please update this risk factor if recent inflationary pressures have
materially impacted
         your operations. In this regard, identify the types of inflationary
pressures you are facing
         and how your business has been affected.
If we fail to implement and maintain an effective system of internal controls,
we may be unable
to accurately or timely report our..., page 29

7.       You disclose that your management has not performed an assessment of
the effectiveness
         of your internal controls. Either here or in a new risk factor, please
also address your
         management's team lack of experience complying with U.S. public
company ongoing
         reporting requirements and the negative impact this could have on your
business.
Use of Proceeds, page 35

8.       We note your disclosure that approximately 15% of the offering's
proceeds will be used to
         "expand through strategic acquisitions and investments." Please give a
brief description
 Jison Lim
FirstName
Ten-LeagueLastNameJison     Lim
             International Holdings Ltd
Comapany
August      NameTen-League International Holdings Ltd
        3, 2023
August
Page  3 3, 2023 Page 3
FirstName LastName
         of the businesses you are planning to acquire and information on the
status of the
         acquisitions. Refer to Item 3.C.3 of Form 20-F, as incorporated by
Item 4.a of Form F-1.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
42

9.       We note your disclosure stating that spending levels by customers are
a key factor
         affecting your results of operations. To the extent that increased
interest rates have
         impacted customers' spending levels causing a corresponding impact on
your sales
         volumes, please describe this here and in the risk factors section, as
applicable.
Year on Year Comparison of Our Results of Operations, page 48

10.      We note your sales of heavy equipment increased by 36.5% for the year
ended December
         31, 2022. Please revise to provide quantified analysis of the
significant drivers
         behind material changes in your revenues, including the extent to
which changes in
         revenue are attributable to changes in prices or to changes in volume.
Refer to Item 5 of
         Form 20-F, including the related Instructions.
11.      Please revise to provide an analysis of the significant drivers behind
material changes in
         your cost of revenue which increased by 28.5% for the year ended
December 31, 2022.
         For example, elsewhere in the filing you discuss supply chain
disruptions, rising costs of
         material and labor. Please quantify the effects of changes in both
price and volume on
         expenses, where appropriate. Refer to Item 5 of Form 20-F, including
the related
         Instructions.
Business, page 70

12.      We note your disclosure on page 15 that the prices of your equipment
fluctuate during the
         "construction season." If your business is impacted by seasonality,
please provide a
         description. Refer to Item 4.B.3 of Form 20-F, as incorporated by Item
4.a of Form F-1.
13.      You reference the dependency ceiling ratio imposed by the Singaporean
Ministry of
         Manpower. We also note your disclosure on page 12 that 52.9% of your
employees are
         foreign workers. Please disclose in this section, or elsewhere you
deem appropriate, how
         close you are to meeting the dependency ceiling ratio. In addition,
please disclose if the
         foreign manpower regulation has any other material effects on your
business. Refer to
         Item 4.B.8 of Form 20-F, incorporated by Item 4.a of Form F-1.
We have a strong long-term relationship with our Major Supplier and a wide
customer base
across..., page 72

14.      We note that your Major Supplier is a China-based enterprise. Please
disclose whether
         your business segments, products, lines of service, projects, or
operations were materially
         impacted by the pandemic related lockdowns in China. In addition,
discuss any steps you
         are taking, or have taken, to mitigate adverse impacts to your
business.
 Jison Lim
Ten-League International Holdings Ltd
August 3, 2023
Page 4
Executive Officers and Directors, page 104

15.      We note that in the biography for Ms. Lin you refer to her joining the
"Group" in 1998.
         However, the definition of Group on page 1 states that "Group" refers
to Ten-League
         International Holdings Limited or its subsidiaries. International
Holdings Limited is
         disclosed as having been founded in 2023 and its subsidiaries were all
founded after 1998.
         Please clarify this discrepancy. Refer to Item 1.A of Form 20-F, as
incorporated by Item
         4.a of Form F-1.
Consolidated Statements of Operations and Comprehensive Income, page F-4

16.      We note you reported zero selling and distribution costs in both years
ended December 31,
         2022 and 2021. However your policy states    sales and marketing
expenses include
         payroll, employee benefits and other headcount-related expenses
associated with sales and
         marketing personnel, and the costs of advertising, promotions,
seminars, and other
         programs. Also, page 92 shows 10% of your full-time employees are
categorized as Sales
         and Marketing. Please revise or explain.
Note 2 Summary of Significant Accounting Policies
(f) Accounts Receivable, net, page F-9

17.      You disclose "The normal settlement terms of accounts receivable from
insurance
         companies in the provision of brokerage agency services are within 30
days upon the
         execution of the insurance policies." Please describe for us the
nature of these
         transactions.
(j) Revenue Recognition, page F-10

18.      Please clarify if you are recognizing revenue from the sale of
products on a gross basis.
         Please revise to disclose whether there are any sales for which you
are acting as an agent
         and have evaluated for indicators of gross and net revenue reporting
in ASC 606-10-55-36
         through 55-40.
Notes to consolidated Financial Statements
Note 12 Bank Borrowings, page F-19

19.      Please revise to disclose the nature of "Bills payable," including
significant terms.
Exhibits
FirstName LastNameJison Lim
20.    Please file your agreements with Major Supplier, including the
distribution agreement(s),
Comapany    NameTen-League
       service-dealer         International
                      agreement(s),         Holdings
                                    and dealership   Ltd
                                                   agreement(s) as exhibits to
the registration
Auguststatement.   Refer
        3, 2023 Page  4 to Item 8(a) of Form F-1 and Item 601(b)(10) of
Regulation S-K.
FirstName LastName
 Jison Lim
FirstName
Ten-LeagueLastNameJison     Lim
             International Holdings Ltd
Comapany
August      NameTen-League International Holdings Ltd
        3, 2023
August
Page  5 3, 2023 Page 5
FirstName LastName
General

21.      We note the use of the term "Major Supplier" throughout the
registration statement.
         Instead, please disclose the name of the entity represented by the
term "Major Supplier."
22.      Please provide us with supplemental copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         have presented or expect to present to potential investors in reliance
on Section 5(d) of the
         Securities Act, whether or not you retained, or intend to retain,
copies of those
         communications. Please contact the staff member associated with the
review of this filing
         to discuss how to submit the materials, if any, to us for our review.
23.      We note your placeholder for the initial public offering price range
in the IPO Prospectus
         cover page, indicating that the initial public offering price will not
be fixed at the time of
         effectiveness. However, the Resale Prospectus cover page includes a
placeholder for the
         fixed initial public offering price. Please tell us whether the
selling shareholders plan to
         sell their shares at a fixed price, and if so, please confirm that you
will specify prior to
         effectiveness the fixed price at which or price range within which
selling shareholders will
         sell their shares and revise the Resale Prospectus cover page as
applicable. Refer to Item
         501(b)(3) of Regulation S-K. In the alternative, please confirm that
the selling
         shareholders will not make any sales until the shares are listed on a
national securities
         exchange, and revise your Resale Prospectus cover page to remove the
reference to a fixed
         price and clarify that such selling shareholders will sell their
shares at market prices once
         trading of your common stock begins.
       You may contact Nasreen Mohammed at 202-551-3773 or Lyn Shenk at
202-551-3380 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442 with
any other
questions.




                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Trade
& Services