November 27, 2024

Dongjian Xie
Chief Executive Officer
Delixy Holdings Ltd
883 North Bridge Road
#04-01 Southbank
Singapore 198785

       Re: Delixy Holdings Ltd
           Registration Statement on Form F-1
           Filed November 15, 2024
           File No. 333-283248
Dear Dongjian Xie:

       We have reviewed your 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.

Registration Statement on Form F-1 filed November 15, 2024
Capitalization, page 30

1.     You disclose that as of September 30, 2024 there were 15 million
Ordinary Shares
       outstanding on an actual basis. Please reconcile this amount to the 1
million Ordinary
       Shares outstanding disclosed in your balance sheet as of June 30, 2024
on page F-28.
       Please also address similar discrepancies regarding outstanding shares
on pages 7, 32,
       96, 97 and 101.
2.     Please revise the number of Ordinary Shares issued and outstanding on an
as adjusted
       basis to reflect the issuance of Ordinary Shares in this offering.
Dilution, page 32

3.     Please revise your dilution calculations to use amounts derived from
your most recent
       interim financial statements.
 November 27, 2024
Page 2

Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 39

4.     We note your disclosure that revenues from trading in crude oil were
50.1% of total
       trading revenue for the six months ended June 30, 2024, a decrease from
97.4% of
       total trading revenue for the six months ended June 30, 2023. Please
explain whether
       this decline in the portion of revenues from crude oil trading
constitutes a known trend
       within your business and, if so, identify any anticipated material
impacts to your
       results of operations.
Results of Operations
Comparison of Results of Operations for the Six Months Period Ended June 30,
2023 and
2024, page 41

5.     Please revise your revenue discussion to provide quantified explanations
for the
       change in revenue between the two reporting periods. In doing so, please
describe and
       quantify the extend to which such change is attributable to changes in
prices or to
       changes in the volume of the products being sold. Refer to Item
303(b)(2) of
       Regulation S-K.
Management
Employment Agreements, page 94

6.     Please revise to eliminate inconsistencies between the disclosure in
this section and
       the executed employment agreements on file as Exhibits 10.1, 10.2, and
10.3. For
       example, you state here that the agreements contain non-compete
provisions lasting
       twelve months after cessation of employment, but Section 2.03 of the
agreements
       imply a two year post-termination non-compete period. The description of
the
       termination provisions under the agreements also appears inconsistent
with Article III
       thereof.
Notes to Consolidated Financial Statements
Note 1 - Business Overview and Basis of Presentation
Reorganization, page F-7

7.     Please tell us how you have retroactively adjusted your financial
statements and
       related information to reflect the 1:200 forward stock split of your
Ordinary Shares
       and the shares surrendered by your existing shareholders on October 2,
2024.
 November 27, 2024
Page 3

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact James Giugliano at 202-551-3319 or Suying Li at
202-551-3335 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rebekah Reed at 202-551-5332 or Taylor Beech at 202-551-4515 with any
other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:   Jason Ye