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                             February 5, 2024

       Sun Lei
       Chief Executive Officer
       JX Luxventure Ltd.
       Bin Hai Da Dao No. 270
       Lang Qin Wan Guo Ji Du Jia Cun Zong He Lou
       Xiu Ying District
       Haikou City, Hainan Province 570100
       People   s Republic of China

                                                        Re: JX Luxventure Ltd
                                                            Form 20-F for
Fiscal Year Ended December 31, 2022
                                                            Filed May 12, 2023
                                                            Amendment No. 4 to
Form 20-F for Fiscal Year Ended December 31, 2022
                                                            Filed January 17,
2024
                                                            File No.001-35715

       Dear Sun Lei:

              We have reviewed your January 17, 2024 response to our comment
letter and have the
       following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our January 2, 2024
       letter.

       Amendment No. 4 to Form 20-F for Fiscal Year Ended December 31, 2022

       Critical Accounting Policies
       Revenue Recognition
       Revenue from reselling of airline ticket, page 81

   1.                                                   We note you recognize
revenue at a point in time, once the air-tickets are issued to
                                                        passengers. We also
note that your return and replacement guarantees are valid up until
                                                        the point of departure.
Please tell us why you believe revenue should be recognized at the
 Sun Lei
FirstName LastNameSun Lei
JX Luxventure Ltd.
Comapany5,NameJX
February   2024 Luxventure Ltd.
February
Page 2 5, 2024 Page 2
FirstName LastName
         time the air-tickets are issued as opposed to the point of departure.
Specifically address:
             How you considered the return and replacement guarantees as
separate performance
             obligations under IFRS 15.
             How you considered whether the transactions should be considered a
sale with a right
             of return under IFRS 15 B22-27.
             Specifically address how you considered the need to estimate a
liability for losses on
             returns as described in paragraph B25 of IFRS 15.
             If you consider this a sale with right of return, please tell us
how your current
             accounting is in accordance with paragraph B21 of IFRS 15.
Specifically address
             why you have not estimated the liability associated with returned
air-tickets at the
             time of recognition under your current policy.
             Please tell us in your response the range and average length of
time between ticket
             issuance and departure date.
Notes to Consolidated Financial Statements
9. Cost of Revenues, page F-29

2.       We note your response to our previous comment 5. Please revise your
tabular presentation
         of cost of revenues to separately present the net impact to cost of
revenues of value of
         returned tickets not refunded to you by the airlines. In this regard,
the revised table should
         show the $965,000 and $917,000 separately from the line item,
"Outsourced service cost."
3.       As a related matter, please provide to us in your response a table
showing the calculation
         of the net charge to cost of revenues related to airline ticket
returns for each period an
         income statement is presented. Specifically, this table should detail
gross value of airline
         tickets refunded to customers, gross value received by you from
airlines for airline tickets
         returned, and the resulting net value included in cost of revenue.
19. Loss Per Share, page F-33

4.       As requested in our previous comment 13, please revise disclosures
throughout your filing
         to retrospectively restate the number of shares to reflect the reverse
split. Refer to the
         guidance in SAB Topic 4C and FASB ASC 505-10-S99-5. Specifically, the
calculation of
         basic and diluted weighted average shares outstanding presented in
this table does not
         reflect the 1:10 reverse stock split that occurred on April 26, 2023.
 Sun Lei
JX Luxventure Ltd.
February 5, 2024
Page 3

       Please contact Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with any other
questions.



FirstName LastNameSun Lei                                Sincerely,
Comapany NameJX Luxventure Ltd.
                                                         Division of
Corporation Finance
February 5, 2024 Page 3                                  Office of Trade &
Services
FirstName LastName