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                      November 13, 2023

       Yong Zhang
       Chief Executive Officer
       Xinyuan Real Estate Co., Ltd.
       27/F, China Central Place, Tower II
       79 Jianguo Road, Chaoyang District
       Beijing 100025
       People   s Republic of China

                                                        Re: Xinyuan Real Estate 
Co., Ltd.
                                                            Form 20-F for the 
Fiscal Year Ended December 31, 2022
                                                            File No. 001-33863

       Dear Yong Zhang:

              We have completed our review of your filing. 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.



                                                                                
                      Sincerely,

                                                                                
                      Division of Corporation Finance
                                                                                
                      Disclosure Review Program
       cc:                                              Haoze Zheng