November 15, 2024 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, 2023 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 Office of Real Estate & Construction