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                             December 9, 2022

       James Lim Eng Hock
       Chief Executive Officer
       Multi Ways Holdings Limited
       3E Gul Circle
       Singapore 629633

                                                        Re: Multi Ways Holdings
Limited
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted November
23, 2022
                                                            CIK No. 0001941500

       Dear James Lim Eng Hock:

             We have reviewed your amended 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.

       Amendment No. 2 to Draft Registration Statement on Form F-1 submitted
November 23, 2022

       Report of Independent Registered Public Accounting Firm, page F-25

   1.                                                   We note your response
to comment 2 and your statement that the audit report date in the
                                                        initial filing "was
incorrect due to clerical error." Considering the initial filing was
                                                        submitted on August 26,
2022, an audit report dated October 21, 2022 would not have
                                                        been possible.
Accordingly, please clarify why the audit report date changed between
                                                        filings and tell us how
your audit report date complies with PCAOB Auditing Standard
                                                        3110. In doing so, tell
us if the financial statements included in any prior filings were
                                                        submitted prior to
audit completion.
 James Lim Eng Hock
FirstName
Multi WaysLastNameJames   Lim Eng Hock
            Holdings Limited
Comapany9,
December  NameMulti
             2022     Ways Holdings Limited
December
Page 2    9, 2022 Page 2
FirstName LastName
       You may contact Andi Carpenter at 202-551-3645 or Andrew Blume at
202-551-3254 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Patrick Fullem at 202-551-8337 or Jay Ingram at 202-551-3397 with any
other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing
cc:      Jason Ye