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                              March 1, 2023

       Nga Fan Wong
       Chief Executive Officer and Chairman
       VS MEDIA Holdings Ltd
       6/F, KOHO
       75 Hung To Road
       Kwun Tong
       Hong Kong

                                                        Re: VS MEDIA Holdings
Ltd
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted February
7, 2023
                                                            CIK No. 0001951294

       Dear Nga Fan Wong:

             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. 1 to Draft Registration Statement on Form F-1 Submitted
February 7, 2023

       Cover Page

   1.                                                   We note your response
to comment 2 and reissue in part. We note your additional cover
                                                        page disclosure adding
a cross-reference to your disclosure on pages 130 and 193. In
                                                        addition to the added
cross-references, please include disclosure highlighting the risks and
                                                        consequences of
complying with Hong Kong laws and regulations, including the
                                                        enforcement of civil
liabilities.
 Nga Fan Wong
FirstName
VS MEDIALastNameNga
            Holdings Ltd Fan Wong
Comapany
March      NameVS MEDIA Holdings Ltd
       1, 2023
March2 1, 2023 Page 2
Page
FirstName LastName
Significant Risks, page 16

2.       We note your response to comment 8 and reissue. In your response
letter you state that the
         summary risk factor section has been amended to fit on two pages.
However, in the
         amended registration statement we note that the summary risk factor
section starts on page
         16 and ends on page 21. Please clarify the discrepancy between your
response letter and
         the registration statement.
Our Clients, page 124

3.       We note your response to comment 18 and reissue in part. For the 6
long-term contracts
         with services committed for more than one year, please provide a range
for the length of
         these contracts, or confirm that all your long-term contracts are one
year with a yearly
         renewal clause.
Notes to the Unaudited Condensed Consolidated Financial Statements
Note 17 - Related Party Transactions, page F-50

4.       We note that you signed an agreement to sell Shuobing (Shanghai)
Culture
         Communication Co., Ltd., a related party, in 2022. Please tell us why
the sales price of
         $5,349,399 was receivable at December 31, 2021 (page F-25) if the
agreement to
         sell Shuobing was signed on July 31, 2022, a subsequent date. In
addition, please explain
         why the total due before any allowance was $5,453,399, and the
relation, if any, to the
         December 31, 2020 related party balance of $5,522,928.
       You may contact Blaise Rhodes at 202-551-3774 or Lyn Shenk at
202-551-3380 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with
any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services
cc:      Benjamin A. Tan