SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      January 8, 2009

Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
  Amendment No. 2 to Form F-1
Filed December 24, 2008 File No. 333-153796

  Form 20-F for the year ended December 31, 2007
  Filed June 27, 2008   File No. 001-14542
Dear Mr. Tang:

We have reviewed your filings and have the following comments.  We welcome
any questions you may have about our comments or any other aspect of  our review.  Feel
free to call us at the telephone numbers  listed at the end of this letter.

Form F-1

Operating and Financial Revi ew and Prospects, page 41
 1. We note the discussion of current econ omic risks on page 16, as well as the
 discussion on page 60.  Please revise to  include a prominent discussion providing
 investors with a detailed understanding of how the economic events are affecting
 your business.  This discussion should quantify the known impact on your  operations, financial position and liquid ity in the period since June 30, 2008, as
 well as address management’s expectat ions for the future in more detail.

Disclosures of Critical Accounting Policies, page 41

2. We note your response to prior comment 18 and your revised disclosure where
 you have added a policy note for impairme nt of long lived assets.  Clarify in
 future filings whether or not an impa irment test was actually performed on your
 long lived assets under SFAS 144 at Decem ber 31, 2007.  Your current disclosure
 only discloses that you did not record any impairment on your assets.  Please

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  January 8, 2009
Page 2   disclose the results of those tests and a ssumptions used, to the extent a test was
 performed, and if no test was performe d how you considered that one was not
 necessary under paragraph 8 of SFAS 144.  Note for future periods, disclosing
 whether or not a SFAS 144 analysis was actually performed w ould clearly inform
 investors whether the absence of impair ment charges is due to management’s
 determination that the SFAS 144 test were not required as a result of no triggering
 events or because there were triggering events present and managements estimate  of cash flow projections exceeded asset carrying values resulting in no
 impairment charges.  Related Party Transactions, page 67

 3. We note your revised disclosure on page  68 in response to prior comment 10.
 Please explain what “secondment” mean s and clarify what the managers do.
   Form 20-F for the Year Ending December 31, 2007

 Note 20. Segment Financial Information, page F-41

 4. We note your response to prior comment 20 and the CODM reports that you have
 provided under separate cover.  Your response states that you have defined your
 operating and reporting segments based on the structure of your internal  organization.  You state that this st ructure is a “geographic, market-driven
 enterprise” structure.  This geographic mark et driven enterprise is not apparent in
 the CODM reports provided.  In this regard, it appears as  if you have eight
 operating segments that are represented by certain subsidiaries or business units,
 such as Sigma Cable, Sigma Epan, and Au stralia Pacific Electric Cable, etc.
 Further, it is unclear how you have take n these reports that  are broken down by
 subsidiary/business unit and aggregated  them into three reportable segments;
 manufactured products, di stributed products and SDI,  as these reports do not
 include discreet financial informati on for these three reportable segments.
  Based on your CODM reports, it is no t clear to us that these units are
 economically similar such that aggregati on of these units pursuant to paragraph
 17 of SFAS 131 is appropriate.  Gros s margins among the eight units appear
 materially different.  For example,  Shanghai Yayang Electric margins are
 approximately 3% when Sigma Epan ar e approximately 17%.  Please provide us
 an analysis that includes explanati ons for these differences in economic
 characteristics, including differences in trends, and te ll us why these differences
 would not be considered an indication of  differences in economic characteristics.
 Additionally tell how these reports link to the segment reporting provided in your
 periodic reports.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  January 8, 2009 Page 3
As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
You may contact Melissa Ro cha, Staff Accountant, at  (202) 551-3692 or Terrence
O’Brien, Accounting Branch Chief, at (202)  551-3355 if you have questions regarding
comments on the financial statements and related matters.  Please contact me at (202) 551-3767 with any other questions.
Sincerely,    Jennifer Hardy  Branch Chief

cc: Michael J. Hagan, Esq.
 Morrison & Foerster LLP