SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      February 4, 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
  Registration Statement on Form F-1
Amendment #3 filed on January 22, 2009 File No. 333-153796  Form 20-F for the Fiscal Year Ended December 31, 2007 Filed on June 27, 2008 File No. 001-14542
 Dear Mr. Tang:
We have reviewed your filings and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
Form F-1

Risk Factors

Actual and Possible Impacts on the Company, page 5

1. The proposed future disclosure provided in response to prior comment 1 is general in nature and does not provid e detailed information on your business to
enable investors to see the company through the eyes of management.  For
example, the statement, “During the s econd half of 2008, the Company began to
experience the impact of the economic cr isis, which included lower sales and
lower gross margins…” does not provide an  investor with sufficient information
to understand the specific impact of recen t economic events.  The statement, “the
Company is presently anticipating that  the extremely challenging and difficult

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  February 4, 2009 Page 2
economic conditions now facing the global economy will continue at least through the first half  of 2009,” does not address th e effects of the current
economic crisis or provide detailed information about the current or anticipated impact on your customers, products, order levels, trends or expectations of
management.  The statement, “The Co mpany’s management has taken certain
steps in response to these events such as increasing its efforts to lower the days sales outstanding of its receivables ” is limited and does not provide an
understanding of management’s  considerations or plans to address these issues on
all aspects of operations and liquidity.  Please expand this disclosure.  As
discussed in SEC Release 33-8350, quantifica tion of the material effects of known
material trends and uncertainties can promote understanding. Quantitative
disclosure should be considered and may be  required to the extent material if
quantitative information is reasonably available.

 You may contact Melissa Ro cha, Staff Accountant, at  (202) 551-3692 or me at
(202) 551-3355 if you have questions regard ing comments on the financial statements
and related matters.

Sincerely,

 Terence O’Brien  Accounting Branch Chief

cc: Michael J. Hagan, Esq.  Morrison & Foerster LLP  1290 Avenue of the Americas  New York, New York  10104