SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      April 23, 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
Post-Effective Amendment No. 1 to
Registration Statement on Form F-1
Filed on April 2, 2009 File No. 333-153796

Dear Mr. Tang:
 We have limited our review  of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  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.

Signatures, page II-4

1. We note that Mr. Yuan Chun Tang signed the post-effective amendment on behalf
of those persons who duly executed the power  of attorney filed as part of the
Form F-1, which was filed with the Securities and Exchange Commission on
October 2, 2008.  As this post-effective amendment is considered a separate
registration statement, pl ease arrange to have the post-effective amendment
signed by the registrant, the principal ex ecutive officer, the principal financial
officer, the controller or pr incipal accounting officer, and at  least a majority of the
board of directors.  See  Instructions Nos. 1 and 2 to the Signature Section of Form
F-1 and Item 601 of Regulation S-K.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  April 23, 2009 Page 2
As appropriate, please amend your filing in response to these comments.  You
may wish to provide us with marked copies of the amendment to e xpedite our review.
Please furnish a cover letter with your amendment that ke ys your responses to our
comments and provides any requested inform ation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.      Before the amended registration statem ent is declared effective pursuant to
Section 8 of the Securities Act, the co mpany should provide us with a letter,
acknowledging that:   ‚ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;
 ‚ the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and
 ‚ the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
You may contact Jessica Kane , Staff Attorney, at (202)  551-3235 or me at (202)
551-3397 with any questions.
 Sincerely,    Jay Ingram Legal Branch Chief

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  April 23, 2009 Page 3
cc: Michael J. Hagan, Esq.  Morrison & Foerster LLP  1290 Avenue of the Americas  New York, NY  10104