SecProbe.io

July 28, 2011
 Via E-mail

Frank Tseng Chief Financial Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan Republic of China
Re: Asia Pacific Wire & Cable Corporation Limited
  Post-Effective Amendment No. 7 to Form-1 on Form F-3
Filed July 11, 2011
  File No. 333-153796

Dear Mr. Tang:
 We have limited our review of your registra tion statement to those issues we have
addressed in our 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 amending your registration statement and providing the
requested information.  Where you do not beli eve 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 any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. We note that Post-Effective Amendment No. 6 to the Form F-1 went effective on October
6, 2010 and contained audited financial statements as of December 31, 2009.  Pursuant to Item 8.A of Form 20-F, the last year of aud ited financial statements may not be older than
15 months at the time of the offering.  Accordingly, it appears you were required to
update the audited financial statements for this offering by April 1, 2011.  Please advise
us as to whether any offers or sales were  made pursuant to the prospectus during the
period in which the financial statements were not current.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in

Frank Tseng  Asia Pacific Wire & Cable Corporation Limited July 28, 2011 Page 2

 possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission 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.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.
 You may contact Jessica Kane  at (202) 551-3235 or me at (202) 551-3397 with any
questions.
Sincerely,
   /s/ Jay Ingram
Jay Ingram Legal Branch Chief
 cc: Michael J. Hagan, Esq. (Via E-mail)  Thompson Hine LLP   335 Madison Avenue, Floor 12  New York, NY 10017