SecProbe.io

October 20, 2011
Via E-mail
Frank Tseng, CFO 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
File No. 1-14542 Form 20-F for the Fiscal Ye ar Ended December 31, 2010
Filed May 13, 2011

Dear Mr. Tseng:
 We have reviewed your filing 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 with in ten business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circ umstances, please tell us why in your response.
After reviewing the information you provide in  response to these comments, we may have
additional comments.
Operating results, page 45

1. In future filings, please quantify the impact th at (1) sales price variances, (2) sales volume
variances, and (3) foreign exchange rate varian ces had on reported sales increases and decreases.
This information should be provided for both your consolidated and segment (page F-44) sales
data. Your existing disclosure does not enable an i nvestor to fully understand the extent to which
your consolidated and segment sales were impacted  by these factors. See Section 501.04 of the
Financial Reporting Codification and Item  5.A of the Form 20-F instructions.
 Liquidity, page 54

2. Your disclosure states that the Registrant has no direct business operations. In future filings,
please provide the audited information prescribed by Article 12-04 of Regulation S-X and Item
17(a) of the Form 20-F instructions.

3. Please explain to us why the DSO data on page 55 differs from the corresponding data on page
48. Also, please provide us your calculation for th is measure. It is not clear how you determined
that your DSO decreased given that gross account s receivable increased 37% which is higher than
the annual and 4th quarter sales increases of 30% and 6%, respectively.

4. Given the material adverse impact that the r eceivables increase had on your operating cash flow,
please expand your disclosure in future filings  to state whether the receivables increase was

Mr. Frank Tseng, CFO
October 20, 2011 Page 2 of 2
 impacted by an increase in the aging of your recei vables portfolio and/or changes in your revenue
recognition policies. Please provide us with a dr aft disclosure pertaining to your 2010 financial
statements. See Section 501.04 of the Financial Reporting Codification.

Market Risks Related to Copper, page 83

5. In future filings, please quantify both the volum e and pricing terms of your forward pricing
contracts. Absent such disclosure, investors cannot fully understand the extent to which a material
change in copper commodity prices could impact  your loss exposure on these contracts. See Item
5.D and 11 of the Form 20-F instructions.
 Statements of Cash Flows, page F-8

6. Please provide us with a quantitative reconcilia tion between the $6,857 depreciation amount for
2010 and the $21,441 change in accumulated depreciation reflected on page F-4. Also, please
provide us with a quantitative reconciliation between the $3,653 purchases of property, plant and
equipment amount for 2010 and the $21,702 change in gross property, plant and equipment
reflected on page F-4. Regarding your future f ilings, note that material non-cash investing and
financing activities are required to be disclosed pursuant to ASC 230-10-50.

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 include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Al Pavot, St aff Accountant, at (202) 551- 3738 or me at (202) 551-3355
if you have any questions.
Sincerely,
   /s/ Terence O’Brien
Terence O’Brien Accounting Branch Chief