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SEC Company Response from ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980) (APWC) — Jul 24, 2009

ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980)
Date: July 24, 2009 · CIK: 0001026980 · Accession: 0000950123-09-025156

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File numbers found in text: 333-153796

Date
July 23, 2009
Author
ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED
Form
CORRESP
Company
ASIA PACIFIC WIRE & CABLE CORP LTD (APWC) (CIK 0001026980)

Letter

ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

7/Fl. B, No. 132, Sec. 3

Min-Sheng East Road

Taipei, 105, Taiwan

Republic of China

July 23, 2009

VIA FACSIMILE AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Jessica Kane

Re:

Asia Pacific Wire & Cable Corporation Limited

Post-Effective Amendment No. 3 to Form F-1, Filed on July 7, 2009

(File No. 333-153796)

Request for Acceleration

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned registrant, Asia Pacific Wire & Cable Corporation Limited (the “Registrant”), hereby confirms its request that the above-referenced Registration Statement be declared effective as of 5:30 p.m. (EDT), on July 23, 2009, or as soon as practicable thereafter.

The Registrant hereby acknowledges that:

(i)

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(ii)

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(iii)

the Registrant may not assert the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

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CORRESP
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corresp

ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

7/Fl. B, No. 132, Sec. 3

Min-Sheng East Road

Taipei, 105, Taiwan

Republic of China

July 23, 2009

VIA FACSIMILE AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Jessica Kane

    Re:

    Asia Pacific Wire & Cable Corporation Limited

    Post-Effective Amendment No. 3 to Form F-1, Filed on July 7, 2009

    (File No. 333-153796)

    Request for Acceleration

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned
registrant, Asia Pacific Wire & Cable Corporation Limited (the “Registrant”), hereby confirms its
request that the above-referenced Registration Statement be declared effective as of 5:30 p.m.
(EDT), on July 23, 2009, or as soon as practicable thereafter.

The Registrant hereby acknowledges that:

    (i)

    should the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the Registration Statement effective,
it does not foreclose the Commission from taking any action with respect to the
Registration Statement;

    (ii)

    the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
Registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

    (iii)

    the Registrant may not assert the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement
effective as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

    Very truly yours,

ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

    By:

/s/ Samuel
See

    Samuel See

    Interim Chief Financial Officer

2