SecProbe.io

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                                 (212) 701-3139

                                                               September 1, 2005

Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549-0405

        Re:     Global Sources Ltd.
                Form 20-F for the year ended December 31, 2004
                Filed May 13, 2005
                File No. 333-0-30678

Dear Mr. Spirgel:

     On behalf of Global Sources Ltd. (the "Company"), set forth below are the
Company's responses to the Comment Letter of the Staff dated August 10, 2005.
For the convenience of the Staff, the Staff's comments are repeated below and
the responses of the Company immediately follow each comment. Each of the
responses set forth below are based upon the information and representations of
the Company provided to us.

Item 5.  Operating and Financial Review and Prospects

Results of Operations- Fiscal 2004 and 2003, page 28

     1.   Your current disclosures mostly indicate areas of change, but they do
          not provide the reader with an understanding of the underlying
          business and other drivers affecting your results of operations and
          financial position, they do not quantify or indicate the relevant
          weight of revenue categories, and the disclosures do not provide an
          indication that past results are indicative of future performance. In
          this respect, your disclosures do not comply fully with the
          requirements or intent of Item 303 of Regulation S-K.

<PAGE>

                                      -2-

For example, you indicate in your discussion of revenue, that revenue derived
from your online and other media services segment increased 5% from 2003. It is
not clear from your disclosures what specific segment revenue categories
contributed to the increase and why. It is not clear whether the revenue surge
was due to creating and hosting websites, banner advertising, trade magazine
subscriptions or magazine advertising, etc. It is not clear what the underlying
business drivers were that contributed to the year-over-year revenue category
increase or if you expect this trend to continue.

Please revise to provide a comprehensive discussion of your results of
operations in accordance with Item 303 of Regulation S-K.

Response: The Company will respond to the Staff's comment by revising its
disclosure to make changes such as those shown in the following version of the
applicable section (bold underlined sections identify additions):

     Fiscal Year 2004 Compared to Fiscal Year 2003

     Revenue

          Our total revenue grew to $105.8 million during the year ended
     December 31, 2004 from $91.7 million during the year ended December 31,
     2003, a growth of 15%. Our online and other media services revenue grew by
     $4.6 million or 5% to $92.3 million during the year ended December 31,
     2004, as compared with $87.7 million during the year ended December 31,
     2003 due primarily to a 9% growth in our China market and the growth in our
     Hong Kong, Japan and USA markets offset by drop in some of our other
     markets during the year. "Online and other media services" revenue from
     China grew by 9% in 2004 compared to 2003. China represented 45% of "Online
     and other media services" revenue in 2004 compared to 43% in 2003. Our
     exhibitions revenue grew from $3.3 million during the year ended December
     31, 2003 to $13.0 million during the year ended December 31, 2004, a growth
     of 294%, due mainly to an increase in the number of our China Sourcing
     Fairs events held in year 2004. In 2004 we held six China Sourcing F airs
     versus only one in 2003.

          We have made substantial progress in developing our customer base in
     China, our largest market. Total revenue from China grew by 26% during the
     year ended December 31, 2004 compared to the year ended December 31, 2003
     partially mainly as a result of an increase in China Sourcing Fairs
     revenue. China accounted for 47% of total revenue during the year ended
     December 31, 2004 compared to 43% of total revenue during the year ended
     December 31, 2003. We expect China's percent of the total to continue to
     grow and China's revenue overall to continue to grow.

<PAGE>

                                      -3-

Liquidity and Capital Resources, page 34

2.   Your discussions of cash flows from operating, investing and financing
     activities appear to be a mechanical recitation of your cash flow
     statement. Please revise to provide not only a "discussion" but also an
     "analysis" of historical information as well as known trends, demands,
     commitments, events or uncertainties that will result in your liquidity
     increasing or decreasing in any material way. In addition, revise your
     disclosures of capital resources in a similar fashion to provide the reader
     with a clear, cohesive view of your liquidity and capital resource needs as
     seen through the eyes of management. For example, you should have discussed
     and analyzed the business demands, events and needs that led management to
     purchase $131.4 million and sell $157.3 million worth of securities.

     Response: The Company will respond to the Staff's comment by adding
     disclosure such as the following disclosure in the applicable section:

                    Operating Cashflows

                    Advance payments received from customers were $30,195 as of
               December 31, 2004, compared to $27,454 as at December 31, 2003,
               improving the Company's liquidity. A majority of its customers in
               China pay the Company in advance for its Online and other media
               services business. The Company Exhibitions business collections
               are all advance payments. The Company expects the growth in its
               revenues from China to continue and the Company plans to launch
               more Exhibition events in the future. As a result, the Company
               expects that the advance payments received from customers to
               continue to increase in the future as its revenue increases.

                    Receivable from sales representatives was reduced from
               $3,883 as at December 31, 2003 to $3,407 as at December 31, 2004.
               However, the Company expects the receivable from sales
               representatives to slightly increase due to expected growth in
               its China business and its Exhibitions business.

                    Investing and Financing Cashflows

                    As and when the Company needs additional funds for capital
               acquisitions the Company can raise additional capital for the
               remainder of $259,500 under its Form F-3 shelf filing dated May
               21, 2004.

                    The Company invests its excess cash in available-for-sale
               securities to generate income from interest received as well as
               capital gains, while the funds are held to support the Company's
               business. The majority of the available-for-sale securities have
               maturities of less than 3 months.

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                                      -4-

                    Generally the Company holds the securities with specified
               maturity dates such as Treasury Bills until their maturity but
               the securities managed by high quality institutions that do not
               have fixed maturity dates are generally sold on a quarterly basis
               and proceeds reinvested in similar securities. The $157,253 of
               sales of available-for-sale securities during the year 2004,
               consists of $128,453 securities sold or matured and reinvested
               and $28,800 withdrawn from available-for-sale securities during
               the year to pay for a major one-time capital expenditure of
               $19,400 and $9,400 in repayment of the loan owed to a
               shareholder.

                    The Company does not engage in buying and selling of
               securities with the objective of generating profits on short-term
               differences in price.

                    Capital Resources

                    The Company anticipates that its cash and securities on hand
               and expected positive cash-flows from its operations will be
               adequate to satisfy the Company's working capital, capital
               expenditure requirements and cash commitments based on the
               current levels of the Company's operations.

Item 8.  Financial Information

Note 2 Summary of Significant Accounting Policies

(d) Available-for-sale Securities, page 54

3.   Please tell us how you determined, in accordance with paragraph 12 of SFAS
     115, the classification of securities bought and sold in 2004 as available
     for sale and not trading.

     Response: The Company invests its excess cash in readily marketable
     securities managed by high quality institutions and in government-backed
     securities such as US Treasury bills.

     The Company's intention in keeping its excess cash in these securities is
     to generate income from interest received as well as capital gains, while
     the funds are held to support the Company's business. The majority of the
     available-for-sale securities are short-term with a maturity of less than 3
     months.

     Generally the Company holds the securities with specified maturity dates
     such as Treasury Bills until their maturity but the securities managed by
     high quality institutions that do not have fixed maturity dates are
     generally sold on a quarterly basis and proceeds reinvested in similar
     securities.

     The Company records sales of securities upon their maturity or sale.

<PAGE>

                                      -5-

As per paragraph 12 of SFAS 115 "Accounting for Certain Investments in Debt and
Equity Securities", securities that are bought and held principally for the
purpose of selling them in the near term (thus held only for a short period of
time of generally hours or days) are to be classified as trading securities.
Trading generally reflects frequent buying and selling, and trading securities
are generally used with the objective of generating profits on short-term
differences in price.

Investments not classified as trading securities (nor as held-to-maturity
securities) shall be classified as available-for-sale securities.

As the Company's objective and intent is not to generate profit on short-term
differences in price and since the Company does not frequently buy or sell the
securities in order to profit from short-term price fluctuations, the Company
classifies its investments as available-for- sale securities, in accordance with
US GAAP.

(q) Minority Interest, page 57

4.   Quantify in this footnote the amount of dividends that must be paid by
     eMedia Asia Ltd. in order to trigger CMP's obligation to pay $6,000 to the
     company. Discuss under Liquidity in MD&A the business purpose of this
     arrangement and management's expectations of receiving this payment from
     CMP, and advise us.

     Response: As per the agreement with the Company's minority shareholder, UBM
     Asia B.V. (CMP), $6,000 is payable by CMP only by applying any and all of
     the dividends paid by the Company's subsidiary, eMedia Asia Ltd. (eMedia).
     Such dividends are to be applied first against the interest due and
     secondly, towards the principal sum.

     As of December 31, 2004, the balance sheet of eMedia shows accumulated
     losses of $4,094. Under the laws of the country of incorporation of eMedia,
     a company cannot pay dividends unless it has positive retained earnings.

     eMedia is currently profitable. However based on the current level of
     profitability, the Company does not expect eMedia to pay any dividends in
     next five years. Due to the contingent nature of the re-payment, the
     Company did not record in its balance sheet the promissory note receivable
     of $6,000 and no interest income was accrued.

     As the Company does not expect eMedia to pay dividends in the near term,
     the Company did not discuss the above arrangement under the liquidity
     section in its MD&A. The Company will start to discuss the recoverability
     in the Company's MD&A once eMedia starts to pay dividends.

Note 14 Income Taxes, page 66

<PAGE>

                                      -6-

5.   We note, notwithstanding the fact that the company's subsidiaries subject
     to income tax have apparently generated taxable income in each of the last
     three fiscal years; the company continues to fully reserve its deferred tax
     assets. This policy suggests it is management's belief that it is more
     likely than not that the company will not realize any of the net deferred
     tax assets, which would mean management has concluded that there is a
     greater than 50 percent likelihood that the company's subsidiaries subject
     to tax will not generate any future taxable income through the date the
     company's net operating loss carryforwards expire. If this is so, we
     believe comprehensive disclosure should be provided to alert investors of
     this negative view held by management. In this disclosure you should
     explain to investors, in detail, your consideration of all available
     negative and positive evidence that formed the basis for your conclusion
     and why this conclusion is reasonable given that deferred tax assets were
     re alized by the company in past fiscal years. Also, please advise us in
     detail of your basis for the full valuation allowance. We refer you to
     paragraphs 20-25 of SFAS No. 109.

     Response: The break-down of the deferred tax assets of $7,410 as at
     December 31, 2004 is as follows:

Deferred tax assets relating to tax losses
in two of the Company's Hong Kong subsidiaries
and a Cyprus subsidiary                                  $    19

Deferred tax assets relating to tax losses in the
Company's US subsidiary                                  $ 7,391

Total deferred tax assets as at December 31, 2004         $7,410

The Company's deferred tax assets arose primarily from the past tax losses of
$17,188 in its US subsidiary.

These losses resulted primarily from non-cash compensation expenses relating to
a share award to the Company's chairman and chief executive officer by the US
subsidiary as discussed in Note 22 to the Company's financial statements.

The taxable profits/ (losses) of the Company's US subsidiary during the last
three years were as follows:

B/f loss at beginning of 2002:  ($17,275)

Year-2002:  ($45) loss
Year-2003:  $70 profit
Year-2004:  $62 profit
C/f loss at end of 2004:  ($17,188)

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                                      -7-

Though the US subsidiary is currently profitable, its operations are very small
and the Company does not expect its operations to increase substantially in near
future to generate enough profits to realize any material amounts of the
deferred tax assets before the net operating losses carried forward expire.
Accordingly the Company provided for a full valuation allowance.

The Company's US subsidiary provides certain administrative services to its
related company and receives a fee from its related company for the services
rendered. It does not generate any revenue from third parties for the Company
and its inability to realize the deferred tax assets has no impact on the
Company's profitability or financial position.

Operations of the Company's two Hong Kong subsidiaries and Cyprus