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GIBSON, DUNN & CRUTCHER LLP

Lawyers

A REGISTERED
LIMITED LIABILITY PARTNERSHIP

INCLUDING PROFESSIONAL CORPORATIONS

__________

2029 Century Park
East, Suite 4000 Los Angeles, California 90067

(310) 552-8500

  VIA FACSIMILE AND EDGAR

  November 18, 2004

U.S. Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3-9

450 Fifth Street, N.W.

Washington, D.C. 20549-0404

Attention: Jeffrey Riedler

  Re:

  WH Holdings (Cayman Islands) Ltd.

  Registration Statement on S-1 filed October 1,
  2004

  File No. 333-119485

Dear Mr. Riedler:

On behalf of WH Holdings (Cayman
Islands) Ltd., a Cayman Islands exempted limited liability company (the “Company”), we transmit herewith
supplemental materials for your review in connection with the Company’s Registration
Statement on Form S-1 originally filed with the Securities and Exchange
Commission on October 1, 2004 (the “Registration
Statement”). By this letter, on behalf of the Company, we supplement
our November 16, 2004 and November 9, 2004 responses to the comments of
the staff of the Securities and Exchange Commission (the “Staff”) in its letter dated
November 3, 2004 (the “Comment Letter”),
relating to the Company’s Registration Statement. For ease of reference, the
headings and numbered paragraphs below correspond to the headings and numbered
comments in the Comment Letter, with the Staff’s comments presented in bold
italicized text.

Underwriters,
page 124

98.  We note your
disclosure on page 126 that you intend to do a “directed share offering.”  Please provide us with any material you
intend to sell to potential purchasers such as a “friends and family”
letter.  Tell us when you intend to send
them to these potential purchasers.  Tell
us whether the sale will be handled by you directly or by the underwriting
syndicate.  Tell us the procedures you or
the underwriter will employ in making the offering and how you will assure this
offer will meet the requirements of Section 5 of the Securities Act and Rule
134.  We may have further comments.

We note the Staff’s
comment and provide herewith a copy of the pre-screen form that the Company
plans to send out in connection with the Reserved Share Program (the “Program”).  The Company has been informed by Merrill
Lynch, Pierce, Fenner & Smith Incorporated (“Merrill Lynch”) that
this pre-screen form has been previously reviewed and approved by Cecilia Blye
of the Office of the General Counsel of the Division of Corporation
Finance.  No changes (other than
inserting the name of the Company and the name of the contact at the Company
and changing the title of the security from Common Stock to Common Shares) have
been made to the form.  The Company is
planning on sending out the pre-screen form on Friday, November 19, 2004.  Accordingly, we will contact you before then
to confirm that the Staff does not have additional comments related to the
pre-screen form at this time.  We further
confirm that we will send along to the Staff on a supplemental basis other
materials related to the Program as soon as they are finalized.

                Please
contact me at (310) 551-8800, Rayan Joshi at (213) 229-7207 or
Jonathan K. Layne at (310) 552-8641 with any questions regarding the
foregoing responses.

  Very truly yours,

  /s/ MICHAEL B. MAYES

  Michael B. Mayes

  cc:

  Brett R. Chapman, Esq., WH Holdings (Cayman Islands) Ltd.

  Richard Goudis, WH Holdings (Cayman Islands) Ltd.

  Jonathan K. Layne, Esq., Gibson, Dunn & Crutcher LLP

From:  WH Holdings (Cayman
Islands) Ltd.

To:  Friends of WH Holdings
(Cayman Islands) Ltd.

                                A Registration Statement providing
for a public offering of shares of Common Shares of WH Holdings (Cayman
Islands) Ltd. (the “Company”) has been filed with the United States Securities
and Exchange Commission, but has not yet been declared effective.

                                The Company is creating a database of
people who may be invited to purchase Common Shares in our initial offering
through a Reserved Share Program.  If you
would like to receive a prospectus for this purpose, please complete and return
the enclosed Database Information Form to Vicki Tuchman at the Company by                           ,
2004.

                                We will need all of the information
requested.  The Company has not yet
determined who will be able to participate in the Reserved Share Program and is
not hereby assuring you that you will have the opportunity to subscribe for
Common Shares in the offering.  If you are invited to participate in the Reserved
Share Program you may receive your invitation by e-mail.  You are under no obligation if you
respond to this letter.  This is not an
offer of the Common Shares, which offering can only be made by means of a
Prospectus.

                                No offer to buy Common Shares can be
accepted and no part of the purchase price can be received until the
Registration Statement relating to the Common Shares has become effective under
the Securities Act of 1933.  Any such offer to buy may be withdrawn or revoked, without obligation
or commitment of any kind, at any time prior to notice of its acceptance given
after the effective date of the Registration Statement.

                                The following statement is required
to be included in this letter by the rules and regulations of the United States
Securities and Exchange Commission:

“A Registration Statement
relating to these securities has been filed with the Securities and Exchange
Commission but has not yet become effective.
These securities may not be sold nor may offers to buy be accepted prior
to the time the Registration Statement becomes effective.  This letter shall not constitute an offer to
sell or the solicitation of an offer to buy nor shall there be any sale of
these securities in any state in which such offer, solicitation or sale would
be unlawful prior to registration or qualification under the securities laws of
any such state.”

                                The
Company will not share this information with anyone other than the underwriters
of the Common Shares, and will only share the information with the underwriters
to the extent necessary to conduct the Reserved Share Program.

DATABASE INFORMATION FORM

Attention:
Vicki Tuchman

Phone:  (310)
203-2336

Fax:  (310)
203-2478

                                I
am interested in receiving a copy of the prospectus for the public offering of
Common Shares of WH Holdings (Cayman Islands) Ltd.  I understand that I am under no obligation by
reason of delivering this information to the Company.

Please print all information clearly

  Name:

  Employer (Exact Name):

  Title/Position:

  Home Mailing Address:

  Street Address

  City

  State

  Zip Code

  Home Phone (including area code):

  Work Phone (including area code):

  E-mail Address:

  Signature:

  Date:

This
Database Information Form must be returned to
no later than                           ,
2004.  (Completed forms must be returned
by fax to                      .)  NO EXCEPTIONS WILL BE MADE TO EXTEND THIS
DEADLINE.