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January 4, 2023
Wei Wen Kelvin Chen
Chief Executive Officer
EUDA Health Holdings Limited
1 Pemimpin Drive #12-07
One Pemimpin Singapore 576151
Re:EUDA Health Holdings Limited
Registration Statement on Form S-1
Filed December 23, 2022
File No. 333-268994
Dear Wei Wen Kelvin Chen:
            We have limited our review of your registration 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.  If you do not believe 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed December 23, 2022
Cover Page
1.For each of the ordinary shares and warrants being registered for resale, disclose the price
that the selling securityholders paid for such ordinary shares and warrants overlying such
securities.
2.Disclose the exercise price of the warrants compared to the market price of the underlying
security. If the warrants are out the money, please disclose the likelihood that warrant
holders will not exercise their warrants.  Provide similar disclosure in the prospectus
summary, risk factors, MD&A and use of proceeds section and disclose that cash proceeds
associated with the exercises of the warrants are dependent on the stock price.  As
applicable, describe the impact on your liquidity and update the discussion on the ability
of your company to fund your operations on a prospective basis with your current cash on

 FirstName LastNameWei Wen Kelvin Chen
 Comapany NameEUDA Health Holdings Limited
 January 4, 2023 Page 2
 FirstName LastNameWei Wen Kelvin Chen
EUDA Health Holdings Limited
January 4, 2023
Page 2
hand.
3.We note the significant number of redemptions of your ordinary shares in connection with
your business combination and that the shares being registered for resale will constitute a
considerable percentage of or may exceed your public float.  We also note that all or most
of the shares being registered for resale were purchased by the selling securityholders for
prices considerably below the current market price of the ordinary shares.  Highlight the
significant negative impact sales of shares on this registration statement could have on the
public trading price of the ordinary shares.
Risk Factors
Due to the significant number of the Company's ordinary shares that were redeemed..., page 10
4.We refer to your risk factor highlighting the negative pressure potential sales of ordinary
shares pursuant to this registration statement could have on the public trading price of the
ordinary shares.  Please revise to disclose the purchase price of the securities being
registered for resale and the percentage that these shares currently represent of the total
number of shares outstanding.
EUDA Health Limited Management's Discussion and Analysis of Financial Condition and
Results of Operations, page 93
5.We note that the preliminary projected revenues for 2022 were $50 million and later
revised to $13 million, as set forth in the unaudited prospective financial information
management prepared in connection with the evaluation of the business combination.  We
also note that your actual revenues for the nine months ended September 30, 2022 was
approximately $7.4 million.  It appears that you may miss your 2022 revenue projection.
Please update your disclosure in Liquidity and Capital Resources, and elsewhere, to
provide updated information about the company's financial position and further risks to
the business operations and liquidity in light of these circumstances.
6.In light of the significant number of redemptions and the unlikelihood that the company
will receive significant proceeds from exercises of the warrants because of the disparity
between the exercise price of the warrants and the current trading price of the ordinary
shares, expand your discussion of capital resources to address any changes in the
company's liquidity position since the business combination.  If the company is likely to
have to seek additional capital, discuss the effect of this offering on the company's ability
to raise additional capital.
7.Please expand your discussion here to reflect the fact that this offering involves the
potential sale of a substantial portion of shares for resale and discuss how such sales could
impact the market price of the company's ordinary shares.  Your discussion should
highlight the fact that Watermark Developments Limited, a beneficial owner of more than
47% of your outstanding shares, will be able to sell all of its shares for so long as the
registration statement of which this prospectus forms a part is available for use.

 FirstName LastNameWei Wen Kelvin Chen
 Comapany NameEUDA Health Holdings Limited
 January 4, 2023 Page 3
 FirstName LastName
Wei Wen Kelvin Chen
EUDA Health Holdings Limited
January 4, 2023
Page 3
General
8.Revise your prospectus to disclose the price that each selling securityholder paid for the
ordinary shares and warrants being registered for resale.  Highlight any differences in the
current trading price, the prices that the Sponsor, the private placement investors and other
selling securityholders acquired their shares and warrants, and the price that the public
securityholders acquired their shares and warrants.  Disclose that while the Sponsor, the
private placement investors and other selling securityholders may experience a positive
rate of return based on the current trading price, the public securityholders may not
experience a similar rate of return on the securities they purchased due to differences in
the purchase prices and the current trading price.  Please also disclose the potential profit
the selling securityholders will earn based on the current trading price.  Lastly, please
include appropriate risk factor disclosure.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       J. Britton Williston, Esq.