SEC Comment Letter for EUDA Health Holdings Ltd (EUDA, EUDAW) (CIK 0001847846) (EUDA) — Sep 17, 2025

EUDA Health Holdings Ltd (EUDA, EUDAW) (CIK 0001847846)
Date: Sept. 17, 2025 · CIK: 0001847846 · Accession: 0000000000-25-010135

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AI Filing Summary & Sentiment

File numbers found in text: 001-40678

Date

September 17, 2025

Author

Not clearly detected

Form

UPLOAD

Company

EUDA Health Holdings Ltd (EUDA, EUDAW) (CIK 0001847846)

Letter

September 17, 2025 Alfred Lim Chief Executive Officer EUDA Health Holdings Ltd 60 Kaki Bukit Place, #03-01 Eunos Techpark, Singapore 415979 Re:EUDA Health Holdings Ltd Amendment No. 1 to Form 20-F for Fiscal Year Ended December 31, 2024 File No. 001-40678 Dear Alfred Lim: We have reviewed your filing and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 20F/A filed September 11, 2025 Report of Independent Registered Public Accounting Firm, page F-1 1.We note your amended Form 20-F includes only the revised report of your independent registered public accounting firm without the corresponding financial statements. Please file an amended Form 20-F to include the entire Item 17, as required by Exchange Act Rule 12b-15. Note the amended filing is to be accompanied by all certifications, updated as appropriate and referring to the amendment, as well as an updated consent from your independent registered public accounting firm. 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. Please contact Tayyaba Shafique at 202-551-2110 or Terence O'Brien at 202-551- 3355 if you have questions regarding comments on the financial statements and related matters.

September 17, 2025 Page 2 Sincerely, Division of Corporation Finance Office of Industrial Applications and Services

Show Raw Text

September 17, 2025
Alfred Lim
Chief Executive Officer
EUDA Health Holdings Ltd
60 Kaki Bukit Place, #03-01
Eunos Techpark, Singapore 415979
Re:EUDA Health Holdings Ltd
Amendment No. 1 to Form 20-F for Fiscal Year Ended December 31, 2024
File No. 001-40678
Dear Alfred Lim:
            We have reviewed your filing and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20F/A filed September 11, 2025
Report of Independent Registered Public Accounting Firm, page F-1
1.We note your amended Form 20-F includes only the revised report of your
independent registered public accounting firm without the corresponding financial
statements. Please file an amended Form 20-F to include the entire Item 17, as
required by Exchange Act Rule 12b-15. Note the amended filing is to be accompanied
by all certifications, updated as appropriate and referring to the amendment, as well as
an updated consent from your independent registered public accounting firm.
            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.
            Please contact Tayyaba Shafique at 202-551-2110 or Terence O'Brien at 202-551-
3355 if you have questions regarding comments on the financial statements and related
matters.

September 17, 2025
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

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