SecProbe.io

CORRESP
1
filename1.htm

EUDA
HEALTH HOLDINGS LIMITED

1
Pemimpin Drive #12-07

One
Pemimpin Singapore 576151

September
19, 2023

VIA
EDGAR

Mr.
Colon Danberg

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:

    EUDA
    Health Holdings Limited (the “Company”)

    Registration
    Statement on Form F-1

    (File
    No. 333-268994) (the “Registration Statement”)

Dear
Mr. Danberg,

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 4:00 p.m. on September 21, 2023, or soon
thereafter as practicable.

The
Company hereby acknowledges that:

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

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

    ●
    The
    Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

{Signature
page to follow}

    Very
    truly yours,

    EUDA
    Health Holdings Limited

    By:
    /s/
    Kelvin Chen

    Name:

    Kelvin
    Chen

    Title:

    Chief
    Executive Officer

    2