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EUDA
Health Holdings Ltd

60
Kaki Bukit Place, #03-01

Eunos
Techpark, Singapore 415979

    September
    11, 2025

Via
Edgar

United
States Securities and Exchange Commission

Division
of Corporation Finance Office

of
Industrial Applications and Services

Washington,
DC 20549

Attention:
Tayyaba Shafique and Terence O’Brien

    Re:
    EUDA
    Health Holdings Ltd

    Form
    20-F for Fiscal Year Ended December 31, 2024

    File
    No. 001-40678

Dear
Tayyaba Shafique and Terence O’Brien:

We
hereby provide a response to the comment issued in a letter dated August 29, 2025 (the “Staff’s Letter”) regarding
the Company’s Form 20-F for Fiscal Year Ended December 31, 2024 (the “Form 20-F”). Contemporaneously, we are
filing Amendment No. 1 to the Form 20-F via Edgar (the “Form 20-F Amendment No. 1”).

For
ease of reference, the comment contained in the Staff’s Letter is reproduced below and is followed by the Company’s response.
All page references in the responses set forth below refer to the page numbers in the Form 20-F Amendment No. 1.

Form
20-F filed April 29, 2025

Report
of Independent Registered Public Accounting Firm, page F-1

1. Based
                                            on the language provided in the audit reports of your successor and predecessor auditors,
                                            it is not clear who has taken audit responsibility for the adjustments made to the prior
                                            periods presented in the financial statements stemming from the changes to your reportable
                                            segment structure. Please clarify whether J&S Associate PLT performed additional procedures
                                            for the prior period segment changes and, if so, how they concluded they were not required
                                            to revise their audit report to discuss the procedures performed on the prior period financial
                                            statements. Refer to AS 3105 and Question 5 of the PCAOB’s Staff Questions and Answers
                                            on Adjustments to Prior Period Financial Statements Audited by a Predecessor Auditor.

Response:
We respectfully advise the Staff that J&S Associate PLT, our successor auditor, has performed the necessary additional procedures
with respect to the retrospective adjustments related to our changes in reportable segment structure. In accordance with the guidance
in AS 3105 and Question 5 of the PCAOB’s Staff Questions and Answers on Adjustments to Prior-Period Financial Statements Audited
by a Predecessor Auditor, J&S Associate PLT revised their auditor’s report to address these procedures.

Please
do not hesitate to contact me or Tahra Wright, Esq. of Loeb & Loeb LLP at (212) 407-4122 if you would like additional information
with respect to any of the foregoing. Thank you.

    Sincerely,

    /s/
                                                                                                              Alfred Lim

    Alfred
    Lim

    Chief
    Executive Officer

    cc:
    Tahra
Wright, Esq. (Twright@loeb.com)

    Jane
    Tam, Esq. (JTam@loeb.com)

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