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EUDA
Health Holdings Ltd

60
Kaki Bukit Place, #03-01

Eunos
Techpark, Singapore 415979

    September
    24, 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

    Amendment
    No. 1 to 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 September 17, 2025 (the “Staff’s Letter”) regarding
the Company’s Amendment No. 1 to Form 20-F for Fiscal Year Ended December 31, 2024. Contemporaneously, we are filing Amendment
No. 2 to the Form 20-F via Edgar (the “Form 20-F Amendment No. 2”).

For
ease of reference, the comment contained in the Staff’s Letter is reproduced below and is followed by the Company’s response.

Form
20-F/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.

Response:
The Form 20-F Amendment No. 2 has been revised to include (1) Items 17 and 18 and Financial Statements of Part III; and (2) Item 19 of
Part III in to file updated certifications of the Principal Chief Executive Officer and Principal Chief Financial officer, and
the consent letters of J&S Associate PLT and Marcum Asia LLP.

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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