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CORRESP
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Multi
Ways Holdings Limited

3E
Gul Circle

Singapore
629633

February
8, 2023

Via
Edgar Correspondence

Mr.
Andrew Blume

Division
of Corporation Finance

Office
of Manufacturing

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

    Re:
    Multi
    Ways Holdings Limited

    Amendment
    No. 2 to Draft Registration Statement on Form F-1

    Submitted
    November 23, 2022

    CIK
    No. 0001941500

Dear
Mr. Blume,

This
letter is in response to the letter dated December 9, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) addressed to Multi Ways Holdings Limited (the “Company”, “we”, and “our”).
For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly. An amended draft
registration statement on Form F-1 (the “Amendment No. 3 to the Draft Registration Statement”) is being submitted to accompany
this letter.

Amendment
No. 2 to Draft Registration Statement on Form F-1 Submitted November 23, 2022

Report
of Independent Registered Public Accounting Firm, page F-25

1.
We note your response to comment 2 and your statement that the audit report date in the initial filing “was incorrect due to clerical
error.” Considering the initial filing was submitted on August 26, 2022, an audit report dated October 21, 2022 would not have
been possible. Accordingly, please clarify why the audit report date changed between filings and tell us how your audit report date complies
with PCAOB Auditing Standard 3110. In doing so, tell us if the financial statements included in any prior filings were submitted prior
to audit completion.

RESPONSE:
We note the Staff’s comment, and in response thereto, respectfully advise the Staff that the audit completed on August 26, 2022.
The auditor issued the auditor’s report on August 26, 2022 when the Company initially submitted the draft registration statement
on Form F-1. The auditor changed the date of the audit report from August 26, 2022 to October 21, 2022 because the Company disclosed
two revenue streams accounting policy notes pursuant to the Staff’s prior comments. The auditor has re-assessed the changes to
the financial statements and PCAOB Auditing Standard 3110 and 4101 and clarified that the audit reports in the draft registration statement
amendment no.1 submitted on October 21, 2022 and in the draft registration statement amendment no.2 submitted on November 23, 2022 should
have remained as August 26, 2022. The financial statements included in prior filings were not submitted prior to an audit completion.
The auditor included the audit report dated August 26, 2022 in the Amendment No. 3 to the Draft Registration Statement.

We
hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions
regarding the information contained herein, please contact our outside securities counsel William S. Rosenstadt, Esq. or Mengyi “Jason”
Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or jye@orllp.legal.

    Very
    truly yours,

    /s/
James
    Lim Eng Hock

    Name:

    James
    Lim Eng Hock

    Title:

    Chief
    Executive Officer