SecProbe.io

CORRESP
1
filename1.htm

March
28, 2023

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Manufacturing

100
F Street, NE

Washington,
D.C., 20549

    Attention:
    Ms.
    Andi Carpenter

    Mr.
    Andrew Blume

    Mr.
    Patrick Fullem

    Mr.
    Jay Ingram

    Re:
    Multi
    Ways Holdings Limited

    Registration
    Statement on Form F-1, as amended (File No. 333-269641)

    Request
    for Acceleration of Effectiveness

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), we, the underwriter (the “Underwriter”),
hereby join in the request of Multi Ways Holdings Limited (the “Registrant”), for the acceleration of the effective date
of the Registrant’s Registration Statement on Form F-1 (File No. 333-269641) (as amended, the “Registration Statement”),
relating to a public offering of shares of the Registrant’s ordinary shares, US$0.00025 par value, so that the Registration Statement
may be declared effective on March 30, 2023, at 4.30 p.m. Eastern Time, or as soon thereafter as practicable. The undersigned,
as the Underwriter, confirms that it is aware of its obligations under the Securities Act.

Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated
to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.

    Very
    truly yours,

    SPARTAN
    CAPITAL SECURITIES LLC

    /s/
    Kim Monchik

    Name:
    Kim
    Monchik

    Title:
    Chief
    Administrative Officer