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CORRESP
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filename1.htm

Multi
Ways Holdings Ltd

3E
Gul Circle

Singapore
629633

July
18, 2025

VIA
EDGAR

Division
of Corporation Finance

Office
of Manufacturing

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

  Attention:
  Kristin Baldwin

  Geoffrey
Kruczek

  Re:
  Multi Ways Holdings Ltd

  Registration Statement on Form F-1

  Filed March 28, 2025

  File No. 333-286220

Ladies
and Gentlemen:

We
are in receipt of the comment letter dated April 7, 2025, regarding Multi Ways Holdings Ltd (the “Company”, “Multi
Ways” or “we”) from the U.S. Securities and Exchange Commission staff (the “Staff”). An amended Draft Registration
Statement on Form F-1 (the “Amended Registration Statement No. 1”) is being submitted to accompany this letter. As requested
by the Staff, we have provided responses to the questions raised by the Staff. We set forth below the comments in your letter relating
to the Registration Statement on Form F-1 filed on March 28, 2025 followed by our responses to the comments.

Form
F-1

The
Offering, page 12

 1. The
                                            prospectus cover page indicates that you have engaged Spartan Capital Securities, LLC as
                                            the exclusive placement agent in this offering and that you intend to issue warrants to it.
                                            If so, please describe those securities in your disclosure beginning on page 111 and in your
                                            fee table. Also file a revised Exhibit 5.1, as applicable.

RESPONSE:
We note the Staff’s comment, and, in response hereto, respectfully advise the Staff that all references to warrants being issued
to the placement agent have been removed in the Amended Registration Statement No. 1. Accordingly, no disclosure related to such warrants
appears in the prospectus or the fee table, and, as such, no corresponding revision to Exhibit 5.1 is required.

Financial
Statements, page F-1

 2. Please
                                            update your financial statements and related disclosures. See Item 8.A.4 of Form 20-F.

RESPONSE:
We note the Staff’s comment, and, in response hereto, respectfully advise the Staff that the financial statements and related
disclosures have been updated in the Amended Registration Statement No. 1 to reflect the information contained in Item 8.A.4 of the Company’s
Annual Report on Form 20-F, as filed with the SEC on May 23, 2025.

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,

    MULTI
    WAYS HOLDINGS LTD

    By:

    /s/
    Lim Eng Hock

    Name:

    Lim
    Eng Hock

    Title:

    Chief
    Executive Officer

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