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CORRESP
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Davis Commodities Limited

August 31, 2023

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick Kuhn

    Theresa Brillant

    Nicholas Nalbantian

    Mara Ransom

    Re:
    Davis Commodities Limited

    Amendment No. 4 to Registration Statement on Form F-1

    Filed August 23, 2023

    File No. 333-270427

Ladies and Gentlemen:

This letter is in response to the letter dated
August 30, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Davis Commodities 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 amendment No. 5 to the Registration Statement
on Form F-1 is being filed to accompany this letter.

Cover Page

1. We note your intent to register a resale
transaction using a separate resale prospectus. Because you do not intend to use the resale prospectus unless and until the primary offering
is complete and NASDAQ listing is approved, revise to ensure the prospectus reflects that those events have taken place. For example,
revise to remove the initial public offering range and your statement that there is no public market for the Company's Ordinary Shares
given that you expect a market to be available when you use this prospectus. In this regard, Instruction 2 to Item 501(b)(3) of Regulation
S-K requires disclosure explaining the method by which the price will be determined and indicating the trading market and the market price
of the securities as of the latest practicable date.

In response to the Staff’s comments, we
have amended the disclosure in the resale prospectus on the cover page and under the heading “Selling Shareholders’ Plan of
Distribution” to clarify that the Resale Shares will be sold concurrently with the Company’s initial public offering shares
and from time to time thereafter.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Li Peng Leck

    Name:
    Li Peng Leck

    Title:

    Executive Chairwoman and

    Executive Director

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC