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October 5, 2023
Gary Seaton
Chairman and CEO
Australian Oilseeds Holdings Limited
126-142 Cowcumbla Street, Cootamundra
Site 2: 52 Fuller Drive Cootamundra
PO Box 263 Cootamundra, Australia 2590
Re:Australian Oilseeds Holdings Limited
Registration Statement on Form F-4
Filed September 18, 2023
File No. 333-274552
Dear Gary Seaton:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form F-4 filed September 18, 2023
Background of the Business Combination, page 111
1.Please revise to disclose any discussions about the need to obtain additional financing for
the combined company in connection with the Business Combination transaction or
shortly thereafter, including the ELOC. Please discuss negotiations related to size of the
ELOC.
2.Please elaborate on the negotiations related to the PIPE, including the amount of the
PIPE.
Index to Consolidated Financial Statements
Australian Oilseeds Investments Pty Ltd, page F-1
3.Please provide updated annual audited financial statements and related disclosures as
required by Item 14 of Form F-4.

 FirstName LastNameGary Seaton
 Comapany NameAustralian Oilseeds Holdings Limited
 October 5, 2023 Page 2
 FirstName LastNameGary Seaton
Australian Oilseeds Holdings Limited
October 5, 2023
Page 2
Exhibits
4.We note you have filed the forms of the opinions as exhibit 5.1, 5.2 and 8.1. Please file the
executed and dated opinions with your next amendment.
General
5.Please revise your Form F-4 to provide risk factor disclosure regarding the Investment
Company Act of 1940 and Nasdaq listing risks consistent with the disclosure in the proxy
statement filed by EDOC Acquisition Corp. on October 3, 2023.
6.In your next amendment please include missing Annexes B-D.
7.Please revise your Background of the Business Combination section to disclose any
discussions about the need to obtain additional financing for the combined company in
connection with the Business Combination transaction or shortly thereafter, including the
ELOC. Please also revise your disclosure here to include all material terms of the ELOC,
including any termination provisions for the investor. Please file the ELOC as an exhibit
to your registration statement.
8.Please revise your prospectus summary to describe the agreement, including the
commitment fee payable to the investor in the form of commitment shares and any other
material terms, and update your estimated ownership percentages upon completion of the
business combination throughout your filing to account for the estimated commitment
shares. Finally, please include a separate, specific risk factor to address the potential
dilutive effect of your equity line agreement with the investor.
9.Please revise the tables on page 29 to reflect the ownership interest of the EDOC Public
Shareholders and others as result of the potential sources of dilution.
10.As previously requested in prior comment 6, please revise to disclose the scope of your
exclusive forum provision in your Amended and Restated Memorandum of Association
and include any appropriate risk factor disclosure.  In this regard. it appears that the new
disclosure on page 80 is related to an exclusive forum provision in the warrant agreement
rather than the exclusive forum provision in your Amended and Restated Memorandum of
Association.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Charles Eastman at 202-551-3794 or Anne McConnell at 202-551-3709 if
you have questions regarding comments on the financial statements and related matters. Please

 FirstName LastNameGary Seaton
 Comapany NameAustralian Oilseeds Holdings Limited
 October 5, 2023 Page 3
 FirstName LastName
Gary Seaton
Australian Oilseeds Holdings Limited
October 5, 2023
Page 3
contact Thomas Jones at 202-551-3602 or Asia Timmons-Pierce at 202-551-3754 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Barry I. Grossman, Esq.