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JBDI
Holdings Limited

34
Gul Crescent

Singapore
629538

+65
6861 4150

August
26, 2024

VIA
EDGAR

Assistant
Director

Division
of Corporation Finance

Office
of Manufacturing

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Patrick Fullem

    Re:
    JBDI
    Holdings Limited

    (SEC
    File No. 333-276945)

Dear
Sir or Madam:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, JBDI Holdings Limited (the “Registrant”) hereby requests that Pre-Effective
Amendment No. 6 to the Registrant’s Registration Statement on Form F-1 (SEC File No. 333-276945), filed with the Commission on
August 21, 2024, become effective at 2:00 pm (Eastern Time) on August 26, 2024, or as soon thereafter as possible.

The
Registrant acknowledges that (i) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective,
it does not foreclose the Commission from taking any action with respect to the filings; (ii) the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and (iii) the Registrant may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please
note that this letter will be filed with the Commission via EDGAR. In light of the time difference between Washington D.C. and Singapore,
if you have any questions or concerns, please contact David Stefanski, Esq. at (303) 717-0744.

    JBDI HOLDINGS LIMITED

    By:
     /s/
    Mr. Lim Chwee Poh

    Name:
    Mr. Lim Chwee Poh

    Title:
    Executive Director and Principal Executive Officer

    c:
    Henry
    F. Schlueter

    David
    Stefanski