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CORRESP
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QMMM
Holdings Ltd.

April
22, 2024

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Tony
    Watson

    Joel
    Parker

    Kate
    Beukenkamp

    Dietrich
    King

    Re:
    QMMM
    Holdings Ltd.

    Amendment
    No. 2 to Registration Statement on Form F-1

    Filed
    March 25, 2024

    File
    No. 333-274887

Ladies
and Gentlemen:

On
behalf of our client, QMMM Holdings Limited, a foreign private issuer organized under the laws of Cayman Islands (the “Company”),
we are submitting this letter and the following information in response to a letter, dated April 10, 2024, from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Registration
Statement on Form F-1/A (the “Registration Statement”) filed with the Commission on March 25, 2024. Concurrently
with the submission of this letter, the Company is filing herewith Amendment No. 3 to registration statement on Form F-1 (the “Amended
Registration Statement”) and certain exhibits via EDGAR to the Commission.

To
facilitate your review, we have separately delivered to you a courtesy copy of the Amended Registration Statement, marked to show changes
to the Registration Statement filed with the Commission on March 25, 2024.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have included page references
in the Amended Registration Statement where the language addressing a particular comment appears. Capitalized terms used in this letter
but otherwise not defined herein shall have the meanings ascribed to such terms in the Amended Registration Statement.

In
addition to revising the disclosure in response to the Staff’s comments, the Company has also included other information and data
to reflect recent developments.

Amendment
No. 2 to Registration Statement on Form F-1

Cover Page

 1. We
                                            note your response to prior comment 1 and reissue in part. Please revise your disclosure,
                                            as appropriate, to reflect the amount due to ManyMany Creation by the holding company for
                                            the payment of salaries of executive officers. In this regard, we note your Compensation
                                            of Directors and Executive Officers disclosure on page 79 and your Related Party disclosure
                                            on page 84 reflect expense for executive officer salaries of $181,787, whereas your cover
                                            page disclosure and page 4 of your prospectus summary disclosure reflect an amount of $45,773.
                                            Please reconcile.

Response:
We have revised and updated disclosure on cover page and page 4 for the payment of salaries of executive officer amounting $181,787
as stated under Compensation of Directors and Executive Officers disclosure on page 79 and Related Party disclosure on page 84.

We
thank the Staff for its review of the foregoing and the Amended Registration Statement. If you have further comments, please feel free
to contact our counsel Jeffrey Li at Jeffrey.li@fisherbroyles.com or by telephone at (703) 618-2503.

    Very
    truly yours,

    /s/
    Bun Kwai

    Bun
    Kwai, Chief Executive Officer

    Enclosures

    cc:
    Jeffrey
    Li

    FisherBroyles,
    LLP

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