SecProbe.io

CORRESP
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QMMM
HOLDINGS LIMITED

VIA
EDGAR

June
26, 2024

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Tony
    Watson

    Joel
    Parker

    Kate
    Beukenkamp

    Dietrich
    King

    Re:
    QMMM
    Holdings Ltd. (CIK No. 0001971542)

    Request
    for Acceleration

    Registration
    Statement on Form F-1, as amended (File No. 333-274887)

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended
(the “Securities Act”), QMMM Holdings Ltd. (the “Company”) hereby requests that the effectiveness of the above-referenced
Registration Statement on Form F-1, as amended (the “Form F-1 Registration Statement”) be accelerated to, and that
the Form F-1 Registration Statement become effective at, 4:00 p.m., Eastern Time on June 28, 2024, or as soon thereafter as practicable.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461
of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel,
FisherBroyles, LLP.

The
Company understands that the representative of the underwriters, on behalf of the prospective underwriters of the offering, have joined
in this request in a separate letter filed with the Securities and Exchange Commission (the “Commission”) today.

The
Company hereby acknowledges the following:

    ●
    should
    the Commission or the staff of the Commission (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 filing;

    ●
    the
    action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
    the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ●
    the
    Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

    Very
    truly yours,

    QMMM
    Holdings Ltd.

    By:
    /s/
    Bun Kwai

    Name:

    Bun
    Kwai

    Title:
    Chief
    Executive Officer and Chairman of the Board of the Directors