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October 19, 2023
Man Tak Lau
Director and Chairman of the Board of Directors
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia
Re:Linkers Industries Ltd
Draft Registration Statement on Form F-1
Submitted September 22, 2023
CIK 1972074
Dear Man Tak Lau:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Form F-1 submitted September 22, 2023
General
1.We note from page iv that you commissioned a report from Ken Research.  Please file
their consent as an exhibit.
2.We note that you are a foreign private issuer offering voting securities in the United
States.  Please tell us how would the company determine whether more than 50 percent of
its outstanding voting securities are owned of record by U.S. residents for purposes of
satisfying the foreign private issuer definition.  See Securities Act Rule 405 and Exchange
Act Rule 3b-4; Securities Act Rules Compliance and Disclosure Interpretation 203.17.
Industry and Market Data, page 34
3.You state that Ken Research Private Limited analysis shows that high inflation rates may
negatively affect the major appliances market in Asia-Pacific and Western Europe.  Please

 FirstName LastNameMan Tak Lau
 Comapany NameLinkers Industries Ltd
 October 19, 2023 Page 2
 FirstName LastName
Man Tak Lau
Linkers Industries Ltd
October 19, 2023
Page 2
expand to identify the principal factors contributing to the inflationary pressures the
company has experienced and clarify the resulting impact to the company.
Use of Proceeds, page 39
4.Please revise the first bullet to discuss in greater detail the potential acquisitions and joint
ventures.
Managements Discussion and Analysis of Financial Condition and Results of Operations, page
46
5.Please update your disclosure to identify actions planned or taken, if any, to mitigate
inflationary pressures.
Diversified customer base, page 60
6.Please identify the "key customers who are renowned global brand name manufacturers
and OEMs."  Also reconcile the "diversified customer base" with the concentration of
revenue percentages on page 17.
Management, page 81
7.Please update your disclosure to include compensation disclosure for your executive
officers.
Board of Directors, page 84
8.Please reconcile your disclosure here that a majority of your board will not be independent
with your disclosure that you do not intend to rely on controlled company provisions you
cite.
            Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick