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 April 21, 2025

Xiaoyan Liao
Reporting Person
SKK Holdings Limited
27 First Lok Yang Road
Singapore, U0, 629735

 Re: SKK Holdings Limited
 Schedule 13D filed February 27, 2025 by Xiaoyan Liao
 File No. 005-94899
Dear Xiaoyan Liao:

 We have conducted a limited review of the above-captioned filing and
have the
following comments.

 Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comments apply to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.

 After reviewing any amendment to the filing and any information provided
in
response to these comments, we may have additional comments.

Schedule 13D filed February 27, 2025
General

1. We note that the event reported as requiring the filing of the Schedule
13D was
 December 31, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing
of a
 Schedule 13D within five business days after the date beneficial
ownership of more
 than five percent of a class of equity securities specified in Rule
13d-1(i)(1) was
 acquired. Based on the December 31, 2024 event date, the Schedule 13D
submitted on
 February 27, 2025, was not timely filed. Please advise us why the
Schedule 13D was
 not filed within the required five business days after the date of the
acquisition.
2. The cover page of the above-captioned Schedule 13D indicates that
December 31,
 2024 was the date of the event that required this filing to have been
made. Please
 advise us how this date was determined.
Item 3, page 1

3. Please amend the disclosure provided in Item 3 of your Schedule 13D to
include the
 April 21, 2025
Page 2

 amount of funds used to purchase the reported Ordinary Shares. Refer to
Item 3 of
 Schedule 13D.
Item 5, page 1

4. We note your disclosure of "[n]one" in Item 5(c) of your Schedule 13D.
Item 5(c),
 however, requires that each beneficial owner "describe any transactions
in the class of
 securities reported on that were effected during the past sixty days."
Please revise to
 provide the requisite disclosure for each filing person with respect to
all transactions
 in the securities between the deadline for timely filing the Schedule
13D and the
 actual filing of the Schedule 13D. In amending the Schedule 13D to
include the
 required disclosures, please be advised that the Instruction to Item
5(c) requires the
 beneficial owner to "describe," at a minimum, the following: "(1) The
identity of the
 person covered by Item 5(c) who effected the transaction; (2) the date
of transaction;
 (3) the amount of securities involved; (4) the price per share or unit;
and (5) where
 and how the transaction was effected."
 We remind you that the filing person is responsible for the accuracy
and adequacy
of his disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.

 Please direct any questions to Blake Grady at 202-551-8573 or Nicholas
Panos at
202-551-3266.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers &
Acquisitions
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