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CORRESP
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SKK
Holdings Limited

27
First Lok Yang

Singapore
629735

July
19, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Pearlyne Paulman

    Re:
    SKK
    Holdings Limited

    Amendment
    No. 4 to Registration Statement on Form F-1

    File
    No. 333-276744

Ladies
and Gentlemen:

We
are writing in response to your letter dated July 17, 2024 with respect to the following comment regarding the Plan of Distribution on
page A-2:

“We
note your disclosure that broker-dealers may agree with the resale shareholders to sell a specified number of shares of your common stock
at a stipulated price per share, and that the resale shareholders may use any method permitted pursuant to applicable law when selling
shares of your common stock. Please confirm your understanding that the retention by a resale shareholder of an underwriter would constitute
a material change to your plan of distribution requiring a post-effective amendment. Refer to your undertaking provided pursuant to Item
512(a)(1)(iii) of Regulation S-K.”

We
confirm our understanding that the retention by a resale shareholder of an underwriter would constitute a material change to our plan
of distribution and would require a post-effective amendment. In the event the resale shareholder retains an underwriter, we would file
a post-effective amendment to disclose this material change.

Please
notify Joilene Wood of any questions or further comments at 415-305-4651 or jwood@troygould.com.

    Sincerely,

    SKK
    Holdings Limited

    /s/
    Koon Kiat Sze

    Koon
    Kiat Sze

    Chief
    Executive Officer

    cc:
    David
    L. Ficksman

    R.
    Joilene Wood