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SKK Holdings Limited

27 First Lok Yang Road

Singapore 629735

 September 3, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Pearlyne Paulemon

    Brigitte Lippmann

    Division of Corporate Finance

    Office of Real Estate & Construction

    Re:
    SKK Holdings Limited Request for Acceleration

    Registration Statement on Form F-1

    File No. 333-276744

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities
Act of 1933, as amended (the “Securities Act”), SKK Holdings Limited, a Cayman Islands company (the “Company”),
respectfully requests that the effective date of its Registration Statement on Form F-1 (File No. 333-276744) (the “Registration
Statement”), be accelerated so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday, September 4, 2024, or as
soon thereafter as possible.

In making this acceleration request, the Company acknowledges
that:

    (i)
    should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

    (ii)
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

    (iii)
    the Company may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Once the Registration Statement is effective, please
orally confirm the event with our counsel, TroyGould PC by calling David Ficksman at (310) 789-1290 or Joilene Wood at (415) 305-4651.
We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of the Registration
Statement be sent to our counsel, TroyGould PC, Attention: David Ficksman, by facsimile to (310)789-1290 or email at dficksman@troygould.com.

If you have any questions regarding this request,
please contact David Ficksman at (310) 789-1290.

    Very truly yours,

    By:
    /s/ Koon Kiat Sze

    Name:
    Koon Kiat Sze

    Title:
    Chief Executive Officer

    cc:
    David Ficksman, TroyGould PC

    R. Joilene Wood, TroyGould PC