SecProbe.io

CORRESP
1
filename1.htm

September
16, 2024

VIA
EDGAR TRANSMISSION

Division
of Corporate Finance

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549-6010

    Attn:

    Pearlyne
    Paulemon

    Brigitte
    Lippmann

    Division
    of Corporate Finance

    Office
    of Real Estate & Construction

    Re:
    SKK
    Holdings Limited (the “Company”)

    Registration
    Statement on Form F-1 (Registration No. 333-276744)

    Request
    for Acceleration of Effective Date

Ladies
and gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended, Bancroft Capital, LLC, as sole underwriter, hereby requests acceleration of the effective date of the above-referenced Registration
Statement so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday, September 18, 2024, or as soon thereafter as practicable,
or at such later time as the Company or its counsel may request via telephone call to the staff.

Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

    Very
    truly yours,

    Bancroft
    Capital, LLC

    By:
    /s/
    Robert L. Malin

    Name:

    Robert
    L. Malin

    Title:

    Managing
    Director

    cc:
    Mitchell
    Goldsmith, Esq., Taft Stettinius & Hollister LLP

    Alan
    Gilbert, Esq., Taft Stettinius & Hollister LLP