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                                                                     345
Park Avenue

                                                                     Main 212.407.4000

    New
    York, NY 10154
    Fax
    212.407.4990

August
21, 2024

United
States Securities and Exchange Commission

Division
of Corporation Finances

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    HomesToLife
    Ltd

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

    Submitted
    July 17, 2024

    CIK
    No. 0002023153

    Attn:
    Jenna Hough and Lilyanna Peyser

Dear
Ms. Hough and Ms. Peyser:

On
behalf of our client, HomesToLife Ltd (the “Company”), we hereby provide a response to the comments issued in a letter dated
July 31, 2024 (the “Staff’s Letter”) regarding the Company’s amendment No. 1 to Draft Registration Statement
on Form F-1 (the “Amendment No. 1”). Contemporaneously, we are filing Registration Statement on Form F-1 via Edgar (the “F-1”).

In
order to facilitate the review by the staff of the Securities and Exchange Commission (the “Staff”) of the F-1, we have responded,
on behalf of the Company, to the comments set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set
forth below respond to the Staff’s comments and correspond to the numbered paragraph in the Staff’s Letter.

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

Use
of Proceeds, page 33

1. We
                                            note your revised disclosure and response pursuant to comment 4 and reissue in part. Please
                                            state here, as you noted in your response, that you have not yet identified specific assets
                                            or businesses to acquire.

Response:
In response to the Staff’s comments, the Company has included additional disclosure on page 33 of the F-1.

Los
Angeles      New York     Chicago     Nashville     Washington, DC     San Francisco     Beijing Hong     Kong www.loeb.com

For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.

                                                                                United
States Securities and Exchange Commission

    August
    21, 2024

    Page 2

Combined
Financial Statements

Combined
Statements of Operations, page F-4

2. We
                                            read your response to prior comment 13. Please tell us and disclose in a financial statement
                                            footnote the nature of the amounts included in the recovery from over-accruals line item
                                            and the facts and circumstances resulting in the recovery from over-accruals in each period
                                            presented. Also tell us:

 ● the
                                            nature and amounts of the related expenses originally accrued in each period presented and
                                            the statement of operations line item(s) in which the original expenses were included,

Response:
In response to the Staff’s comments, the expenses originally over-accrued, which relate to operating expenses, have been reclassified
into general and administrative or sales and marketing expenses, amounting to SGD$78,188 (2022: SGD$9,923). Details of the transactions
that have not been reclassified are further disclosed on page F-4.

 ● why
                                            the recovery from over-accruals were not included in the same line item(s) that the original
                                            expenses were included in, if true, and

Response:
In response to the Staff’s comments, the Company has reclassified the recovery from over-accruals to the same line item in
which the original expenses were relatively included by nature.

 ● the
                                            GAAP literature you are relying upon for including the recovery from over- accruals in other
                                            income, net.

Response:
In response to the Staff’s comments, there is no GAAP literature that the Company is relying upon for including the recovery from
over-accruals in other income, net. The Company has reclassified the recovery to the same line item in which the original expenses were
included.

Please
call me at 212-407-4939 if you would like additional information with respect to any of the foregoing. Thank you.

    Sincerely,

    /s/
    Xiaoqin (“Sherry”) Li

    Xiaoqin
    (“Sherry”) Li

    Senior
    Counsel