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    Loeb
                                            & Loeb LLP

    345
    Park Avenue

    New York, NY 10154

Main    212.407.4000

    Fax       212.407.4990

September
19, 2024

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Jenna Hough and Lilyanna Peyser

    Re:
    HomesToLife
    Ltd

    Registration
    Statement on Form F-1

    Filed
    August 22, 2024

    File
    No. 333-281693

Dear
Sirs:

On
behalf of our client, HomesToLife Ltd (the “Company”), we hereby provide a response to the comments issued in a letter dated
September 19, 2024 (the “Staff’s Letter”) regarding the Company’s Registration Statement on Form F-1 (the
“F-1”). Contemporaneously, we are filing an amendment No. 1 to the F-1 via Edgar (the “Amendment No. 1”).

In
order to facilitate the review by the staff of the Securities and Exchange Commission (the “Staff”) of the Amendment No.
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.

Registration
Statement on Form F-1

Dilution,
page 36

    1.
    Please
    update your net tangible book value to December 31, 2023, as well as the underlying calculated amounts presented in the dilution
    table.

    Response:
    In response to the Staff’s comments, the Company has updated its net tangible book value
    to December 31, 2023, as well as the underlying calculated amounts presented in the dilution table, on page 36 of the Amendment No.
    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.

    September
                                            19, 2024

    Page
    2

Combined
Financial Statements

Combined
Statements of Operations, page F-4

    2.
    We
    reviewed the changes you made to correct the errors in your financial statements in response to prior comment 2. Please make arrangements
    with your auditor for them to revise their audit report to reference the error correction and the footnote that discusses it. Refer
    to paragraphs .09 and .16 of PCAOB AS 2820. Also, revise your financial statements to label them as restated and provide the disclosures
    required by ASC 250-10-50-7, including disclosing the nature of the errors and quantifying the effect of the error correction on
    income from operations.

    Response:
    In response to the Staff’s comments, the Company’s auditor has revised their audit
    report to reference the error correction and the footnote that discusses it in the Amendment No. 1.

Exhibit
5.1

    3.
    Please
    revise to include counsel’s consent to be named in the Material Income Tax Considerations section of the prospectus.

    Response:
    In response to the Staff’s comments, Ogier, the Company’s Cayman Islands counsel, has
    revised the Exhibit 5.1 of the Amendment No. 1.

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

cc:
Chew Kwang Yong, Chief Financial Officer of HomesToLife Ltd