SecProbe.io

August 15, 2025
Tsai Yi Yang
Chief Executive Officer
Agencia Comercial Spirits Ltd.
No. 65, Ln. 114, Xishi Rd., Xi’an Vil., Fengyuan Dist.
Taichung City 42061, Taiwan (R.O.C.)
Re:Agencia Comercial Spirits Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed July 29, 2025
File No. 333-288600
Dear Tsai Yi Yang:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1
Exhibit Index, page II-4
1.Please have counsel revise their opinion in exhibit 5.1 to opine on the resale shares to
be offered by the Resale Prospectus and include the fully executed opinion.
2.We note your disclosure that you have entered into employment agreements with your
executive officers. We also note you have filed a "Form of Employment Agreement
between the Registrant and each of its executive officers" as an exhibit to the
registration statement. Please file the executed agreements with your executive
officers and revise to include a summary of the material terms of each agreement, if
applicable. Refer to Item 601(b)(10)(iii)(A).
3.Please revise the fee table to also include the resale shares.

August 15, 2025
Page 2
            Please contact Amy Geddes at 202-551-3304 or Angela Lumley at 202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Alyssa Wall at 202-551-8106 or Taylor Beech at 202-551-4515 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Kyle Leung