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 Document ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED Room B, 15th Floor, No. 77, Sec. 2, Dunhua S. Road, Taipei, Taiwan Tel: (886) 2-2712-2558 Fax: (886) 2-2712-3557 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing 100 F Street, N.E. Washington, D.C. 20549 November 26, 2025 Attention: Mr. Bradley Ecker Re: Asia Pacific Wire & Cable Corporation Limited Registration Statement on Form F-1 File No. 333-289970 Request for Acceleration of Effectiveness Dear Mr. Ecker: Asia Pacific Wire & Cable Corporation Limited (“APWC”) hereby requests that APWC’s Registration Statement on Form F-1 (File No. 333-289970), as amended, filed with the Securities and Exchange Commission on August 29, 2025, be declared effective at 10:00 a.m. (New York, NY time) on December 02, 2025, or as soon thereafter as practicable. APWC authorizes Ben Lee, its Chief Financial Officer, to orally modify or withdraw this request for acceleration. Best Regards, /s/ Ben Lee Name: Ben Lee Title: Chief Financial Officer

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 Document ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED Room B, 15th Floor, No. 77, Sec. 2, Dunhua S. Road, Taipei, Taiwan Tel: (886) 2-2712-2558 Fax: (886) 2-2712-3557 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing 100 F Street, N.E. Washington, D.C. 20549 Attention: Mr. Bradley Ecker Re: Asia Pacific Wire & Cable Corporation Limited Registration Statement on Form F-1 File No. 333-289970 Request for Acceleration of Effectiveness Dear Mr. Ecker: Asia Pacific Wire & Cable Corporation Limited (“APWC”) hereby requests that APWC’s Registration Statement on Form F-1 (File No. 333-289970), as amended, filed with the Securities and Exchange Commission on August 29, 2025, be declared effective at 10:00 a.m. (New York, NY time) on November 07, 2025, or as soon thereafter as practicable, once the SEC offices reopen following the current government shutdown. APWC authorizes Ben Lee, its Chief Financial Officer, to orally modify or withdraw this request for acceleration. Best Regards, /s/ Ben Lee Name: Ben Lee Title: Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 4, 2025

Paul Weber
Senior Vice President
ASIA PACIFIC WIRE & CABLE CORP LTD
15/Fl. B, No. 77, Sec. 2
Dunhua South Road
Taipei, 106, Taiwan
Republic of China

 Re: ASIA PACIFIC WIRE & CABLE CORP LTD
 Registration Statement on Form F-1
 Filed on August 29, 2025
 File No. 333-289970
Dear Paul Weber:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Bradley Ecker at 202-551-4985 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

July 18, 2024
Ivan Hsia
Chief Financial Officer
Asia Pacific Wire & Cable Corporation Limited
15/Fl. B, No. 77, Sec. 2
Dunhua South Road
Taipei, 106, Taiwan
Republic of China
Re:Asia Pacific Wire & Cable Corporation Limited
Form 20-F for the Year Ended December 31, 2023
Filed April 29, 2024
File No. 001-14542
Dear Ivan Hsia:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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apwc-responses_0705

   Re: Asia Pacific Wire & Cable Corporation Limited  Form 20-F for the Year Ended December 31, 2023  Filed April 29, 2024  File No. 001-14542    File No. 001-37928     Ladies and Gentlemen:     On behalf of Asia Pacific Wire & Cable Corporation Limited (the “Company”),  we are hereby filing with the Staff (the “Staff”) of the Division of Corporation Finance  of the Securities and Exchange Commission (the “Commission”) this response to the  letter dated June 10, 2024 from Heather Clark and Melissa Gilmore the Staff Office of  Manufacturing to Ivan Hsia the Company’s Chief Financial Officer (the “Comment  Letter”), with respect to the Company’s above-captioned Form 20-F for the Fiscal Year  Ended December 31, 2023 (the “Form 20-F”).     The comment and response set forth below are keyed to the headings used in the  Comment Letter.     Comment:  Financial Statements  Notes to the Consolidated Financial Statements  27. Financial Risk Management Objectives  27(d) Capital management, page F-84  1. We refer to “net debt” and “gearing ratio.” Please tell us whether these measures  are currently required to be disclosed by your home country or other applicable  securities regulators. If these measures are not currently required to be disclosed by  IFRS, Commission Rules, or regulatory requirements, it appears that they are non-  IFRS measures as defined by Item 10(e)(2) in Regulation S-K. Therefore, please  expand your disclosure in your future filings to explain how it was calculated, and  provide reconciliation to the most directly comparable IFRS measure. Refer to General  Instruction C(e) of Form 20-F. To the extent this is not required by IFRS, please revise  to remove this apparent non-IFRS measure from your financial statement footnotes.  Refer to Item 10(e)(1)(ii)(C) of Regulation S-K.    Response to Comment:  The Company respectfully advises the Staff that the Company will in future  filings provide additional disclosure regarding the reference and definition of “net debt” and  “gearing ratio”, please see the underlined text that follows below.  “IAS 1.134-135  requires entities to make qualitative and quantitative disclosures regarding their  objectives, policies, and processes for managing capital. The Company has disclosed  its gearing ratio as this is the measure it uses to monitor capital. The Company  considers both capital and net debt as relevant components of funding, and hence,

part of its capital management. The gearing ratio indicates the current proportion of  debt in the Company's capital structure.  The Company has provided the definition of 'net debt' because this is relevant  to understanding how it manages capital, and it is not defined in the IFRS Accounting  Standard. Additionally, the Company has provided reconciliations between these  measures and items represented in the consolidated financial statements.”    27(d)    Capital management  The primary objectives of our Company’s capital management are to safeguard  our Company’s ability to continue as a going concern and maintain healthy capital  ratios in order to support its business, maximize shareholders’ value and to maintain  an optimal capital structure to reduce the cost of capital.  Our Company manages its capital structure and makes adjustments to it, in  light of changes in economic conditions and the risks characteristics of the underlying  assets. To maintain or adjust the capital structure, our Company may adjust the  dividend payment to shareholders, return capital to shareholders, issue new shares or  conduct stock repurchase programs. Our Company is not subject to any externally  imposed capital requirements. No changes were made in the objectives, policies or  processes for managing capital during the years ended December 31, 2023 and 2022.  In line with industry practices, our Company monitors capital on the basis of  the following gearing ratio:  Net debt (interest bearing loans and borrowings, trade and other payables, less  cash and cash equivalents, as shown in the Consolidated Balance Sheets.)  divided by   Total equity (as shown in the Consolidated Balance Sheets)    In addition, the Company acknowledges that the Company and its  management are responsible for the accuracy and adequacy of their disclosures,  notwithstanding any review, comments, action or absence of action by the Staff.      If you have any questions or comments regarding the foregoing, kindly contact  the undersigned at +886-2-27122558 or Paul Weber, our legal counsel, at +1(972)754- 8992.     Sincerely,     /s/ Ivan Hsia  Ivan Hsia   Chief Financial Officer

United States securities and exchange commission logo
June 10, 2024
Ivan Hsia
Chief Financial Officer
Asia Pacific Wire & Cable Corporation Limited
15/Fl. B, No. 77, Sec. 2
Dunhua South Road
Taipei, 106, Taiwan
Republic of China
Re:Asia Pacific Wire & Cable Corporation Limited
Form 20-F for the Year Ended December 31, 2023
Filed April 29, 2024
File No. 001-14542
Dear Ivan Hsia:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Year Ended December 31, 2023
Financial Statements
Notes to the Consolidated Financial Statements
27. Financial Risk Management Objectives
27(d) Capital management, page F-84
1.We refer to “net debt” and “gearing ratio.”  Please tell us whether these measures are
currently required to be disclosed by your home country or other applicable securities
regulators.  If these measures are not currently required to be disclosed by IFRS,
Commission Rules, or regulatory requirements, it appears that they are non-
IFRS measures as defined by Item 10(e)(2) in Regulation S-K.  Therefore, please expand
your disclosure in your future filings to explain how it was calculated, and provide
reconciliation to the most directly comparable IFRS measure.  Refer to General
Instruction C(e) of Form 20-F.  To the extent this is not required by IFRS, please revise to

 FirstName LastNameIvan Hsia
 Comapany NameAsia Pacific Wire & Cable Corporation Limited
 June 10, 2024 Page 2
 FirstName LastName
Ivan Hsia
Asia Pacific Wire & Cable Corporation Limited
June 10, 2024
Page 2
remove this apparent non-IFRS measure from your financial statement footnotes.  Refer to
Item 10(e)(1)(ii)(C) of Regulation S-K.

            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Heather Clark at 202-551-3624 or Melissa Gilmore at 202-551-3777 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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 ARNOLD & PORTER KAYE SCHOLER LLP

Three Embarcadero Center, 10th Floor

San Francisco, California 94111

December 23, 2021

 VIA EDGAR

 Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

Attention:

Geoff Kruczek

Special Counsel

Anne Parker

Office Chief

Re:

Registration Statement on Form F-1 of

Asia Pacific Wire & Cable Corporation Limited

 Ladies and Gentlemen:

On behalf of Asia Pacific Wire & Cable Corporation Limited (“APWC”) we hereby request that APWC’s Registration
Statement on Form F-1 (File No. 333-257970), as amended, filed with the Securities and Exchange Commission on July 16, 2021, be declared effective at 10:00
a.m. (New York time) on December 28, 2021, or as soon thereafter as practicable.

 Very truly yours,

By:

 /s/ Benjamin Fackler

 Benjamin Fackler

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 ARNOLD & PORTER KAYE SCHOLER LLP

Three Embarcadero Center, 10th Floor

San Francisco, California 94111

December 15, 2021

 VIA EDGAR AND E-MAIL

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Manufacturing

100 F Street, N.E.

 Washington, D.C. 20549

Attn:

 Geoff Kruczek

 Special Counsel

 Anne Parker

Office Chief

 Re:  

 Asia Pacific Wire & Cable Corp Ltd

Amendment No. 2 to Registration Statement on Form F-1

Filed December 10, 2021

 File No. 333-257970

 Dear Mr. Kruczek,

This letter responds to the comments of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) as communicated to us via telephone on December 14, 2021 (the “Communication”) with respect to the above-referenced Registration Statement (the “Registration Statement”). On behalf of Asia Pacific
Wire & Cable Corp Ltd (the “Company”), we are responding to the Communication, as set forth below.

 Our understanding
of the Staff’s telephonic comments are summarized below in bold-face type for your ease of reference and are followed by the Company’s response. With this letter, and bearing the same date, the Company is filing Amendment No. 3 to the
Registration Statement (“Amendment No. 3”).

 ***

Amendment No. 2 to Form F-1 filed December 10, 2021

Risk Factors, page 29

1.
 In the second to last sentence on page 29, remove the words “without restriction”.

 In response to the Staff’s comment, the Company has updated its Registration Statement by filing Amendment
No. 3 to incorporate the Staff’s comment. Please see the revised disclosure on page 29 of Amendment No. 3.

 Summary of Risk Factors,
page iv; and Risk Factors, pages 29-30

2.
 Add language “in addition to the trading prohibition, shares may also be delisted” to the end of
the following risk factor (and summary of same): “[o]ur auditor’s China affiliate, like other independent registered public accounting firms operating in China, is not permitted to be subject to inspection by the Public Company Accounting
Oversight Board, and if the PCAOB determines that it is unable to inspect or investigate completely because of a position taken by the PRC government, trading in our securities could be prohibited in the U.S.”

 In response to the Staff’s comment, the Company has updated its Registration Statement
by filing Amendment No. 3 to incorporate the Staff’s comment. Please see the revised disclosures on page iv and pages 29-30 of Amendment No. 3.

We trust the foregoing is responsive to the Staff’s comments. If you have any additional comments or questions, please do not hesitate to
contact the undersigned at ben.fackler@arnoldporter.com or (415) 471-3125, or Isaac Chao at isaac.chao@arnoldporter.com or (415) 471-3126.

Sincerely,

/s/ Benjamin Fackler

Benjamin Fackler

 Enclosures

cc:
 Ivan Hsia

Daphne Hsu

 James Lu

Lucy Tsai

 (Asia Pacific
Wire & Cable Corp. Ltd)

 Isaac Chao

(Arnold & Porter Kaye Scholer LLP)

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 ARNOLD & PORTER KAYE SCHOLER LLP

Three Embarcadero Center, 10th Floor

San Francisco, California 94111

December 10, 2021

 VIA EDGAR AND E-MAIL

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 Office of Manufacturing

100 F Street, N.E.

 Washington, D.C. 20549

 Attn:

 Geoff Kruczek

 Special Counsel

 Anne Parker

 Office Chief

 Re:

 Asia Pacific Wire & Cable Corp Ltd

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

 Filed September 2, 2021

 File No. 333-257970

 Dear Mr. Kruczek,

This letter responds to the comments of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) dated November 19, 2021 (the “Comment Letter”) with respect to the above-referenced Registration Statement (the “Registration Statement”). On behalf of Asia Pacific Wire & Cable Corp Ltd (the
“Company”), we are responding to the Comment Letter, as set forth below.

 The Staff’s comments are retyped below in
bold-face type for your ease of reference and are followed by the Company’s response. With this letter, and bearing the same date, the Company is filing Amendment No. 2 to the Registration Statement (“Amendment No. 2”).

***

 Amendment
No. 1 to Form F-1 filed September 2, 2021

 Prospectus Cover Page, page i

1.
 Provide a description of how cash is transferred through your organization and disclosure regarding your
intentions to distribute earnings or settle amounts owed under your agreements. State whether any transfers, dividends, or distributions have been made to date.

In response to the Staff’s comment, the Company has updated its Registration Statement by filing Amendment No. 2 to include updated
disclosures regarding the Company’s current intentions to distribute earnings, settle amounts owed under agreements, or make transfers, dividends, or distributions. Please see the revised disclosures commencing on page 10 (Prospectus Summary),
on page 37 (Risk Factors), and on page 46 (Dividend Policy) of Amendment No. 2.

 Prospectus Summary, page 8

2.
 Please disclose whether you are required to obtain any approvals to offer securities to foreign investors,
whether you have received such approvals and the consequences to you and your investors if you do not receive or maintain the approvals, inadvertently conclude that such approvals are not required, or applicable laws, regulations, or interpretations
change and you are required to obtain approval in the future.

 We respectfully refer the Staff to page ii (About this
Prospectus) of the Registration Statement, which states that “[t]his prospectus does not constitute an offer to sell, or a solicitation of an offer to purchase, the securities offered by this prospectus in any jurisdiction where it is unlawful
to make such offer or solicitation. For investors outside of the United States: We have not done anything that would permit this offering or possession or distribution of this prospectus in any jurisdiction where action for that purpose is required,
other than in the United States. You are required to inform yourselves about and to observe any restrictions relating to this offering and the distribution of this prospectus.”

Accordingly, the Company is not making any public offering in foreign jurisdictions where such public offering would be unlawful. As to whether
any foreign approvals would be required in order to make an offering in a foreign jurisdiction lawful, the Company is unable to determine, based on the information available to the Company, the location of each of its shareholders for purposes of
the applicable foreign securities law analyses, given shareholdings of record in “Street” name and uncertainty around the actual residence or location of individual beneficial owner shareholders. Notwithstanding the foregoing, responsive
to the Staff’s comments, the Company has updated its Registration Statement by filing Amendment No. 2 to include disclosures addressing the Staff’s comment, including concerning Bermuda securities laws (where the Company is formed),
Taiwanese securities laws (where our controlling shareholder maintains its corporate headquarters) and risks associated with any applicable foreign securities laws. Please see the disclosures on page 11 (Prospectus Summary), page 40 (Risk Factors)
and pages 58 - 59 (The Rights Offering) of Amendment No. 2.

 Risk Factors, page 16

3.
 Please expand your risk factor disclosure to discuss that the United States Senate passed the Accelerating
Holding Foreign Companies Accountable Act, which, if enacted, would decrease the number of non-inspection years from three years to two, thus reducing the time period before your securities may be prohibited
from trading or delisted.

 In response to the Staff’s comment, the Company has updated its Registration
Statement by filing Amendment No. 2 to include disclosure with respect to the Accelerating Holding Foreign Companies Accountable Act (if enacted) and the risk it presents to our investors. Please see the disclosure on page 30 (Risk Factors) of
Amendment No. 2.

 We trust the foregoing is responsive to the Staff’s comments. If you have any additional comments or
questions, please do not hesitate to contact the undersigned at ben.fackler@arnoldporter.com or (415) 471-3125, or Isaac Chao at isaac.chao@arnoldporter.com or (415)
471-3126.

 Sincerely,

 /s/ Benjamin Fackler

 Benjamin Fackler

 Enclosures

 cc:

Ivan Hsia

 Daphne Hsu

 James Lu

 Lucy Tsai

 (Asia Pacific Wire & Cable Corp. Ltd)

 Isaac Chao

 (Arnold & Porter Kaye Scholer LLP)

 - 2 -

United States securities and exchange commission logo
November 19, 2021
Ivan Hsia
Chief Financial Officer
ASIA PACIFIC WIRE & CABLE CORP LTD
15/Fl. B, No. 77, Sec. 2
Dunhua South Road
Taipei, 106, Taiwan
Republic of China
Re:ASIA PACIFIC WIRE & CABLE CORP LTD
Amendment No. 1 to Registration Statement on Form F-1
Filed September 2, 2021
File No. 333-257970
Dear Mr. Hsia:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Amendment No. 1 to Form F-1 filed September 2, 2021
Prospectus Cover Page, page i
1.Provide a description of how cash is transferred through your organization and disclosure
regarding your intentions to distribute earnings or settle amounts owed under your
agreements.  State whether any transfers, dividends, or distributions have been made to
date.
Prospectus Summary, page 8
2.Please disclose whether you are required to obtain any approvals to offer securities to
foreign investors, whether you have received such approvals and the consequences to you

 FirstName LastNameIvan Hsia
 Comapany NameASIA PACIFIC WIRE & CABLE CORP LTD
 November 19, 2021 Page 2
 FirstName LastName
Ivan Hsia
ASIA PACIFIC WIRE & CABLE CORP LTD
November 19, 2021
Page 2
and your investors if you do not receive or maintain the approvals, inadvertently conclude
that such approvals are not required, or applicable laws, regulations, or interpretations
change and you are required to obtain approval in the future.
Risk Factors, page 16
3.Please expand your risk factor disclosure to discuss that the United States Senate passed
the Accelerating Holding Foreign Companies Accountable Act, which, if enacted, would
decrease the number of non-inspection years from three years to two, thus reducing the
time period before your securities may be prohibited from trading or delisted.
             Please contact Geoff Kruczek at (202) 551-3641 or Anne Parker, Office Chief, at (202)
551-3611 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Benjamin Fackler

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 ARNOLD & PORTER KAYE SCHOLER LLP

Three Embarcadero Center, 10th Floor

San Francisco, California 94111

 September 2,
2021

 VIA EDGAR AND E-MAIL

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Manufacturing

 100 F Street, N.E.

Washington, D.C. 20549

Attn:
 Geoff Kruczek

 Special Counsel

 Anne Parker

 Office Chief

Re:
 Asia Pacific Wire & Cable Corp Ltd

 Registration Statement on Form F-1

 Filed July 16, 2021

 File No. 333-257970

Dear Mr. Kruczek,

 This letter responds to the
comments of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) dated August 13, 2021 (the “Comment Letter”) with respect to the above-referenced Registration Statement (the
“Registration Statement”). On behalf of Asia Pacific Wire & Cable Corp Ltd (the “Company”), we are responding to the Comment Letter, as set forth below.

The Staff’s comments are retyped below in bold-face type for your ease of reference and are followed by the Company’s response. With
this letter, and bearing the same date, the Company is filing Amendment No. 1 to the Registration Statement (“Amendment No. 1”).

***

 Registration Statement
on Form F-1 filed July 16, 2021

 Prospectus Cover Page, page i

1.
 Please disclose prominently on the prospectus cover page that you are not a Chinese operating company but a
Bermuda holding company with operations conducted by your subsidiaries.

 In response to the Staff’s comment, the
Company has updated its Registration Statement by filing Amendment No. 1 to include disclosure on the prospectus cover page clarifying that the Company is not a Chinese operating company, but rather a holding company based in Bermuda, with its
headquarters in Taipei, Taiwan, with operating subsidiaries in the countries in which it operates, including the People’s Republic of China (the “PRC”).

2.
 Provide prominent disclosure about the legal and operational risks associated with being based in or having
the majority of the company’s operations in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or the value of your common shares or could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless. Your disclosure should address how recent statements and regulatory actions by China’s
government, such as those related to the use of variable interest entities and data security or anti-monopoly concerns, has or may impact the company’s ability to conduct its business, accept foreign investments, or list on an U.S. or other
foreign exchange. Your prospectus summary should address, but not necessarily be limited to, the risks highlighted on the prospectus cover page.

 We respectfully note that the Company is not based, and does not have the majority of its
operations, in PRC. The Company’s Taipei, Taiwan headquarters, and relative contributions of various geographic segments including North Asia (which encompasses PRC, Hong Kong and Taiwan), are disclosed in the Company’s Annual Report on 20-F and the Company’s financial statements filed therewith, which are incorporated by reference into the Registration Statement. In response to the Staff’s comment and in order to highlight the
Company’s relative geographic exposures in its various markets in the Asia Pacific region, the Company has updated its Registration Statement by filing Amendment No. 1 to include (1) disclosure on the prospectus cover page concerning
its ownership and control structure, (2) disclosure in the prospectus summary commencing on page 8 describing in greater detail its structure and operations, including relative geographic contributions, and (3) enhanced disclosure of
certain risks associated with the operation of its subsidiaries in PRC in both the summary risk factors on pages (iv) - (v) and the risk factors on pages 28 - 37 of the prospectus included
in Amendment No. 1.

3.
 Clearly disclose how you will refer to the holding company and subsidiaries when providing the disclosure
throughout the document so that it is clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business operations. Disclose clearly the entity (including the domicile) in which investors
are purchasing their interest.

 In response to the Staff’s comment, the Company has updated its Registration
Statement by filing Amendment No. 1 to clarify references to the Company and its business and operations on the prospectus cover page, on page (ii) of the prospectus summary and throughout the remainder of the prospectus where applicable.

Summary Risk Factors, page iii

4.
 In your summary of risk factors, disclose the risks that your corporate structure and being based in or
having the majority of the company’s operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the
prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice;
and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in
your operations and/or the value of your common shares. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers
could significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

We respectfully refer the Staff to our response to Comment 2, including the revised disclosure of certain risks associated with the ownership
and operation of the Company’s PRC subsidiaries reflected in both the summary risk factors on pages (iv) - (v) and the risk factors on pages 28 - 37 of the prospectus included in Amendment No. 1.

Prospectus Summary, page 1

5.
 Disclose each permission that you or your subsidiaries are required to obtain from Chinese authorities to
operate and issue these securities to foreign investors. State whether you or your subsidiaries are covered by permissions requirements from the CSRC, CAC or any other entity that is required to approve your or your subsidiaries’ operations,
and state affirmatively whether you have received all requisite permissions and whether any permissions have been denied.

 2

 We note to the Staff that, based on conversations with PRC counsel, as a Bermuda company
with headquarters in Taipei, Taiwan, the Company is not required to obtain any permission from PRC authorities to issue the Company’s subscription rights, or the Company’s Common Shares upon exercise of the subscription rights, to foreign
investors. Given that certain Chinese regulators have authority over the Company’s subsidiaries based in the PRC, and not APWC or its other subsidiaries or operations, in response to the Staff’s comment, the Company has revised the
disclosure of certain risks associated with the ownership and operation of the Company’s PRC subsidiaries, both in the summary risk factors on pages (iv) - (v) and the risk factors on
pages 28 - 37 of the prospectus included in Amendment No. 1.

6.
 Provide a clear description of how cash is transferred through your organization. Disclose your intentions
to distribute earnings or settle amounts owed under the your operating structure. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries and direction of transfer. Quantify
any dividends or distributions that a subsidiary has made to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax
consequences. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from your
businesses, including subsidiaries and/or consolidated VIEs, to the parent company and U.S. investors as well as the ability to settle amounts owed.

In response to the Staff’s comment, the Company has updated its Registration Statement by filing Amendment No. 1 to include more
detailed disclosure with respect to the company’s current structure and cash flows within that structure, including dividends received by the Company from relevant subsidiaries, tax implications relating to such dividends, and the effect of
foreign exchange restrictions on such cash flows. Please see the revised disclosures commencing on page 8 of the prospectus included in Amendment No. 1. In addition, in response to the Staff’s comment, the Company has also added an
additional risk factor on page 33 of the prospectus included in Amendment No. 1 to address risks regarding the PRC government’s control of currency conversion and expatriation of funds with respect to the Company’s PRC
subsidiaries.

7.
 Disclose that trading in your securities may be prohibited under the Holding Foreign Companies Accountable
Act if the PCAOB determines that it cannot inspect or fully investigate your auditor, and that as a result an exchange may determine to delist your securities. If the PCAOB has been or is currently unable to inspect your auditor, revise your
disclosure to so state.

 In response to the Staff’s comment, the Company has updated its Registration Statement
by filing Amendment No. 1 to supplement the discussion of the risks related to the Holding Foreign Companies Accountable Act and related PCAOB inspections of the Company’s PRC subsidiaries. Please see pages 28 - 29 of the
prospectus included in Amendment No. 1.

 Risk Factors, page 14

8.
 Given the Chinese government’s significant oversight and discretion over the conduct of your business,
please revise to separately highlight the risk that the Chinese government may intervene or influence your operations at any time, which could result in a material change in your operations and/or the value of your common shares. Also, given recent
statements by the Chinese government indicating an intent to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers, acknowledge the risk that any such action could significantly
limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

 3

 We respectfully refer the Staff to our response to Comment 2, including the revised
disclosure of certain risks associated with the ownership and operation of the Company’s subsidiaries in PRC reflected in both the summary risk factors on pages (iv) - (v) and the risk factors on pages 28 - 37 of the prospectus included in
Amendment No. 1.

9.
 In light of recent events indicating greater oversight by the Cyberspace Administration of China over data
security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure to explain how this oversight impacts your business and your offering and to what extent you believe that you are compliant with the
regulations or policies that have been issued by the CAC to date.

 In response to the Staff’s comment, the
Company has updated its Registration Statement by filing Amendment No. 1 to include disclosure with respect to relevant cybersecurity regulations in the PRC. Please see pages 31-33 of the prospectus included in Amendment No. 1.

We trust the foregoing is responsive to the Staff’s comments. If you have any additional comments or questions, please do not hesitate to
contact the undersigned at ben.fackler@arnoldporter.com or (415) 471-3125, or Isaac Chao at isaac.chao@arnoldporter.com or (415) 471-3126.

Sincerely,

/s/ Benjamin Fackler

Benjamin Fackler

 Enclosures

cc:
 Ivan Hsia

 Angeline Tseng

 James Lu

 Daphne Hsu

 (Asia Pacific Wire & Cable Corp. Ltd)

 Isaac Chao

 (Arnold & Porter Kaye Scholer LLP)

 4

United States securities and exchange commission logo
August 13, 2021
Ivan Hsia
Chief Financial Officer
ASIA PACIFIC WIRE & CABLE CORP LTD
15/Fl. B, No. 77, Sec. 2
Dunhua South Road
Taipei, 106, Taiwan
Republic of China
Re:ASIA PACIFIC WIRE & CABLE CORP LTD
Registration Statement on Form F-1
Filed July 16, 2021
File No. 333-257970
Dear Mr. Hsia:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1 filed July 16, 2021
Prospectus Cover Page, page i
1.Please disclose prominently on the prospectus cover page that you are not a Chinese
operating company but a Bermuda holding company with operations conducted by your
subsidiaries.
2.Provide prominent disclosure about the legal and operational risks associated with being
based in or having the majority of the company’s operations in China.  Your disclosure
should make clear whether these risks could result in a material change in your operations
and/or the value of your common shares or could significantly limit or completely hinder

 FirstName LastNameIvan Hsia
 Comapany NameASIA PACIFIC WIRE & CABLE CORP LTD
 August 13, 2021 Page 2
 FirstName LastNameIvan Hsia
ASIA PACIFIC WIRE & CABLE CORP LTD
August 13, 2021
Page 2
your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.  Your disclosure should address how
recent statements and regulatory actions by China’s government, such as those related to
the use of variable interest entities and data security or anti-monopoly concerns, has or
may impact the company’s ability to conduct its business, accept foreign investments, or
list on an U.S. or other foreign exchange. Your prospectus summary should address, but
not necessarily be limited to, the risks highlighted on the prospectus cover page.
3.Clearly disclose how you will refer to the holding company and subsidiaries when
providing the disclosure throughout the document so that it is clear to investors which
entity the disclosure is referencing and which subsidiaries or entities are conducting the
business operations.  Disclose clearly the entity (including the domicile) in which
investors are purchasing their interest.
Summary Risk Factors, page iii
4.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or having the majority of the company’s operations in China poses to investors.
In particular, describe the significant regulatory, liquidity, and enforcement risks with
cross-references to the more detailed discussion of these risks in the prospectus.  For
example, specifically discuss risks arising from the legal system in China, including risks
and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of
your common shares.  Acknowledge any risks that any actions by the Chinese government
to exert more oversight and control over offerings that are conducted overseas and/or
foreign investment in China-based issuers could significantly limit or completely hinder
your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.
Prospectus Summary, page 1
5.Disclose each permission that you or your subsidiaries are required to obtain from Chinese
authorities to operate and issue these securities to foreign investors. State whether you or
your subsidiaries are covered by permissions requirements from the CSRC, CAC or any
other entity that is required to approve your or your subsidiaries' operations, and state
affirmatively whether you have received all requisite permissions and whether any
permissions have been denied.
6.Provide a clear description of how cash is transferred through your organization.  Disclose
your intentions to distribute earnings or settle amounts owed under the your operating
structure.  Quantify any cash flows and transfers of other assets by type that have occurred
between the holding company and its subsidiaries and direction of transfer.  Quantify any

 FirstName LastNameIvan Hsia
 Comapany NameASIA PACIFIC WIRE & CABLE CORP LTD
 August 13, 2021 Page 3
 FirstName LastNameIvan Hsia
ASIA PACIFIC WIRE & CABLE CORP LTD
August 13, 2021
Page 3
dividends or distributions that a subsidiary has made to the holding company and which
entity made such transfer, and their tax consequences.  Similarly quantify dividends or
distributions made to U.S. investors, the source, and their tax consequences.  Describe any
restrictions on foreign exchange and your ability to transfer cash between entities, across
borders, and to U.S. investors.  Describe any restrictions and limitations on your ability to
distribute earnings from your businesses, including subsidiaries and/or consolidated VIEs,
to the parent company and U.S. investors as well as the ability to settle amounts owed.
7.Disclose that trading in your securities may be prohibited under the Holding Foreign
Companies Accountable Act if the PCAOB determines that it cannot inspect or fully
investigate your auditor, and that as a result an exchange may determine to delist your
securities.  If the PCAOB has been or is currently unable to inspect your auditor, revise
your disclosure to so state.
Risk Factors, page 14
8.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to separately highlight the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of your common shares.  Also, given recent
statements by the Chinese government indicating an intent to exert more oversight and
control over offerings that are conducted overseas and/or foreign investment in China-
based issuers, acknowledge the risk that any such action could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless.
9.In light of recent events indicating greater oversight by the Cyberspace Administration of
China over data security, particularly for companies seeking to list on a foreign exchange,
please revise your disclosure to explain how this oversight impacts your business and your
offering and to what extent you believe that you are compliant with the regulations or
policies that have been issued by the CAC to date.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameIvan Hsia
 Comapany NameASIA PACIFIC WIRE & CABLE CORP LTD
 August 13, 2021 Page 4
 FirstName LastName
Ivan Hsia
ASIA PACIFIC WIRE & CABLE CORP LTD
August 13, 2021
Page 4

            Please contact Geoff Kruczek at (202) 551-3641 or Anne Parker, Office Chief, at (202)
551-3611 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Benjamin Fackler

CORRESP
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CORRESP

 ARNOLD & PORTER KAYE SCHOLER LLP

Three Embarcadero Center, 10th Floor

San Francisco, California 94111

 VIA EDGAR

 July 16, 2021

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Asia Pacific Wire & Cable Corporation Limited—Registration Statement on Form F-1

 Ladies and Gentlemen:

On behalf of Asia Pacific Wire & Cable Corporation Limited (“APWC”), we hereby transmit electronically for filing under the
Securities Act of 1933, as amended, a Registration Statement of APWC on Form F-1, including exhibits thereto.

The filing fee for the Registration Statement in the aggregate amount of $904.64 has been deposited by wire transfer of same day funds to the
Commission’s account at U.S. Bank.

 If you should have any questions with respect to this filing, please do not hesitate to contact
the undersigned at (415) 471-3125 or ben.fackler@arnoldporter.com, or Isaac Chao at (415) 471-3126 or isaac.chao@arnoldporter.com.

Sincerely,

/s/ Benjamin Fackler

 (Enclosures)

cc:
 Ivan Hsia

Angeline Tseng

 James Lu

Daphne Hsu

 (Asia Pacific
Wire & Cable Corporation Limited)

 Isaac Chao

(Arnold & Porter Kaye Scholer LLP)

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

        November 1, 2011
Via E-mail
 Frank Tseng, CFO Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road
Taipei, 105, Taiwan
People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
Form 20-F for the Fiscal Ye ar Ended December 31, 2010
Filed May 13, 2011 File No. 1-14542

Dear Mr. Tseng:
We have completed our review of your  filing. We remind you that our comments
or changes to disclosure in response to our comments do not for eclose the Commission
from taking any action with respect to the company or the filing and the company may
not assert staff comments as a defense in any proceeding initiate d by the Commission or
any person under the federal securities laws of  the United States.  We urge all persons
who are responsible for the accuracy and adequa cy of the disclosure in the filing to be
certain that the filing include s the information the Securities Exchange Act of 1934 and
all applicable rules require.                                                       Sincerely,       /s/ Terence O’Brien                                                      Terence O'Brien                                                         Accounting Branch Chief

CORRESP
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corresp

October 26, 2011

Chief Accountant’s Office

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention:   Mr. Terence O’Brien, Chief

                   Mr. Alfred Pavot

    Re:

    Asia Pacific Wire & Cable Corporation

Limited (the “Company”) File No. 333-153796

Dear Sirs:

We write on behalf of the Company in connection with its response letter dated as of today’s date
(the “Response Letter”) and submitted herewith in response to the letter of the Commission dated
October 20, 2011 providing certain comments on the Company’s annual report on Form 20-F for the
fiscal year ended December 31, 2010 (the “2010 Form 20-F”).

We wish to confirm the Company’s understanding that the draft disclosure language provided in
paragraph 4 of the Response Letter is for illustrative purposes, in response to the Staff’s request
for sample disclosure, in connection with future filings to be made by the Company. The Company
wishes to confirm that in its future filings it shall provide disclosure, when relevant, that
addresses the methodology employed to calculate DSO, and whether the amounts used, in this case
with respect to accounts receivable, are based upon net or gross amounts.

We wish to clarify also that references in the Response Letter to page F-4 or any other
F-denominated pages refer to the financial statement pages set forth in the audit report of the
Company that forms part of the 2010 Form 20-F.

Please do not hesitate to contact the undersigned if you have any questions with regard to the
foregoing or the Response Letter. Thank you for your attention to this matter.

Very truly yours,

Michael J. Hagan

cc: Mr. Frank Tseng, Chief Financial Officer

    Michael.Hagan@ThompsonHine.com Fax: 212.344.6101 Phone: 212.908.3916

    MH:cl 210611.1

    Asia Pacific Wire & Cable Corp Ltd

Quoted on the New York OTC Bulletin Board

7/FI. B, No. 132, Sec. 3, Min-Sheng East Road, Taipei, 105,
Taiwan

Tel: 886(2) 2712 2558 Fax: 886(2) 2712 3557

October 26, 2011

By
Email: (PavotA@SEC.GOV), and U.S. Mail

By Edgar

Terence O’Brien

Accounting Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable Corporation Limited (the
“Company”) File No. 333-153796

Dear Mr. O’Brien:

This letter is in reply to your letter of October 20, 2011, which commented on the Form 20-F
filed by the Company for the fiscal year ended December 31, 2010. Please find our responses below.
Our paragraph numbering corresponds to the paragraph numbers in your October 20, 2011 letter.

1. Duly noted and the Company wishes to confirm that it shall comply with this comment.

2. Duly noted and the Company wishes to confirm that it shall apply with this comment.

3. In calculating the DSO data on page 55, we used gross
accounts receivable as the basis for
our results, while on page 48 we used net accounts receivable, by which we mean net of
estimated allowance for doubtful accounts. While gross accounts receivable increased by 37% in
2010, net accounts receivable only increased by 21%. As the annual and 4th quarter sales increased
by 30% and 6%, respectively, the DSO based on net accounts receivable accordingly decreased. In
future, we will conform our methodologies to avoid confusion.

4. We will expand disclosure in future filings to address whether an increase in accounts
receivable, if one then exists, has been impacted by an increase in the aging of our receivables
portfolio and/or changes in our revenue recognition policies. We would propose the following draft
disclosure pertaining to our 2010 financial statements: “The gross accounts receivable at the end
of fiscal year 2010 increased by 37% when compared with 2009. However, the DSO, when calculated
using net accounts receivable, increased by only 21%. In addition, our DSO is calculated using
average accounts receivable across the reporting period. That is, we
take the A/R amount at the
beginning of the year and the A/R amount at the end of the year and divide the sum of those two
amounts by 2. We believe that this approach makes most sense. As annual

Terence O’Brien

Division of Corporation Finance

U.S. Securities and Exchange Commission

October 26, 2011

Page 2

and fourth quarter sales increased by 30% and 6%. respectively, the DSO in 2010 actually
decreased from 2009 and the increase in accounts receivables is attributable to increased sales.
The aging of our accounts receivable portfolio remained comparable
with that of 2009 and there
were no changes with regard to revenue recognition policies.” For your reference, we attach a
spreadsheet which we believe may be helpful in conveying the Company’s determinations on this
point.

5. Duly noted and the Company wishes to confirm that it shall comply with this comment.

6. As the Staff is aware, the Company’s reporting currency is U.S. dollars. Each of the
Company’s operating subsidiaries generates revenues in the local currency of the jurisdiction
in which it operates and similarly incurs most of its expenditures in that local currency, and the
functional currency of each such subsidiary is its local currency. For consolidation purposes, the
Company translates the balance sheets of the subsidiaries using the prevailing exchange rates as
of balance sheet date as specified in ASC 830. Differences arising from the process of translating
each operating subsidiary’s balance sheet into U.S. dollars are included in a separate component
of equity. An exchange realignment arises as a result of the movement of the exchange rate for the
functional currency compared with U.S. dollars of each subsidiary and the carrying amount of
property, plant and equipment in the consolidated balance sheet
reported in U.S. dollars
incorporates such exchange realignment. In 2010, the Company recorded depreciation expense
amounting to $6,857, a net increase in accumulated depreciation based on exchange realignment
of $15,772 and disposal of property, plant and equipment with accumulated depreciation amounting to
$1,188 up to the date of disposal of each item. Accordingly, the increase in accumulated
depreciation during 2010 was $21,441, as reported on page F-4.

Purchases of property, plant and equipment amounted to $3,653 in 2010. The Company had a net
increase of $19,281 due to exchange realignment and disposed of property, plant and equipment
initially acquired for $1,232. In total, gross property, plant and equipment increased by
$21,702, as reported on page F-4.

With regard to our future filings, we note that material non-cash investments and
financing activities are required disclosures.

On behalf of the Company, I acknowledge that:

    •

    should the Commission or the Staff, acting pursuant to delegated authority, declare a filing
effective, it does not foreclose the Commission from taking any action with respect to the
filing;

Terence O’Brien

Division of Corporation Finance

U.S. Securities and Exchange Commission

 October 26, 2011

Page 3

    •

    the action of the Commission or the Staff, acting pursuant to delegated authority, in
declaring a filing effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in such filing; and

    •

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

Thank you for your attention to this matter.

Please do not hesitate to contact us if you have any further questions with regard to this matter.

Sincerely yours,

Frank Tseng

Chief Financial Officer

Asia Pacific Wire & Cable Corporation Limited

    cc:

    Mr. Alfred Pavot, Division of Corporate Finance, U.S. Securities and
Exchange Commission
Michael J. Hagan, Esq.

Annex
A DSO Data

1: Page 55 differs from page 48

2: To provide the calculation

    DSO

    2010

    2009

    Page 48

    95.8

    99.6

    used Net AR to calculate

    Page 55

    102

    109

    used Gross AR to calculate

Calculation:

    Days sales outstanding is calculated as:

    Average net accounts receivable

    x

    365 days

    Total credit sales (total sales)

    2010

    2009

    +/-

    %

    2009

    2008

    +/-

    %

    Gross accounts receivable

    151,340

    110,543

    40,797

    37
    %

    110,543

    105,545

    4,998

    5
    %

    Provision for doubtful accounts

    (6,886
    )

    (8,694
    )

    1,808

    (8,694
    )

    (9,644
    )

    950

    Net accounts receivable

    144,454

    101,849

    42,605

    101,849

    95,901

    5,948

    2010

    2009

    +/-

    %

    2009

    2008

    +/-

    %

    Net sales

    469,330

    362,231

    107,099

    30
    %

    362,231

    500,798

    (138,567
    )

    -28
    %

    Average net accounts receivable

    123,152

    98,875

    24,277

    25
    %

    Average gross accounts receivable

    130,942

    108,044

    22,898

    21
    %

    (opening + closing)/2

    DSO (based on net AR — page 48)

    95.8

    99.6

    DSO (based on gross AR — page 55)

    102

    109

Days Sales Outstanding — DSO

Days sales outstanding is calculated as:

October 20, 2011
Via E-mail
Frank Tseng, CFO Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan People’s Republic of China
Re: Asia Pacific Wire & Cable Corporation Limited
File No. 1-14542 Form 20-F for the Fiscal Ye ar Ended December 31, 2010
Filed May 13, 2011

Dear Mr. Tseng:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure. Please respond to this letter with in ten business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circ umstances, please tell us why in your response.
After reviewing the information you provide in  response to these comments, we may have
additional comments.
Operating results, page 45

1. In future filings, please quantify the impact th at (1) sales price variances, (2) sales volume
variances, and (3) foreign exchange rate varian ces had on reported sales increases and decreases.
This information should be provided for both your consolidated and segment (page F-44) sales
data. Your existing disclosure does not enable an i nvestor to fully understand the extent to which
your consolidated and segment sales were impacted  by these factors. See Section 501.04 of the
Financial Reporting Codification and Item  5.A of the Form 20-F instructions.
 Liquidity, page 54

2. Your disclosure states that the Registrant has no direct business operations. In future filings,
please provide the audited information prescribed by Article 12-04 of Regulation S-X and Item
17(a) of the Form 20-F instructions.

3. Please explain to us why the DSO data on page 55 differs from the corresponding data on page
48. Also, please provide us your calculation for th is measure. It is not clear how you determined
that your DSO decreased given that gross account s receivable increased 37% which is higher than
the annual and 4th quarter sales increases of 30% and 6%, respectively.

4. Given the material adverse impact that the r eceivables increase had on your operating cash flow,
please expand your disclosure in future filings  to state whether the receivables increase was

Mr. Frank Tseng, CFO
October 20, 2011 Page 2 of 2
 impacted by an increase in the aging of your recei vables portfolio and/or changes in your revenue
recognition policies. Please provide us with a dr aft disclosure pertaining to your 2010 financial
statements. See Section 501.04 of the Financial Reporting Codification.

Market Risks Related to Copper, page 83

5. In future filings, please quantify both the volum e and pricing terms of your forward pricing
contracts. Absent such disclosure, investors cannot fully understand the extent to which a material
change in copper commodity prices could impact  your loss exposure on these contracts. See Item
5.D and 11 of the Form 20-F instructions.
 Statements of Cash Flows, page F-8

6. Please provide us with a quantitative reconcilia tion between the $6,857 depreciation amount for
2010 and the $21,441 change in accumulated depreciation reflected on page F-4. Also, please
provide us with a quantitative reconciliation between the $3,653 purchases of property, plant and
equipment amount for 2010 and the $21,702 change in gross property, plant and equipment
reflected on page F-4. Regarding your future f ilings, note that material non-cash investing and
financing activities are required to be disclosed pursuant to ASC 230-10-50.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Al Pavot, St aff Accountant, at (202) 551- 3738 or me at (202) 551-3355
if you have any questions.
Sincerely,
   /s/ Terence O’Brien
Terence O’Brien Accounting Branch Chief

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ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

7/Fl. B, No. 132, Sec. 3

Min-Sheng East Road

Taipei, 105, Taiwan

Republic of China

August 31, 2011

By Email: (IngramJ@sec.gov), and U.S. Mail

By Edgar

Jay Ingram, Esq.

Legal Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable
Corporation Limited (the “Company”)

    File No. 333-153796

Dear Mr. Ingram:

This letter is in response to your letter of July 28, 2011 and subsequent telephone discussions
between a member of the staff at the Commission and our Company’s U.S. counsel at Thompson Hine
LLP.

The Division has inquired as to whether, during the period subsequent to April 1, 2011, any offers
or sales were made pursuant to the prospectus (the “Prospectus”) contained in the Registration
Statement, as amended by Post-Effective Amendment No. 6 to Form F-1 effective as of October 6,
2010, and as proposed to be amended further by Post-Effective Amendment No. 8 (“PEA No. 8”) to the
Form F-1 on Form F-3 registration statement filed with the Commission on or about the date hereof
(such registration statement as so amended is herein the “Registration Statement”).

The holders of the common shares that are registered securities covered by the Registration
Statement are Pacific Electric Wire & Cable Company Limited (“PEWC”) and MSD Credit Opportunity
Master Fund, L.P. (“COF”), as the assignee of SOF Investments, L.P. (“SOF”). I have inquired of,
and confirmed with, each of PEWC and COF (on behalf of itself and on behalf of SOF) that none of
those parties has made any offers or sales of common shares of the Company pursuant to the
Prospectus during the time period in question.

In addition, I have inquired of, and confirmed with, ComputerShare, the Company’s U.S. transfer
agent and Appleby Management (Bermuda) Ltd., the Company’s Bermuda resident secretary and Bermuda
transfer agent, that none of PEWC, COF or SOF has communicated to either transfer agent that it has
made, or offered to make, any sales of common shares of the Company during the time period in
question. The Company and its management acknowledge that they are
responsible for the accuracy and adequacy of all disclosures made in the Registration Statement and
each post-effective amendment thereto.

Jay Ingram, Esq.

Division of Corporation Finance

U.S. Securities and Exchange Commission

August 31, 2011

Page 2

Please note that COF obtained its shares by way of an assignment from SOF, its affiliate. SOF
initially acquired 2,766,154 common shares of the Company from Sino-JP Fund Co., Ltd. on June 28,
2007 in consideration for a purchase price of $11,756,154.50. On that same day, the Company
entered into a shareholders agreement with SOF and PEWC. On March 27, 2009, SOF sold 1,410,739
common shares, constituting 51% of the common shares held by it, to PEWC in consideration for a
purchase price of $6,557,149. On that same day, the Company entered into an Amended and Restated
Shareholders Agreement with PEWC and SOF. COF has executed a Shareholders Joinder to such Amended
and Restated Shareholders Agreement. The foregoing information is disclosed in PEA No. 8 in the
section captioned “Selling Shareholders”.

On behalf of the Company, I acknowledge that:

    •

    should the Commission or the staff, acting pursuant to delegated authority, declare a
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring a filing effective, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in such filing; and

    •

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

The undersigned wishes to confirm that the Company and its management are aware of their respective
responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they
relate to the proposed public offering of common shares of the Company specified in the
Registration Statement. The Company hereby wishes to respectfully request acceleration of the
effective date of PEA No. 8 and the Registration Statement as amended thereby. Specifically, the
Company requests that the Division declare PEA No. 8 and the Registration Statement as amended
thereby to be effective on the fourth business day following the date of the filing of PEA No. 8.
Thank you for your attention to this matter.

Jay Ingram, Esq.

Division of Corporation Finance

U.S. Securities and Exchange Commission

August 31, 2011

Page 3

Please do not hesitate to contact us if you have any further questions with regard to this matter.

Sincerely yours,

/s/ Frank Tseng

Frank Tseng

Chief Financial Officer

Asia Pacific Wire & Cable Corporation Limited

    cc:

    Jessica S. Kane, Esq.

    Michael Hagan, Esq.

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August 4, 2011

By Email: (IngramJ@sec.gov), and U.S. Mail

By Edgar

Jay Ingram, Esq.

Legal Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable Corporation Limited

Post-Effective Amendment No. 7 to Form-1 on Form F-3

Filed July 11, 2011

File No. 333-153796

Dear Mr. Ingram:

I am writing on behalf of Asia Pacific Wire & Cable Corporation Limited (the “Company”) in response
to your letter dated July 28, 2011, with respect to the above-referenced Post-Effective Amendment
No. 7 (“PEA No.7”) and the Company’s registration statement on Form F-1 to which it relates (such
registration statement as amended from time to time is herein referred to as the “Registration
Statement”).

The Division has inquired as to whether, during the period subsequent to April 1, 2011, any offers
or sales were made pursuant to the prospectus (the “Prospectus”) contained in the Registration
Statement, as amended most recently by Post-Effective Amendment No. 6 to Form F-1 effective as of
October 6, 2010.

The holders of the common shares that are registered securities covered by the Registration
Statement are Pacific Electric Wire & Cable Company Limited (“PEWC”) and MSD Credit Opportunity
Master Fund, L.P. (“COF”), as the assignee of SOF Investments, L.P. (“SOF”). We have inquired of,
and confirmed with, each of PEWC and COF (on behalf of itself and on behalf of SOF) that none of
those parties has made any offers or sales of common shares of the Company pursuant to the
Prospectus during the time period in question.

In addition, we have inquired of, and confirmed with, ComputerShare, the Company’s U.S. transfer
agent and Appleby Management (Bermuda) Ltd., the Company’s Bermuda resident secretary and Bermuda
transfer agent, that none of PEWC, COF or SOF has communicated to either transfer agent that it has
made, or offered to make, any sales of common shares of the Company during the time period in
question. The Company and its management acknowledge

Jay Ingram, Esq.

August 4, 2011

Page 2

that they are responsible for the accuracy and adequacy of all disclosures made in the Registration
Statement and each post-effective amendment thereto.

Please note that COF obtained its shares by way of an assignment from SOF, its affiliate. SOF
initially acquired 2,766,154 common shares of the Company from Sino-JP Fund Co., Ltd. on June 28,
2007 in consideration for a purchase price of $11,756,154.50. On that same day, the Company
entered into a shareholders agreement with SOF and PEWC. On March 27, 2009, SOF sold 1,410,739
common shares, constituting 51% of the common shares held by it, to PEWC in consideration for a
purchase price of $6,557,149. On that same day, the Company entered into an Amended and Restated
Shareholders Agreement with PEWC and SOF. COF has executed a Shareholders Joinder to such Amended
and Restated Shareholders Agreement. The foregoing information is disclosed in PEA No. 7 in the
section captioned “Selling Shareholders”.

On behalf of the Company, we acknowledge that:

    •

    should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

    •

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

    •

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

On behalf of the Company, we respectfully request acceleration of the effectiveness of PEA No.7 on
the earliest practicable date following the submission of this response. The Company and its
management wish to confirm they are aware of their respective responsibilities under the Securities
Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering
of the securities specified in the Company’s Registration Statement.

Please do not hesitate to contact the undersigned if you have any further questions with regard to
this matter.

Sincerely yours,

Michael J. Hagan

    cc:

    Jessica S. Kane, Esq.

Mr. Frank Tseng

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July 29, 2011

By Email: (IngramJ@sec.gov), and U.S. Mail

Jay Ingram, Esq.

Legal Branch Chief

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable Corporation Limited

Post-Effective Amendment No. 7 to Form-1 on Form F-3

Filed July 11, 2011

File No. 333-153796

Dear Mr. Ingram:

We are in receipt of the letter of the Division of Corporation Finance dated July 28, 2011 with
regard to Post-Effective Amendment No. 7 to Form-1 on Form F-3 of Asia Pacific Wire & Cable
Corporation Limited (the “Company”). In order to provide a definitive response to the question
raised in the letter of the Division, we are making inquiries, and confirming the records, of
several parties, including the holders of the common shares that are registered securities under
the registration statement to which the Post-Effective Amendment relates, and the U.S. transfer
agent and the Bermuda transfer agent and Corporate Secretary of APWC . In the case of the latter
parties, the responsible persons are out of their office until early next week. Accordingly, we
propose to provide to the Division a definitive response as soon as possible after we have had an
opportunity to communicate with those latter parties.

Of course, please contact me if you have any further questions with regard to this matter.

Sincerely yours,

     /s/ Michael J. Hagan

Michael J. Hagan

    cc:

    Jessica S. Kane, Esq.

Mr. Frank Tseng

    Michael.Hagan@ThompsonHine.com  Phone 212.908.3916  Fax 212.344.6101

    206247

July 28, 2011
 Via E-mail

Frank Tseng Chief Financial Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan Republic of China
Re: Asia Pacific Wire & Cable Corporation Limited
  Post-Effective Amendment No. 7 to Form-1 on Form F-3
Filed July 11, 2011
  File No. 333-153796

Dear Mr. Tang:
 We have limited our review of your registra tion statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not beli eve our comments apply 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. We note that Post-Effective Amendment No. 6 to the Form F-1 went effective on October
6, 2010 and contained audited financial statements as of December 31, 2009.  Pursuant to Item 8.A of Form 20-F, the last year of aud ited financial statements may not be older than
15 months at the time of the offering.  Accordingly, it appears you were required to
update the audited financial statements for this offering by April 1, 2011.  Please advise
us as to whether any offers or sales were  made pursuant to the prospectus during the
period in which the financial statements were not current.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in

Frank Tseng  Asia Pacific Wire & Cable Corporation Limited July 28, 2011 Page 2

 possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.
 You may contact Jessica Kane  at (202) 551-3235 or me at (202) 551-3397 with any
questions.
Sincerely,
   /s/ Jay Ingram
Jay Ingram Legal Branch Chief
 cc: Michael J. Hagan, Esq. (Via E-mail)  Thompson Hine LLP   335 Madison Avenue, Floor 12  New York, NY 10017

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ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

7/Fl. B, No. 132, Sec. 3

Min-Sheng East Road

Taipei, 105, Taiwan

Republic of China

July 23, 2009

VIA FACSIMILE AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Jessica Kane

    Re:

    Asia Pacific Wire & Cable Corporation Limited

    Post-Effective Amendment No. 3 to Form F-1, Filed on July 7, 2009

    (File No. 333-153796)

    Request for Acceleration

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned
registrant, Asia Pacific Wire & Cable Corporation Limited (the “Registrant”), hereby confirms its
request that the above-referenced Registration Statement be declared effective as of 5:30 p.m.
(EDT), on July 23, 2009, or as soon as practicable thereafter.

The Registrant hereby 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
Registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

    (iii)

    the Registrant may not assert the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement
effective as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

    Very truly yours,

ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

    By:

/s/ Samuel
See

    Samuel See

    Interim Chief Financial Officer

2

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CORRESP

    1290 AVENUE OF THE AMERICAS

NEW YORK, NY 10104-0050

TELEPHONE: 212.468.8000

FACSIMILE: 212.468.7900

WWW.MOFO.COM

    morrison & foerster llp

new york, san francisco,

los angeles, palo alto,

san diego, washington, d.c.

northern virginia, denver,

sacramento, walnut creek

tokyo, london, beijing,

shanghai, hong kong,

singapore, brussels

    May 28, 2009

    Writer’s Direct Contact

    212.468.8025

    mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.

Legal Branch Chief

United States Securities and Exchange Commission

Mail Stop 7010

Washington, D.C. 20549-7010

    Re:

    Asia Pacific Wire & Cable Corporation Limited

    Post Effective Amendment No. 2 to

    Registration Statement on Form F-1

    Filed on May 13, 2009

    File No. 333-153796

Dear Mr. Ingram:

Thank you for your letter dated May 27, 2009. We note your comment regarding the currency of the
audited financial statements of the company included in its Registration Statement on Form F-1 and
the company is diligently addressing that point and we will provide a definitive response in the
near future.

To the best of my knowledge, there have been no offers or sales pursuant to the prospectus since
the effective date of the company’s Registration Statement on Form F-1 by the two holders of common
shares covered by the prospectus. I am seeking to confirm that point and will provide a definitive
response as soon as possible.

Please feel free to contact me if you wish to discuss any of the foregoing.

Very truly yours,

Michael J. Hagan

    cc:

    Mr. Yuan Chun Tang

    Jessica Kane, Esq.

    1290 AVENUE OF THE AMERICAS

NEW YORK, NY 10104-0050

TELEPHONE: 212.468.8000

FACSIMILE: 212.468.7900

WWW.MOFO.COM

    morrison & foerster llp

new york, san francisco,

los angeles, palo alto,

san diego, washington, d.c.

northern virginia, denver,

sacramento, walnut creek

tokyo, london, beijing,

shanghai, hong kong,

singapore, brussels

    July 7, 2009

    Writer’s Direct Contact

    212.468.8025

    mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.

Legal Branch Chief

United States Securities and Exchange Commission

100 F Street, N.E., Mail Stop 7010

Washington, D.C. 20549

    Re:

    Asia Pacific Wire & Cable Corporation Limited (the “Company”)

    Post Effective Amendment No. 2 to

    Registration Statement on Form F-1

    Filed on May 13, 2009

    File No. 333-153796

Dear Mr. Ingram:

As a follow-up to my letter to you dated May 28, 2009, in response to your letter dated May 27,
2009, I wish to inform you that the Company filed today with the Securities and
Exchange Commission (the “Commission”) Post-Effective Amendment No. 3 to the Company’s Registration
Statement on Form F-1 (the “Registration Statement”), which incorporates by reference the audited
financial statements included in the Company’s Form 20-F/A for the fiscal year ended December 31,
2008 filed with the Commission on July 6, 2009.

Furthermore, I wish to inform the Commission that the holders of securities registered under the
Registration Statement have confirmed to me that neither of them has made any offers to sell or
solicited any offers to purchase common shares pursuant to, or in reliance on, the prospectus that
forms part of the Registration Statement since the effective date of the Registration Statement.

Mr. Jay Ingram

July 7, 2009

Page Two

Please feel free to contact me if you wish to discuss any of the foregoing.

Very truly yours,

Michael J. Hagan

    cc:

    Mr. Yuan Chun Tang

    Jessica Kane, Esq.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      May 27, 2009  Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
Post-Effective Amendment No. 2 to
Registration Statement on Form F-1
Filed on May 13, 2009 File No. 333-153796

Dear Mr. Tang:
 We have reviewed your filing and have  the following comments.  We welcome
any questions you may have about our comments or any other aspect of  our review.  Feel
free to call us at the telephone numbers  listed at the end of this letter.

General

1. We note that you have included unaudited financial statements through the six
month period ending June 30, 2008.  Howe ver, it appears that your financial
statements are no longer current.  Please  amend your filing to include updated
audited financial statements.  See  Item 8A to Form 20-F.
 2. Please advise us as to whether any offe rs or sales were made pursuant to the
prospectus during the period in which the financial statements were not current.

*    *    *    *
You may contact Jessica Kane , Staff Attorney, at (202)  551-3235 or me at (202)
551-3397 with any questions.
Sincerely,    Jay Ingram Legal Branch Chief

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  May 27, 2009 Page 2
cc: Michael J. Hagan, Esq.  Morrison & Foerster LLP  1290 Avenue of the Americas  New York, NY  10104

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      April 23, 2009  Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
Post-Effective Amendment No. 1 to
Registration Statement on Form F-1
Filed on April 2, 2009 File No. 333-153796

Dear Mr. Tang:
 We have limited our review  of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Signatures, page II-4

1. We note that Mr. Yuan Chun Tang signed the post-effective amendment on behalf
of those persons who duly executed the power  of attorney filed as part of the
Form F-1, which was filed with the Securities and Exchange Commission on
October 2, 2008.  As this post-effective amendment is considered a separate
registration statement, pl ease arrange to have the post-effective amendment
signed by the registrant, the principal ex ecutive officer, the principal financial
officer, the controller or pr incipal accounting officer, and at  least a majority of the
board of directors.  See  Instructions Nos. 1 and 2 to the Signature Section of Form
F-1 and Item 601 of Regulation S-K.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  April 23, 2009 Page 2
As appropriate, please amend your filing in response to these comments.  You
may wish to provide us with marked copies of the amendment to e xpedite our review.
Please furnish a cover letter with your amendment that ke ys your responses to our
comments and provides any requested inform ation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.      Before the amended registration statem ent is declared effective pursuant to
Section 8 of the Securities Act, the co mpany should provide us with a letter,
acknowledging that:   ‚ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;
 ‚ the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and
 ‚ the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
You may contact Jessica Kane , Staff Attorney, at (202)  551-3235 or me at (202)
551-3397 with any questions.
 Sincerely,    Jay Ingram Legal Branch Chief

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  April 23, 2009 Page 3
cc: Michael J. Hagan, Esq.  Morrison & Foerster LLP  1290 Avenue of the Americas  New York, NY  10104

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ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

7/Fl. B, No. 132, Sec. 3

Min-Sheng East Road

Taipei, 105, Taiwan

Republic of China

March 11, 2009

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mr. Terence O’Brien; Ms. Melissa Rocha; Ms.
Pam Long

          Re:

    Asia Pacific Wire & Cable Corporation Limited

Amendment No. 5 to Form F-1, Filed on March 11, 2009

(File No. 333-153796)

Request for Acceleration

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned
registrant, Asia Pacific Wire & Cable Corporation Limited (the “Registrant”), hereby requests that
the above-referenced Registration Statement be declared effective at 5:30 p.m. (EDT), on March 11,
2009, or as soon as practicable thereafter.

The Registrant hereby 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
Registrant from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

    (iii)

    the Registrant may not assert the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the Registration Statement
effective as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

    Very truly yours,

ASIA PACIFIC WIRE & CABLE CORPORATION LIMITED

    By:
    /s/ Yuan Chun Tang

    Yuan Chun Tang

    Chairman and Chief Executive Officer

2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      February 4, 2009  Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
  Registration Statement on Form F-1
Amendment #3 filed on January 22, 2009 File No. 333-153796  Form 20-F for the Fiscal Year Ended December 31, 2007 Filed on June 27, 2008 File No. 001-14542
 Dear Mr. Tang:
We have reviewed your filings and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
Form F-1

Risk Factors

Actual and Possible Impacts on the Company, page 5

1. The proposed future disclosure provided in response to prior comment 1 is general in nature and does not provid e detailed information on your business to
enable investors to see the company through the eyes of management.  For
example, the statement, “During the s econd half of 2008, the Company began to
experience the impact of the economic cr isis, which included lower sales and
lower gross margins…” does not provide an  investor with sufficient information
to understand the specific impact of recen t economic events.  The statement, “the
Company is presently anticipating that  the extremely challenging and difficult

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  February 4, 2009 Page 2
economic conditions now facing the global economy will continue at least through the first half  of 2009,” does not address th e effects of the current
economic crisis or provide detailed information about the current or anticipated impact on your customers, products, order levels, trends or expectations of
management.  The statement, “The Co mpany’s management has taken certain
steps in response to these events such as increasing its efforts to lower the days sales outstanding of its receivables ” is limited and does not provide an
understanding of management’s  considerations or plans to address these issues on
all aspects of operations and liquidity.  Please expand this disclosure.  As
discussed in SEC Release 33-8350, quantifica tion of the material effects of known
material trends and uncertainties can promote understanding. Quantitative
disclosure should be considered and may be  required to the extent material if
quantitative information is reasonably available.

 You may contact Melissa Ro cha, Staff Accountant, at  (202) 551-3692 or me at
(202) 551-3355 if you have questions regard ing comments on the financial statements
and related matters.

Sincerely,

 Terence O’Brien  Accounting Branch Chief

cc: Michael J. Hagan, Esq.  Morrison & Foerster LLP  1290 Avenue of the Americas  New York, New York  10104

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      January 8, 2009

Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
  Amendment No. 2 to Form F-1
Filed December 24, 2008 File No. 333-153796

  Form 20-F for the year ended December 31, 2007
  Filed June 27, 2008   File No. 001-14542
Dear Mr. Tang:

We have reviewed your filings and have the following comments.  We welcome
any questions you may have about our comments or any other aspect of  our review.  Feel
free to call us at the telephone numbers  listed at the end of this letter.

Form F-1

Operating and Financial Revi ew and Prospects, page 41
 1. We note the discussion of current econ omic risks on page 16, as well as the
 discussion on page 60.  Please revise to  include a prominent discussion providing
 investors with a detailed understanding of how the economic events are affecting
 your business.  This discussion should quantify the known impact on your  operations, financial position and liquid ity in the period since June 30, 2008, as
 well as address management’s expectat ions for the future in more detail.

Disclosures of Critical Accounting Policies, page 41

2. We note your response to prior comment 18 and your revised disclosure where
 you have added a policy note for impairme nt of long lived assets.  Clarify in
 future filings whether or not an impa irment test was actually performed on your
 long lived assets under SFAS 144 at Decem ber 31, 2007.  Your current disclosure
 only discloses that you did not record any impairment on your assets.  Please

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  January 8, 2009
Page 2   disclose the results of those tests and a ssumptions used, to the extent a test was
 performed, and if no test was performe d how you considered that one was not
 necessary under paragraph 8 of SFAS 144.  Note for future periods, disclosing
 whether or not a SFAS 144 analysis was actually performed w ould clearly inform
 investors whether the absence of impair ment charges is due to management’s
 determination that the SFAS 144 test were not required as a result of no triggering
 events or because there were triggering events present and managements estimate  of cash flow projections exceeded asset carrying values resulting in no
 impairment charges.  Related Party Transactions, page 67

 3. We note your revised disclosure on page  68 in response to prior comment 10.
 Please explain what “secondment” mean s and clarify what the managers do.
   Form 20-F for the Year Ending December 31, 2007

 Note 20. Segment Financial Information, page F-41

 4. We note your response to prior comment 20 and the CODM reports that you have
 provided under separate cover.  Your response states that you have defined your
 operating and reporting segments based on the structure of your internal  organization.  You state that this st ructure is a “geographic, market-driven
 enterprise” structure.  This geographic mark et driven enterprise is not apparent in
 the CODM reports provided.  In this regard, it appears as  if you have eight
 operating segments that are represented by certain subsidiaries or business units,
 such as Sigma Cable, Sigma Epan, and Au stralia Pacific Electric Cable, etc.
 Further, it is unclear how you have take n these reports that  are broken down by
 subsidiary/business unit and aggregated  them into three reportable segments;
 manufactured products, di stributed products and SDI,  as these reports do not
 include discreet financial informati on for these three reportable segments.
  Based on your CODM reports, it is no t clear to us that these units are
 economically similar such that aggregati on of these units pursuant to paragraph
 17 of SFAS 131 is appropriate.  Gros s margins among the eight units appear
 materially different.  For example,  Shanghai Yayang Electric margins are
 approximately 3% when Sigma Epan ar e approximately 17%.  Please provide us
 an analysis that includes explanati ons for these differences in economic
 characteristics, including differences in trends, and te ll us why these differences
 would not be considered an indication of  differences in economic characteristics.
 Additionally tell how these reports link to the segment reporting provided in your
 periodic reports.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  January 8, 2009 Page 3
As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
You may contact Melissa Ro cha, Staff Accountant, at  (202) 551-3692 or Terrence
O’Brien, Accounting Branch Chief, at (202)  551-3355 if you have questions regarding
comments on the financial statements and related matters.  Please contact me at (202) 551-3767 with any other questions.
Sincerely,    Jennifer Hardy  Branch Chief

cc: Michael J. Hagan, Esq.
 Morrison & Foerster LLP

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      December 15, 2008
  Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
  Amendment No. 1 to Form F-1
Filed November 26, 2008
File No. 333-153796

  Form 20-F for the year ended December 31, 2007
  Filed June 27, 2008   File No. 001-14542
Dear Mr. Tang:

We have reviewed your filings and have the following comments.  We welcome
any questions you may have about our comments or any other aspect of  our review.  Feel
free to call us at the telephone numbers  listed at the end of this letter.

Form F-1

 General

 1. Briefly describe the nature of the cr iminal proceedings against former PEWC
 officers and directors and describe the malfeasance that led to the delisting from  the Taipei Stock Exchange.
Summary, page 1

2. Please provide an organizational chart in the summary which includes your
 joint venture ownerships.
Risk Factors, page 5

3. Please include a risk factor about your default on the PEWC loan.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  December 15, 2008
Page 2  Certain Historical Information Regarding Own ership and Control of the Company, page
24
 4. Please clarify who Set Top International is  and briefly describe  what the litigation
 between them and PEWC related to.   5. Please describe how the Option Agreement came about and disclose its purpose.
 6. Please explain carried interest and clarif y whether PEWC is still paying it.  Clarify
 whether the purchase price was funded w ith debt by Sino JP.  Disclose why the
 transaction was structured to include carri ed interest and how it is accounted for by
 each of the parties.    5.4 -  Liquidity and Capital Resources, page 47

7. We note your response to prior comment 32 and your revised disclosure.  Your
 discussion of the cash flow statement a nd the factors that drive cash flows does
 not provide information for the period  ending June 30, 2008.  Please revise to
 provide a balanced discussion of the factor s that drive cash flow s, explanations of
 the reason for increases and decreases in  your cash flows including the reasons for
 the changes in operating assets and liabilities for the most recent period.
 Additionally, ensure that your discussi on for the interim period discusses the
 significant impact accounts receivable s and inventory had on operating cash
 flows.  Refer to FRR No. 72-501.13.

Related Party Transactions, page 66

8. Please disclose the interest rate and ma turity of the short-term loan from Moon
 View.  9. Please disclose the use of proceeds for each of the related party loans.
 10. Please provide disclosure here about the management fee payable to PEWC and  disclose what the management fee is for.  11. In the last paragraph, pleas e state that the financial st atements you are incorporating
 are in your Form 20-F.  In your cross-re ference to footnote 1 7, please reference your
 copper purchases from PEWC   Plan of Distribution, page 69

 12. We reference the second paragraph.  Please tell us why you would not file a
 prospectus supplement until a pledgee or donee intends to sell more than 500 shares.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  December 15, 2008
Page 3  Selling Shareholder, page 71

 13. We note your response to prior comment 40 and the revised disclosure that SOF may
be  deemed to be an underwriter.  We restate the comment.  Please tell us whether SOF  is a registered broker.  If so, please state that they “are” a nd underwriter.  Please tell
 us whether SOF is an affiliate of a broker-dealer.  If so, please also disclose the  representations set forth in the letter  or state they “are” an underwriter.

Legal Matters, page 189

14. Please clarify which matters Morrison & Foerster and Appleby will pass on.
 Legal Opinion-Exhibit 5.1

 15. Please delete the assumption in (i) since this reflects whether the shares are duly
 authorized.  16. We reference the next to last paragraph wh ich states that the opinion speaks as of
 its date.  Please note that shareholders must be able to rely upon the opinion up to
 the time that the F-1 becomes effective.  Please either delete this statement or file  an executed copy of the opinion dated as of the date of effectiveness.

Form 20-F for the Year Ended December 31, 2007

 3.3.6 Disclosure Controls and Procedures and In ternal Controls Over  Financial Reporting
Classified as Ineffective, page 9
 17. We note your response to prior comment 49 which references your risk factor
 disclosure in your Form F-1/A.  Your disclosure in your Form 20-F which is  incorporated by reference into you r Form F-1/A does not provide this
 information.  Therefore, as previously requested, please revise to disclose in
 greater detail the nature of the four material we aknesses identified in your
 disclosure.  In this regard, also revise  to disclose the specific steps that the
 Company implemented at its June 1 3, 2008 Board meeting to remediate the
 material weaknesses.

Item 5.1 Disclosures of Critical Accounting Policies, page 34

18. We note that your stock price has con tinued to decline from $5.20 at December
 31, 2007, to $1.00 at December 5, 2008, and your market capitalization as of June
 30, 2008, is significantly less th an total stockholders’ equit y, which is an indicator
 that your goodwill and/or long-lived assets may be impaired.  Tell us whether or  not this decline in market cap and stock price has triggered an interim impairment
 test under SFAS 142 and SFAS 144 and how you determined that your long-lived
 assets and goodwill are recoverable in the current market environment.  Further

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  December 15, 2008
Page 4   tell us how the decline in your stock pr ice has impacted your current and future
 cash flows and what consideration you have given to disclosing this in your Form
 F-1.

Note 4. Summary of Significant Accounting Policies

Note 18. Defined Contribution a nd Benefit Plans, page F-38

19. We note your response to prior comment 59 where you have identified for us the
 disclosures required by paragraphs 7 a nd 20 of SFAS 158 in your Form 20-F.
 Please revise your footnote disclosure, in future filings, to clearly identify these
 disclosures as you have in your response.  Further note that Appendix A,  specifically paragraph A6, provides an illu stration of the disc losures required by
 paragraph 20 of SFAS 158.

Note 20. Segment Financial Information, page F-41

20. We note your response to prior comment 60 and have the following comments:
ƒ You state that you have a number of operating subsidiaries, you capture
certain financial information by produc t line, and the Company’s supervisory
personnel act and make decisions on a region al and market basis.  It is still not
clear to us, how you have identified your operating segm ents and reporting
segments.  In this regard, tell us if your various operating subsidiaries are
considered operating segments and if s o, are they aggregated into your three
reportable segments?
ƒ It is unclear how your CODM evaluate s and assesses performance.  Please
clarify whether decisions are made on a regi onal and market basis.  If so, tell
us how you considered this in determining your operating and reportable segments.  Supplmentally provide us  copies of your CODM reports for
December 31, 2007 and June 30, 2008.
ƒ Explain to us why certain key operational data and certain financial information specific to each product line, in your manufactured product
segment, is captured if it is not used internally for decision making on how resources should be allocated.

General:

21. We note throughout your response letter and your Form F-1/A that you have
 made certain revisions as a result of our comments that you indicate, in some
 instances, you will also make in your 2008 Form 20-F.  Since your Form 20-F is
 incorporated by reference in your Form F-1/A and includes information that has
 not been revised as a result of our comme nts, please tell us what consideration has
 been given to revising your Form 20 -F for the year ended December 31, 2007.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  December 15, 2008 Page 5

Current Economic Risks, page 16

 22. Please expand this discussion of recent economic events to clarify the specific
 impacts and risks to your business.  E xplain how the market for your products has
 been affected and the current and ex pected future impact on your operations,
 financial position and liquidity.  Th is disclosure should provide detailed
 information on your operations since June 30, your customers, recent order
 activity, expected trends, management ’s response for managing these events,
 potential future actions by management  and other detailed information.  Expand
 your liquidity discussion to address the e xpected impact to current and future cash
 flows and how you expect recent economic  events, including the credit shortage,
 may affect other sources of liquidity.

     *    *     *     *

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
You may contact Melissa Ro cha, Staff Accountant, at  (202) 551-3692 or Terrence
O’Brien, Accounting Branch Chief, at (202)  551-3355 if you have questions regarding
comments on the financial statements and rela ted matters.  Please contact Jessica Kane,
Staff Attorney, at (202) 551-3235 or me at  (202) 551-3767 with any other questions.

Sincerely,    Jennifer Hardy  Branch Chief

cc: Michael J. Hagan, Esq.  Morrison & Foerster LLP

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010      October 29, 2008  Yuan Chun Tang Chief Executive Officer Asia Pacific Wire & Cable Corporation Limited 7/Fl. B, No. 132, Sec. 3 Min-Sheng East Road Taipei, 105, Taiwan  People’s Republic of China
 Re: Asia Pacific Wire & Cable Corporation Limited
  Registration Statement on Form F-1
Filed on October 2, 2008 File No. 333-153796  Form 20-F for the Fiscal Year Ended December 31, 2007 Filed on June 27, 2008 File No. 001-14542
 Dear Mr. Tang:
We have reviewed your filings and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form F-1

General

1. We note that you have yet to file a lega lity opinion.  Please file as soon as
possible and please note that we may have further comments upon our review.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  October 29, 2008
Page 2
2. Please revise to file a consent from y our independent registered accounting firm
as required by Item 601 of Regulation S-K.

Risk Factors, page 4

3. On page 55, we note that you intend to appl y for listing on either Nasdaq or the
AMEX in 2008.  If you intend to rely on Nasdaq Rule 4350(a) or AMEX
Company Guide Section 110, which permits a foreign private issuer to follow its
home country requirements to some ex tent concerning corporate governance
issues, including whether a majority of its  board of directors must be independent,
then provide a risk factor that discloses this reliance, describes the corporate governance matters affected, and disc loses whether applicable Bermuda
requirements provide less protection than  those required under Nasdaq or AMEX
rules.
 4. Please add a risk factor that discloses whether an investor would find it difficult:
• to effect service of process in the United States against you or your non-U.S.
officers, directors and experts na med in the registration statement;
• to enforce U.S. court judgments based upon the civil liability provisions of the
U.S. federal securities laws in a U.S., Bermuda, or Taiwan court against you and the above-described persons; and
• to bring an original action in a U.S., Bermuda or Taiwan court to enforce liabilities based upon the U.S. federal securities laws against you and the
above-described persons.
 Then provide comparable disclosure in the “Enforceability of Certain Liabilities”
section of the registration statement.  See
 Item 101(g) of Regulation S-K.

Disclosure controls and procedures and in ternal controls over financial reporting
classified as ineffective, page 5

5. In this risk factor, please briefly disclose  the four material weaknesses and certain
significant deficiencies in your internal controls over financia l reporting as of
December 31, 2007.  At an appropriate sec tion of the prospectus, please discuss
the remediation efforts.  We note your di sclosure on page 72 of your latest Form
20-F.

Delinquency in Reporting Obligations; Re porting of Financial Results, page 5

6. You have stated that th e company filed its 2008 annua l report on a timely basis
when it appears that the company file d its Form 20-F for the year ended
December 31, 2007.  Revise accordingly.

7. You have stated that, becau se the company is a forei gn private issuer, it is not
required to provide financial statements  on a quarterly or semi-annual basis.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  October 29, 2008
Page 3
Clarify whether the company is required  to provide quarterly or semi-annual
financial statements under Bermuda law.

Potential Conflict of Certain O fficers and Directors, page 6

8. We note that all but two directors are aff iliated with PEWC and that PEWC is the
majority shareholder.  Please expand this risk factor to furt her discuss how the
conflicts of interest for the PEWC-affiliated officers and directors will impact the
public shareholders of Asia Pacific.  Please also disc uss PEWC’s status as the
majority shareholder.

Risks Relating to China, page 8

9. Because this risk factor is too long a nd bundles together several discrete risks
under a general heading, it is c onfusing for investors.  Disc lose each material risk
under a separate heading that accurately id entifies the risk discussed (for example,
the risk posed by the Chinese civil law system or the risk concerning the PRC
government’s controls on the convertibility of the Renminbi into foreign
currencies).
 10. On page 10, please clarify whether you qua lify for the tax incen tives provided to
high-tech enterprises under the r ecently enacted PRC Measures.

11. If material, discuss the risk posed  by the PRC government providing less
protection to a company’s in tellectual property than th at provided in the United
States or Bermuda.
 International Business Risks, page 12

12. Clarify whether you expect the current gl obal financial and economic crisis to
affect adversely your results of operations or financial condition.

Interim Financial Data, page 15

13. Please revise to include your interim fi nancial statements for the period ending
June 30, 2008 in accordance with the Item 8 requirement of Form 20-F.

Information on the Company, page 19

History and Development of  the Business, page 19

14. In the third paragraph, we note your statem ent that “the company is one of the
five largest producers of telecommunicat ions and low voltage power cable and
enameled wire in Thailand.”  Please disclose the basis for this assertion and the measure by which you are the largest.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  October 29, 2008
Page 4  Certain Historical Information Regarding Own ership and Control of the Company, page
20

15. Please make it clear what restrictions or ob ligations currently exist with respect to
the company shares held by PEWC.  Also, it is not clear at the top of page 21 what effect the agreement extended through 2009 has on the PEWC shares currently.

16. In the third paragraph on page 20, pleas e explain what the “guaranteed returns
payable” was.

17. Please clarify who APCW is.

18. In the second paragraph on page 21, please clarify specifically what the disputes
relating to the company’s govern ance and other matters were.

Competition, page 30

19. Please disclose the bases for the following assertions regarding your competitive position and the measure by the company is the largest:
• For Thailand, “Siam Pacific and Charoong Thai are two of the five largest
wire and cable producers in Thailand.”
• For Singapore, “The company believes it is the largest manufacturer of low
voltage power cable in Singapore” on page 30 and “The company believes that Sigma Cable is the largest producer  of low voltage power cable products
in Singapore” on page 34.
• For China, “PEWS is one of the larges t enameled wire manufacturers amongst
the six manufacturers in Shenzhen” on  page 30 and “SPFC is one of the
largest manufacturers of fiber optic cables in Shandong Province” on page 31.

Operating and Financial Revi ew and Prospects, page 36

Disclosures of Critical Accounting Policies, page 36

20. Considering the decline in your stock price and market capitalization over the past
six months, your current critical accounting policy for goodwill, particularly your disclosure of assessing the recoverability of goodwill, appears to be too general in
nature to provide an investor with su fficient information about management’s
insights and assumptions with regard to the recoverability of this asset balance.
Please expand your disclosures to describe  the steps that you perform to review
your goodwill for recoverabilit y, the assumptions used, and provide information
as to known trends, uncertainties or other factors that will re sult in, or that are
reasonably likely to result in, any material  impairment charges in future periods.
For example, your policy note should quantif y the projected cash flows used in
your analysis, the growth rate used in projecting cash flows, quantify the discount

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  October 29, 2008
Page 5
rate, include terminal value assumptions, and discuss how you assessed your reporting units under paragraph 30 and 31 of SFAS 142.  Given the current
economic conditions and the impact it ha s had on your stock price and operations,
this detailed information will provide the reader with a greater insight into the
quality and variability of your financial po sition and operating results.  Refer to
Release No. 33- 8350 “Interpretatio n: Commission Guidance Regarding
Management's Discussion and Analysis of Financial Conditio n and Results of
Operations.”
 Operating Results, page 42

21. Your discussion of results of operations addresses multiple factors contributing to year over year changes in line items; however, your discussion should quantify
each of the factors.  For example, you disclo se gross profit decreas ed as a result of
decreased margins in the enameled wire products and teleco mmunications cable
in Thailand, offset by an increase in pr ofit margins for power cable products.
However, your disclosure does not quantif y the impact.  Refer to FRR No. 36 –
501.04.
 22. With regard to the gain on the sale of investment in 2007 that was attributable to
the sale of warrants held by a subsidiary, pl ease revise to disclose the nature of
this transaction, how you are accounti ng for the transaction and why the
recognition of a gain is appropriate.  Cite the authoritative literature that supports
your accounting.

23. Please provide information regarding governmental economic, fiscal, monetary, or political policies or fact ors that have affected or could materially affect the
company’s operations or investment s by host country shareholders.  See
 Part I,
Item 5(A)(4) of Form 20-F.

Liquidity and Capital Resources, page 47

24. Please briefly disclose the reason for th e difference in net cash generated from
operating activities from 2006 to 2007.

25. Please evaluate the sources and amounts of cash flow, including the nature and
extent of any legal or economic restrict ions on the ability of subsidiaries to
transfer funds to you in the form of cash dividends, loans, or advances and the
impact such restrictions have had or are expected to have on your ability to meet
your cash obligations.  See Part I, Item 5(B) of Form  20-F.  On page 7, we note
that you have no direct business operati ons other than your ownership of the
capital stock of your subsidiaries and jo int venture holdings and that there are
restrictions on the ability of some of your  subsidiaries to pay you dividends.

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  October 29, 2008
Page 6
26. Please expand your liquidity section to discuss your credit arrangements and
borrowings in more detail.  See
 Part I, Item 5(B)(1)(b) of Form 20-F.

27. We note your statement on page 74 that “the company requires a significant
amount of U.S. dollars for its ongoin g equipment upgrade and maintenance
programs.”  To the extent applicable, please discuss these capital expenditures in accordance with Item 5(B)(3 ) of Form 20-F.

28. Include your interest commitments under your interest-bearing debt in your
contractual obligation tabl e on page 46, or provide textual discussion of this
obligation below the table.  If you provi de a textual discussion, the discussion
should quantify the interest payments using the same time frames stipulated in the
table.  Refer to footnote 46 to Rel ease 33-8350 “Interpretation:  Commission
Guidance Regarding Management’s Disc ussion and Analysis of Financial
Condition and Results of Operations.”

29. We note your Composite Services Agr eement with PEWC which contains
provisions that define the relations hip and the conduct of the respective
businesses of the Company and PEWC, incl uding purchases of raw materials.
Please revise your liquidity section to discuss this agreement, including any
obligations due to or from PEWC that has impacted or you anticipate will impact
cash flows, liquidity and operations.

30. We note that during the year ended December 31, 2007, you had a significant change in your accounts receivable balan ce.  Given the impact that receivables
have on your liquidity, pleas e revise your MD&A to e xplain the reasons for the
increases and any variances in the corre sponding turnover ratios.   Additionally,
we note that you have incurred $3.3 million in bad debt charges as well as significant write offs during 2007 and that the provision largely related to a major
telecommunication subcontractor company.  Please ensure your revised disclosure
discusses this charge, the related acco unts, whether or not you have any other
accounts that are delinquent and would requ ire a bad debt allowance and how the
bad debt provision impacted  or will impact liquidity.

31. You disclose that cash provided by your operating activities will be sufficient to
meet your anticipated working capital, capital expenditures a nd short term and
long term obligations.  With regards to the $71 million in purchase obligations for
copper, please tell us and disclose how you plan to meet this obligation with your
current rate of cash flows from operations.  To the extent your operating cash will not cover this obligation, please disclose  the source of funds you plan to use to
meet the obligation.

32. Your liquidity discussion largely reiterates  what is presented in the statement of
cash flows with little explanation of the reason for increases and decreases.  Please revise your discussion to address the reasons for the changes in operating

Yuan Chun Tang
Asia Pacific Wire & Cable Corporation Limited  October 29, 2008
Page 7
assets and liabilities.  For example, as noted above your change in receivables has
had a material impact on your operating cash flows.  Please disclose your DSO for each period and explain any variances.  Revise to provide expanded disclosure
which will indicate the compa ny’s ability to adjust its future cash flows to meet
needs and opportunities, both expected and unexpected.  Refer to FRR 501.03 and
SEC Release 33-8350.

Trend Information, page 48

33. If material, please discuss the impact the on-going global credit crisis and
economic downturn on your net sales, income from continuing operations, profitability, liquidity, or capital resources.  See
 Part I, Item 5(D) of Form 20-F.
 Directors, Senior Management and Employees, page 49

34. Please revise this section to address the following issues:
• Please provide expanded disclosure re garding the background, including the
business experience, of your named directors and officers.  See Part I, Item
6(A) of Form 20-F.
• In the director and executive officer chart and in Yuan Chun Tang’s biography, please disclose that he  is the Chief Executive Officer.
• Please include Daphne Hsu, your Controll er, in the director and executive
officer chart and provide a biography.  It appears that sh e is a member of
senior management.  See  General Instruction F to Form 20-F.
• Please include biographies for Andy C.C. Cheng