SecProbe.io

<DOCUMENT>
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<FILENAME>filename2.txt
<TEXT>
 March 31, 2025

Li Peng Leck
Executive Chairwoman
Davis Commodities Limited
10 Bukit Batok Crescent, #10-01, The Spire
Singapore 658079

 Re: Davis Commodities Limited
 Registration Statement on Form F-3
 Filed March 24, 2025
 File No. 333-286042
Dear Li Peng Leck:

 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 Rebekah Reed at 202-551-5332 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Clement Au
</TEXT>
</DOCUMENT>

CORRESP
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 Davis Commodities Limited

 March 31, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC 20549

 Re:
 Davis Commodities Limited

 Registration Statement on Form F-3 (File No. 333-286042)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended, Davis Commodities Limited hereby requests an acceleration of the effectiveness
of the above-referenced Registration Statement on Form F-3, as amended, so that such Registration Statement will become effective at 5:00
p.m., Eastern Time, on March 31, 2025, or as soon thereafter as practicable.

 The Company understands that the Commission will
consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the Company
is aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the securities specified in
the Registration Statement.

 Very truly yours,

 /s/ Li Peng Leck

 Name:
 Li Peng Leck

 Title:
 Executive Chairperson and Executive Director (Principal Executive Officer)

CORRESP
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Davis Commodities Limited

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Ms. Kate Beukenkamp

November 22, 2024

    Re:
    Davis Commodities Limited

    Registration Statement on Form F-3, as amended (File No. 333-282380)

    Filed September 27, 2024

Dear Ms. Beukenkamp,

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, Davis Commodities Limited hereby requests acceleration of effectiveness of the above referenced Registration Statement,
so that it will become effective at 4:30 p.m. ET on November 26, 2024, or as soon as thereafter practicable.

Very truly yours,

    /s/ Li Peng Leck

    Name:
    Li Peng Leck

    Title:
    Executive Chairperson and Executive Director (Principal Executive Officer)

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

October 3, 2024
Li Peng Leck
Executive Chairwoman and Executive Director
DAVIS COMMODITIES Ltd
10 Bukit Batok Crescent, #10-01, The Spire
Singapore 658079
Re:DAVIS COMMODITIES Ltd
Registration Statement on Form F-3
Filed September 27, 2024
File No. 333-282380
Dear Li Peng Leck:
            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 Kate Beukenkamp at 202-551-3861 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Ying Li

CORRESP
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September 14, 2023

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Nicholas Nalbantian, Ms. Mara Ransom

    Re:
    Davis Commodities Limited (CIK No. 0001949478)

    Request
     for Acceleration

    Registration
     Statement on Form F-1, as amended (File No. 333-270427)

VIA EDGAR

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Univest Securities, LLC as representative
of the underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will
become effective at 4:30 p.m., Eastern Time on Monday, September 18, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Act, we wish to
advise you that we have distributed as many copies of the Preliminary Prospectus dated August 31, 2023, to selected dealers, institutions
and others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has complied
and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied or will
comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced issue.

Very truly yours,

Univest Securities, LLC

    By:
    /s/ Edric Guo

    Name:
    Edric Guo

    Title:
    Chief Executive Officer

CORRESP
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Davis Commodities Limited

September 14, 2023

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Nicholas Nalbantian

    Mara Ransom

    Re:
    Davis Commodities Limited

    Registration Statement on Form F-1, as amended

    Initially Filed on March 9, 2023

    File No. 333-270427

Ladies and Gentlemen:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Davis Commodities Limited hereby requests that
the effectiveness of the above-referenced Registration Statement on Form F-1, as amended, be accelerated to and that the Registration
Statement become effective at 4:30 p.m., Eastern Time, on September 18, 2023, or as soon thereafter as practicable.

    Very truly yours,

    Davis Commodities Limited

    By:
    /s/ Li Peng Leck

    Name:
     Li Peng Leck

    Title:
    Executive Chairwoman and Executive Director (Principal Executive Officer)

CORRESP
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Davis Commodities Limited

August 31, 2023

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick Kuhn

    Theresa Brillant

    Nicholas Nalbantian

    Mara Ransom

    Re:
    Davis Commodities Limited

    Amendment No. 4 to Registration Statement on Form F-1

    Filed August 23, 2023

    File No. 333-270427

Ladies and Gentlemen:

This letter is in response to the letter dated
August 30, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Davis Commodities Limited (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. An amendment No. 5 to the Registration Statement
on Form F-1 is being filed to accompany this letter.

Cover Page

1. We note your intent to register a resale
transaction using a separate resale prospectus. Because you do not intend to use the resale prospectus unless and until the primary offering
is complete and NASDAQ listing is approved, revise to ensure the prospectus reflects that those events have taken place. For example,
revise to remove the initial public offering range and your statement that there is no public market for the Company's Ordinary Shares
given that you expect a market to be available when you use this prospectus. In this regard, Instruction 2 to Item 501(b)(3) of Regulation
S-K requires disclosure explaining the method by which the price will be determined and indicating the trading market and the market price
of the securities as of the latest practicable date.

In response to the Staff’s comments, we
have amended the disclosure in the resale prospectus on the cover page and under the heading “Selling Shareholders’ Plan of
Distribution” to clarify that the Resale Shares will be sold concurrently with the Company’s initial public offering shares
and from time to time thereafter.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Li Peng Leck

    Name:
    Li Peng Leck

    Title:

    Executive Chairwoman and

    Executive Director

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
August 30, 2023
Li Peng Leck
Executive Chairwoman and Executive Director
Davis Commodities Limited
10 Bukit Batok Crescent
#10-01, The Spire
Singapore 658079
Re:Davis Commodities Limited
Amendment No. 4 to Registration Statement on Form F-1
Filed August 23, 2023
File No. 333-270427
Dear Li Peng Leck:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, 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 comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 6, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1, Filed August 23, 2023
Cover page
1.We note your intent to register a resale transaction using a separate resale prospectus.
Because you do not intend to use the resale prospectus unless and until the primary
offering is complete and NASDAQ listing is approved, revise to ensure the prospectus
reflects that those events have taken place. For example, revise to remove the initial public
offering range and your statement that there is no public market for the Company's
Ordinary Shares given that you expect a market to be available when you use this
prospectus. In this regard, Instruction 2 to Item 501(b)(3) of Regulation S-K requires

 FirstName LastNameLi Peng Leck
 Comapany NameDavis Commodities Limited
 August 30, 2023 Page 2
 FirstName LastName
Li Peng Leck
Davis Commodities Limited
August 30, 2023
Page 2
disclosure explaining the method by which the price will be determined and indicating the
trading market and the market price of the securities as of the latest practicable date.
            You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li

CORRESP
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Davis Commodities Limited

July 10, 2023

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick Kuhn

    Theresa Brillant

    Nicholas Nalbantian

    Mara Ransom

    Re:
    Davis Commodities Limited

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

    Filed July 3, 2023

    File No. 333-270427

Ladies and Gentlemen:

This letter is in response to the letter dated
July 6, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed
to Davis Commodities Limited (the “Company,” “we,” and “our”). For ease of reference, we have recited
the Commission’s comments in this response and numbered them accordingly. An amendment No. 3 to the Registration Statement on Form
F-1 (“Amendment No. 3”) is being filed to accompany this letter.

Risk Factors, page 9

1. We note recent instances of extreme stock
price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number
of recent initial public offerings, particularly among companies with relatively smaller public floats. We also note your disclosure addressing
price and volume volatility shortly following an offering. However, please either revise your existing risk factor, or include a separate
risk factor, to address the potential among relatively smaller public floats for rapid and substantial price volatility and discuss the
risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock
run-up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for
prospective investors to assess the rapidly changing value of your stock.

In response to the Staff’s comments, we
revised our disclosure on page 4 and page 20 of Amendment No. 3 to include a separate risk factor, to address the potential among relatively
smaller public floats for rapid and substantial price volatility and discuss the risks to investors when investing in stock where the
price is changing rapidly.

Use of Proceeds, page 33

2. Please reconcile the estimated net proceeds
from this offering of $8.27 million disclosed in the first paragraph of this section to the net proceeds of approximately $4.45 million
disclosed on page 36 in your capitalization section, and revise as necessary.

In response to the Staff’s comments, we
revised the net proceeds from $8.27 million and $9.14 million to $4.45 million and $5.32 million, respectively, on page 34 of Amendment
No. 3.

      1

Capitalization, page 36

3. Please revise your capitalization table
to reflect the application of the net proceeds of your offering, including the repayment of bank borrowings disclosed in use of proceeds
on page 33.

In response to the Staff’s comments, we
revised our disclosure on page 37 of Amendment No. 3 to reflect the application of the net proceeds of the offering, including the repayment
of bank borrowings disclosed in the use of proceeds on page 33.

Results of Operations

Comparison of Results of Operations for
the Fiscal Years Ended December 31, 2021 and 2022,

page 45

4. Please expand your discussion to describe
the underlying reasons for the material changes in revenue related to Vietnam and Indonesia. Refer to Instruction 1 to Item 5 of Form
20-F.

In response to the Staff’s comments, we
revised our disclosure on page 47 of Amendment No. 3 to describe the underlying reasons for the material changes in revenue related to
Vietnam and Indonesia.

Description of Share Capital, page 114

5. We note that in this section you refer to
your second amended and restated memorandum and articles of association, adopted on June 22, 2023, as your "post-offering memorandum
and articles of association." However, in the rest of the registration statement you refer to it as the second amended and restated
memorandum and articles of association. Seeing as the offering being referred to as "post offering" has not yet occurred, please
align this defined term with the rest of the registration statement, or provide an alternative defined term less likely to confuse readers.

In response to the Staff’s comments, we
revised the term “post-offering memorandum and articles of association” to “second amended and restated memorandum
and articles of association” from page 115 to page 124 of Amendment No. 3.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Li Peng Leck

    Name:
    Li Peng Leck

    Title:

    Executive Chairwoman and

    Executive Director

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

      2

United States securities and exchange commission logo
July 6, 2023
Li Peng Leck
Executive Chairwoman and Executive Director
Davis Commodities Limited
10 Bukit Batok Crescent
#10-01, The Spire
Singapore 658079
Re:Davis Commodities Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed July 3, 2023
File No. 333-270427
Dear Li Peng Leck:
            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.  Unless we note
otherwise, our references to prior comments are to comments in our March 7, 2023 letter.
Amendment No. 2 to Registration Statement on Form F-1 Filed July 3, 2023
Risk Factors, page 9
1.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. We also note your disclosure addressing price and volume volatility
shortly following an offering. However, please either revise your existing risk factor, or
include a separate risk factor, to address the potential among relatively smaller public
floats for rapid and substantial price volatility and discuss the risks to investors when
investing in stock where the price is changing rapidly.  Clearly state that such volatility,

 FirstName LastNameLi Peng Leck
 Comapany NameDavis Commodities Limited
 July 6, 2023 Page 2
 FirstName LastName
Li Peng Leck
Davis Commodities Limited
July 6, 2023
Page 2
including any stock run-up, may be unrelated to your actual or expected operating
performance and financial condition or prospects, making it difficult for prospective
investors to assess the rapidly changing value of your stock.
Use of Proceeds, page 33
2.Please reconcile the estimated net proceeds from this offering of $8.27 million disclosed
in the first paragraph of this section to the net proceeds of approximately $4.45 million
disclosed on page 36 in your capitalization section, and revise as necessary.
Capitalization, page 36
3.Please revise your capitalization table to reflect the application of the net proceeds of
your offering, including the repayment of bank borrowings disclosed in use of proceeds
on page 33.
Results of Operations
Comparison of Results of Operations for the Fiscal Years Ended December 31, 2021 and 2022,
page 45
4.Please expand your discussion to describe the underlying reasons for the material changes
in revenue related to Vietnam and Indonesia.  Refer to Instruction 1 to Item 5 of
Form 20-F.
Description of Share Capital, page 114
5.We note that in this section you refer to your second amended and restated memorandum
and articles of association, adopted on June 22, 2023, as your "post-offering memorandum
and articles of association." However, in the rest of the registration statement you refer to
it as the second amended and restated memorandum and articles of association. Seeing as
the offering being referred to as "post offering" has not yet occurred, please align this
defined term with the rest of the registration statement, or provide an alternative defined
term less likely to confuse readers.
            You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li

CORRESP
1
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Davis Commodities Limited

March 9, 2023

Via EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Attention:
    Patrick Kuhn

    Theresa Brillant

    Nicholas Nalbantian

    Mara Ransom

    Re:
    Davis Commodities Limited

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

    Submitted February 28, 2023

    CIK No. 0001949478

Ladies and Gentlemen:

This letter is in response to the letter dated
March 7, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Davis Commodities Limited (the “Company,” “we,” and “our”). For ease of reference, we
have recited the Commission’s comments in this response and numbered them accordingly. A Registration Statement on Form F-1 (the
“Registration Statement”) is being filed to accompany this letter.

Use of Proceeds, page 33

1. We note your response to comment 2 and reissue
in part. Please also include the interest rate and maturity of the Maxwill Foodlink bank loans. Refer to Item 3.C.4 of Form 20-F, incorporated
by Item 4.a of Form F-1.

In response to the Staff’s comments, we
revised our disclosure on page 33 of the Registration Statement to include the interest rate and maturity of the Maxwill Foodlink bank
loans.

Exhibits

2. We note that in previous versions of the
registration statement you had included an opinion from Raja & Tann Singapore LLP regarding certain Singapore law matters, but these
entries have since been removed. However, Raja & Tann Singapore LLP continues to provide advice on page 32 and is listed in the Legal
Matters section on page 147. Please revise to provide a consent for this information or clarify this discrepancy.

      1

In response to the Staff’s comments, we
respectfully advise the Staff that we have filed the consent of Rajah & Tann Singapore LLP as exhibit 23.3.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

Very truly yours,

    /s/ Li Peng Leck

    Name:
    Li Peng Leck

    Title:
    Executive Chairwoman and

        Executive Director

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

      2

United States securities and exchange commission logo
March 7, 2023
Li Peng Leck
Executive Chairwoman and Executive Director
Davis Commodities Limited
10 Bukit Batok Crescent
#10-01, The Spire
Singapore 658079
Re:Davis Commodities Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted February 28, 2023
CIK No. 0001949478
Dear Li Peng Leck:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1, filed February 28, 2023
Use of Proceeds, page 33
1.We note your response to comment 2 and reissue in part. Please also include the interest
rate and maturity of the Maxwill Foodlink bank loans. Refer to Item 3.C.4 of Form 20-F,
incorporated by Item 4.a of Form F-1.
Exhibits
2.We note that in previous versions of the registration statement you had included an
opinion from Raja & Tann Singapore LLP regarding certain Singapore law matters, but
these entries have since been removed. However, Raja & Tann Singapore LLP continues

 FirstName LastNameLi Peng Leck
 Comapany NameDavis Commodities Limited
 March 7, 2023 Page 2
 FirstName LastName
Li Peng Leck
Davis Commodities Limited
March 7, 2023
Page 2
to provide advice on page 32 and is listed in the Legal Matters section on page 147. Please
revise to provide a consent for this information or clarify this discrepancy.
            You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li

United States securities and exchange commission logo
February 16, 2023
Li Peng Leck
Executive Chairwoman and Executive Director
Davis Commodities Limited
10 Bukit Batok Crescent
#10-01, The Spire
Singapore 658079
Re:Davis Commodities Limited
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted February 3, 2023
CIK No. 0001949478
Dear Li Peng Leck:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 Submitted February 3, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 45
1.We note the revisions in response to prior comment 11. Please further expand your
discussion to more specifically describe the extent to which changes in results of
operations are attributable to changes in prices or changes in the volume or amount of
products being sold. For example, you disclose total revenue increased by approximately
US$62.6 million, or 47.6%, from approximately US$131.6 million in FY2020 to
approximately US$194.2 million in FY2021. Your disclosure should discuss the amount

 FirstName LastNameLi Peng Leck
 Comapany NameDavis Commodities Limited
 February 16, 2023 Page 2
 FirstName LastName
Li Peng Leck
Davis Commodities Limited
February 16, 2023
Page 2

of the change attributable to changes in prices of your commodities and the amount
attributable to changes in amount of products being sold.
Liquidity and Capital Resource, page 54
2.We note you disclose in this section that the funds raised in this initial public offering will
be used for "(b) repayment of certain bank borrowings with the incurred interest expense."
However, in the Use of Proceeds section you do not disclose repayment of
borrowings. Please clarify this discrepancy. In addition, if any of the indebtedness was
incurred within the last year, describe the use of the proceeds of such indebtedness. Refer
to Item 3.C.3 of Form 20-F, incorporated by Item 4.a of Form F-1.
Business, page 76
3.We note your response to comment 21 and reissue in part. We note that Customer A,
disclosed on pages F-48, has been responsible for 10% of your revenue for over a year. In
this section, please disclose the identity of Customer A.
Compensation of Directors and Executive Officers, page 112
4.Please update this disclosure for the fiscal year ended December 31, 2022. Refer to Item
6.B of Form 20-F, incorporated by Item 4.a of Form F-1.
General
5.We note the disclosure of industry data and market data derived from various sources. To
the extent you commissioned any of the third party data you cited, provide the consent of
the third party in accordance with Rule 436.
            You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li

United States securities and exchange commission logo
November 16, 2022
Li Peng Leck
Executive Chairwoman and Executive Director
Davis Commodities Limited
10 Bukit Batok Crescent
#10-01, The Spire
Singapore 658079
Re:Davis Commodities Limited
Draft Registration Statement on Form F-1
Submitted October 21, 2022
CIK No. 0001949478
Dear Li Peng Leck:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 Submitted October 21, 2022
Risk Factors
Risks related to Our Business and Industry
Import or export restrictions by other countries... , page 9
1.You mention the impact of actions by the Indian government, however, it is not clear how
these actions impacted you and to what extent your business is dependent upon exports
from India. Please revise to elaborate.

 FirstName LastNameLi Peng Leck
 Comapany NameDavis Commodities Limited
 November 16, 2022 Page 2
 FirstName LastName
Li Peng Leck
Davis Commodities Limited
November 16, 2022
Page 2
The COVID-19 pandemic has affected, and could continue to affect, the global economy as a
whole..., page 11
2.We note your existing disclosure regarding the impact of COVID-19. However, please
disclose (1) whether your business segments, products, lines of service, projects, or
operations are materially impacted by the pandemic related lockdowns in China and (2)
the impact of consumer demand declines in China. In addition, discuss any steps you are
taking to mitigate adverse impacts to your business.
Fluctuation in the exchange rate between the US$ and foreign currencies may have an adverse
effect on our business, page 12
3.We note that you disclose your exposure to the fluctuation in the "US$, S$ and €."
However, we note that many of your clients and producers are located in jurisdictions that
use currencies other than the US$, S$ or €, for example, you disclose on page 41 that you
acquire raw sugar from India and on page 75 you disclose that you sell sugar in China. In
contrast, we do not see any disclosure suggesting any material exposure to jurisdictions
that use the euro. If true, please update this risk factor to reflect your exposure to
currencies material to your business to help investors better assess the risk.
We rely heavily on our existing brands..., page 14
4.Revise to disclose the amount of revenues that are generated through your exclusive
distributorship with the Thai Roong Ruang Sugar Group and Tong Seng Produce Pte.
Ltd. in order to better understand how these arrangements impact your operations. State, if
true, that you have no commitment from any customer to purchase a certain amount of
your products, even under these exclusive or established distributorships.
Risks Related to this Offering and the Trading Market, page 19
5.We note in this section your risk factor titled "The laws of the Cayman Islands may not
provide our shareholders with benefits comparable to those provided to shareholders of
corporations incorporated in the United States." Please also include a risk factor
addressing that the Cayman Islands is now on the Financial Action Task Force, so called,
"grey list" of anti-money laundering jurisdictions as well as the European Commission's
list of anti-money laundering "high-risk third countries."
Industry Data and Forecasts, page 30
6.We note reference that this prospectus contains data related to the beauty and health
products industry. Please advise.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
40
7.Please include a description, including the amounts invested, of the company's principal

 FirstName LastNameLi Peng Leck
 Comapany NameDavis Commodities Limited
 November 16, 2022 Page 3
 FirstName LastNameLi Peng Leck
Davis Commodities Limited
November 16, 2022
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capital expenditures and divestitures since the beginning of your last two financial years to
the date of this registration statement. Refer to Item 4.A.5 of Form 20-F, incorporated by
Item 4.A. of Form F-1.
8.Please disclose information concerning the principal capital expenditures and divestitures
currently in progress, including the distribution of these investments geographically and
the method of financing. Refer to Item 4.A.6 of Form 20-F, incorporated by Item 4.a of
Form F-1.
Key Factors that Affect Operating Results, page 41
9.We note that the pricing of commodity products affects your business, financial condition,
results of operations, and cash flows. Please discuss recent trends in commodity prices for
sugar, rice, and fats and oils for the periods presented. Refer to Item 5.D of the Form 20-
F.
10.We note you have provided a breakdown of total revenues by category or activity.
However, please also provide a breakdown of total revenues by geographic market. Refer
to Item 4.B.2 of Form 20-F, incorporated by Item 4.a of Form F-1.
Results of Operations, page 45
11.Please expand your discussion to describe the extent to which changes in results of
operations are attributable to changes in prices or changes in the volume or amount of
products being sold. Additionally, in this regard we note per page 12 that you minimize
commodity price risks by selling products on a cost-plus basis or by hedging prices of
products through futures contracts on the commodity exchanges. Please discuss the impact
of these efforts on cost of revenue and gross profit. Refer to Item 5.A of Form 20-F.
12.Please revise your discussions to quantify the reasons underlying material changes within
a line item, including where material changes offset one another. Refer to Item 5 of Form
20-F.
13.Please explain why revenue from oil and fat products decreased 81.9% for the six months
ended June 30, 2022 as compared to the six months ended June 30, 2021. Refer to Item 5
of Form 20-F.
14.Please include a discussion of results of operations on a segment basis. Refer to Item 5 of
Form 20-F.

Liquidity and Capital Resources, page 53
15.Revise to discuss the terms of any available sources of liquidity, such as the secured fixed
rate bank loan you discuss in your financial statements. State your ability to generate and
obtain adequate amounts of cash to meet your requirements and plans for cash in the
short-term and separately in the long-term. Refer to Item 5.B. of Form 20-F.

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 Comapany NameDavis Commodities Limited
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 FirstName LastNameLi Peng Leck
Davis Commodities Limited
November 16, 2022
Page 4
Cash Flows for the Six Months Ended June 30, 2022 Compared to the Six Months Ended June
30, 2021, page 53
16.Your disclosure appears to emphasize how net cash provided by operating activities was
derived for each period presented, and refers to non-cash items that do not impact
cash. Pursuant to Item 5.B of Form 20-F your discussion should be an analysis of material
changes that affected operating cash between comparable periods and should discuss the
key drivers or factors responsible for changes in your operating, investing and financing
cash flows during the periods presented in your financial statements. Please revise your
disclosure accordingly.
Critical Accounting Policies and Estimates, page 59
17.Your disclosure appears to be a summary of your significant accounting policies rather
than disclosure of your critical accounting estimates. Critical accounting estimates are
those estimates made in accordance with generally accepted accounting principles that
involve a significant level of estimation uncertainty and have had or are reasonably likely
to have a material impact on your financial condition or results of operations. Your
disclosure should provide qualitative and quantitative information necessary to understand
the estimation uncertainty and the impact the critical accounting estimate has had or is
reasonably likely to have on your financial condition or results of operations and should
include why each critical accounting estimate is subject to uncertainty and how much each
estimate and/or assumption has changed over a relevant period, and the sensitivity of the
reported amount to the methods, assumptions and estimates underlying its
calculation. Please revise your disclosure accordingly. Refer to Item 5.E of Form 20-F.
Concentrations and Risks
Inflation, page 65
18.We note your disclosure indicating that inflation has not had a material adverse effect on
your business. However, we also note your disclosure on page 43 where you disclose that
the price fluctuations of the commodities you trade may affect your profitability. Please
update your disclosure, if true, if recent inflationary pressures have materially impacted
your operations or the prices in the products your trade.
Business, page 72
19.Please disclose the important events in the development of the company's business,
namely please disclose clearly the establishment, merger or consolidation of the
significant subsidiaries of your business. As one example only, we note that a number of
your management team members also have roles with the wholly owned subsidiary
"Maxwell (Asia)" and that you have reorganized to create a holding company structure.
Refer to Item 4.A.4 of Form 20-F, incorporated by Item 4.a of Form F-1.
20.Please include a description of the marketing channels you use, including, if true, an

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 Comapany NameDavis Commodities Limited
 November 16, 2022 Page 5
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Li Peng Leck
Davis Commodities Limited
November 16, 2022
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explanation of any special sales methods, such as installment sales. Refer to Item 4.B.5 of
Form 20-F, incorporated by Item 4.A of Form F-1.
21.Please provide a summary of information regarding the extent to which you are
dependent, if at all, on patents or licenses, commercial or financial contracts or new
manufacturing processes, where such factors are material to your profitability. For
example, we note that on pages F-48 and F-49 you provide a chart of customers and
suppliers who account for more than 10% of your revenue. Refer to Item 4.B.6 of Form
20-F, incorporated by Item 4.a of Form F-1.
Regulations, page 84
22.Given that you distribute your products to jurisdictions other than Singapore, revise this
discussion to elaborate upon any material regulations applicable to you that pertain to such
jurisdictions. Refer to Item 4.B.8. of Form 20-F.
Principal Shareholders, page 93
23.Revise to clarify whether the 50% ownership you reference in footnotes (2) and (3) held
by Ms. Leck Li Peng constitutes a controlling interest in Davis & KT Holdings Pte. Ltd. If
not, disclose with whom she shares control over such entity.
Related Party Transactions, page 94
24.Clarify when the convertible loan granted to Carfax Commodities (Asia) Pte. Ltd. comes
due and the nature of the events that would trigger a conversion.
Material Income Tax Consideration
United States Federal Income Taxation, page 110
25.We note your disclaimer contains a reference to ADSs, but there is no reference to ADSs
elsewhere in the registration statement. Please align this disclosure with the rest of the
registration statement.
Report of Independent Registered Public Accounting Firm, page F-2
26.Please make arrangements with your auditor for them to revise their reports here and on
page F-26 to comply with the requirements of Article 2 of Regulation S-X, including the
date of the reports.

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 Comapany NameDavis Commodities Limited
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Li Peng Leck
Davis Commodities Limited
November 16, 2022
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Notes to Financial Statements
Note1. Organization and Principal Activities
Reorganization, page F-7
27.Your table on page F-8 presents Maxwill Pte. Ltd. as dormant but you disclose
that Maxwill Pte. Ltd. wholly owns Maxwill (Asia) Pte. Ltd., LP Grace Pte. Ltd. and
Maxwill Foodlink Pte. Ltd., which are your operating companies. Please make any
necessary corrections here and on page F-32.
Note 2. Summary of Significant Accounting Policies
(n) Revenue recognition, page F-12
28.You disclose that you are an asset light business and utilize a network of third-party
commodity suppliers and logistics service providers to distribute sugar, rice, and oil and
fat products from suppliers to customers and also arrange for customers’ insurance and
security coverage, including cargo insurance for the commodities, and engage third-party
service providers for services such as warehouse handling and storage. Please tell us your
consideration of ASU 606-10-55-36 as to whether the nature of your promise is
a performance obligation to provide the specified goods or services itself (that is, as a
principal) or to arrange for those goods or services to be provided by the other party (that
is, as an agent). In addition, tell us your consideration of ASU 606-10-55-37 which states
that an entity does not necessarily control a specified good if the entity obtains legal title
to that good only momentarily before legal title is transferred to a customer.
29.We note that your main business activities include value-added services such as
warehouse handling and storage and logistics services. Please disclose your revenue
recognition policy for these services. Additionally, please tell us the amount of revenue
generated from these services for each of the periods presented.
30.Please tell us the amount of revenue recognized from the rental of investment property for
each period presented.
Note 14. Revenues By Product, page F-19
31.Please provide the disclosure required by ASC 280-10-50-41(a), noting that if revenue
attributed to an individual foreign country is material, those revenues should be disclosed
separately.
Note 21. Subsequent Events, page F-25
32.Please provide the date here and on page F-49 through which you have assessed all
material subsequent events that require disclosure in your consolidated financial
statements.

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Davis Commodities Limited
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General
33.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on our behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications. Please contact the staff member associated
with the review of this filing to discuss how to submit the materials, if any, to us for our
review.
34.Please file the Thai Roong Ruang Sugar Group and the Tong Seng Produce Pte.
Ltd. exclusive distributorship agreements as exhibits. See Item 8(a) of Form F-1 and Item
601(b)(10) of Regulation S-K.
            You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Ying Li