SecProbe.io

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 filename1.htm

 March 19, 2026

 Via EDGAR

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C., 20549

 Re: Linkers Industries Limited

 Registration Statement on Form F-1

 File
No. 333-294360

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, Linkers Industries Limited, hereby respectfully requests acceleration of the effectiveness
of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4:00 p.m. Eastern Time,
on Friday, March 20, 2026, or as soon as practicable thereafter.

 Very truly yours,

 /s/ Man Tak Lau

 Name:
 Man Tak Lau

 Title:
 Chairman of the Board of Directors

 c.c.: David Danovitch, Esq.
 Angela
Gomes, Esq.
 Joseph E. Segilia, Esq.

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 Univest Securities, LLC

 75 Rockefeller Plaza, 18C

 New York, NY 10019

 March 19, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

 Attention: Sarah Sidwell

 Re: Linkers Industries Ltd

 Registration Statement on Form F-1, as amended

 File No. 333-294360

 Ladies and Gentlemen:

 Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the "Securities Act"), we, the undersigned, as the sole placement agent for the proposed
public offering on a best efforts basis of securities of Linkers Industries Ltd (the "Company"), hereby join the Company's
request that the effective date of the above-referenced registration statement on Form F-1, as amended, be accelerated so that it will
be declared effective at 4:00 p.m., Eastern Time, on Friday, March 20, 2026, or as soon thereafter as possible.

 Pursuant to Rule 460 under
the Securities Act, please be advised that we will distribute as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

 The undersigned advises that
it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 Very truly yours,

 UNIVEST SECURITIES, LLC

 By:
 /s/ Bradley Richmond

 Name: Bradley Richmond

 Title: Chief Operating Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 10, 2026

Wai Kee Kan
Chief Executive Officer
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia

 Re: Linkers Industries Ltd
 Draft Registration Statement on Form F-1
 Submitted February 4, 2026
 CIK No. 0001972074
Dear Wai Kee Kan:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
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 Erin Donahue at 202-551-6063 with any questions.

 Sincerely,

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

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Linkers Industries Limited

VIA EDGAR

September 27, 2024

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Manufacturing

Washington, D.C. 20549

Attn: Erin Donahue / Geoffrey Kruczek

    Re:
    Linkers Industries Limited

Registration Statement on Form F-1

Initially Filed on May 28, 2024, as amended

File No. 333-279752

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, Linkers Industries Limited hereby requests acceleration of effectiveness of the above referenced
Registration Statement so that it will become effective at 4:00 p.m. ET on September 30, 2024, or as soon as thereafter practicable.

    Very truly yours,

    /s/ Man Tak Lau

    Man Tak Lau

 Chairman of the Board of Directors

 cc: Loeb & Loeb LLP

VCL Law LLP

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Linkers Industries Limited

September 27, 2024

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, DC 20549

Attn: Erin Donahue / Geoffrey Kruczek

    Re:
    Linkers Industries Limited

    Registration Statement on Form F-1, as amended

    Initially Filed on May 28, 2024

    File No.: 333-279752

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the “Act”), we, R.F. Lafferty & Co., Inc., as the representative of the several
underwriters, hereby join in the request by Linkers Industries Limited that the effective date of the above-referenced registration statement
be accelerated so that it will be declared effective at 4:00 p.m., Eastern Time, on September 30, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 under
the Act, we, as representative of the several underwriters, wish to advise you that we have distributed to each underwriter and dealer
who is reasonably anticipated to participate in the distribution of the security to be offered a sufficient number of copies of the preliminary
prospectus dated August 19, 2024 as it appears to be reasonable to secure their adequate distribution.

We, the undersigned, as representative
of the several underwriters, confirm that we have complied and will continue to comply with, and we have been informed or will be informed
by the participating underwriters and dealers that they have complied or will comply with, Rule 15c2-8 promulgated under the Securities
Exchange Act of 1934, as amended.

Very truly yours,

R.F. Lafferty & Co., Inc.

    By:
    /s/
    John Heidenreich

    Name:
    John Heidenreich

    Title:
    Head of Equity Capital Markets

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June 5, 2024

Via Edgar Transmission

Ms. Erin Donahue/Mr. Geoffrey Kruczek

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Linkers Industries Ltd

    Registration Statement on Form F-1

    Filed May 28, 2024

    File No. 333-279752

Dear Ms. Donahue/Mr. Kruczek:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated June 4, 2024 from the Securities and Exchange Commission
(the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Draft Registration Statement on Form F-1 (the “Form F-1”).

For the Staff’s convenience,
the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such
comment.

Registration Statement on Form F-1 filed May
28, 2024

Explanatory Note, page i

 1. Please update the disclosure in this section to reflect that this is a new registration statement,
and not a post-effective amendment to a registration statement on Form F-1.

Response: We
respectfully advise the Staff that we have updated the disclosure in Explanatory Note to remove the disclosure regarding
post-effective amendment.

General

 2. Please file an updated, correct version of Exhibit 1.1. We note that such exhibit does not appear to
include R.F. Lafferty. We also note that the information in Schedule A, page 24 of Exhibit 1.1 is inconsistent with the disclosure on
page 116 of the Form F-1.

Response: We
respectfully advise the Staff that we have updated exhibit 1.1. The Company notes for the Staff’s reference that save for
exhibit 1.1, the Company did not update any other exhibit since the last as-filed version of the Form F-1 File No. 333-279752.
Furthermore, the Company confirms that the exhibits 3.1, 3.2, 4.1, 10.1 - 10.25, 21.1 and 99.1 – 99.4 are identical to the
exhibits filed in the Company’s previously withdrawn Form F-1 File No. 275953, as amended.

 3. We note your disclosure on page Alt-14 that your selling security holders may sell their securities
in one or more underwritten offerings on a firm commitment or best efforts basis. Please confirm your understanding that the retention
by a selling stockholder of an underwriter would constitute a material change to your plan of distribution requiring a post-effective
amendment. Refer to your undertaking provided pursuant to Item 512(a)(1)(iii) of Regulation S-K.

Response: The
Company confirms its understanding that retention by a selling stockholder of an underwriter would constitute a material change to our
plan of distribution requiring a post-effective amendment. The Company refers to the disclosure in the second to last paragraph of page
Alt-14, and notes the current disclosure already contains “If sales of shares offered under this Resale Prospectus are made to
broker-dealers as principals, we would be required to file a post-effective amendment to the registration statement of which this Resale
Prospectus is a part. In the post-effective amendment, we would be required to disclose the names of any participating broker-dealers
and the compensation arrangements relating to such sales.”

* * *

Please contact the undersigned
at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/ Lawrence S. Venick

    Lawrence S. Venick

    Direct Dial: +852.3923.1188

    Email: lvenick@loeb.com

United States securities and exchange commission logo
June 4, 2024
Wai Kee Kan
Chief Executive Officer
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia
Re:Linkers Industries Ltd
Registration Statement on Form F-1
Filed May 28, 2024
File No. 33-279752
Dear Wai Kee Kan:
            We have reviewed your registration statement and have the following comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1 filed May 28, 2024
Explanatory Note, page i
1.Please update the disclosure in this section to reflect that this is a new registration
statement, and not a post-effective amendment to a registration statement on Form F-1.
General
2.Please file an updated, correct version of Exhibit 1.1.  We note that such exhibit does not
appear to include R.F. Lafferty.  We also note that the information in Schedule A, page 24
of Exhibit 1.1 is inconsistent with the disclosure on page 116 of the Form F-1.

 FirstName LastNameWai Kee Kan
 Comapany NameLinkers Industries Ltd
 June 4, 2024 Page 2
 FirstName LastName
Wai Kee Kan
Linkers Industries Ltd
June 4, 2024
Page 2
3.We note your disclosure on page Alt-14 that your selling securityholders may sell their
securities in one or more underwritten offerings on a firm commitment or best efforts
basis. Please confirm your understanding that the retention by a selling stockholder of an
underwriter would constitute a material change to your plan of distribution requiring a
post-effective amendment.  Refer to your undertaking provided pursuant to Item
512(a)(1)(iii) of Regulation S-K.
            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.
            Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Erin Donahue at 202-551-6063 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Ted Paraskevas

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Linkers Industries
Limited

VIA EDGAR

March 26, 2024

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Manufacturing

Washington, D.C. 20549

Attn: Gregory Herbers, Geoffrey Kruczek

 Re: Linkers Industries Limited

Registration Statement
on Form F-1

Filed
December 8, 2023, as amended

File No. 333-275953

Pursuant to Rule 461
under the Securities Act of 1933, as amended, Linkers Industries Limited hereby requests acceleration of effectiveness of the above
referenced Registration Statement so that it will become effective at 4:00 p.m. ET on March 28, 2024, or as soon as thereafter
practicable.

    Very truly yours,

    /s/ Man Tak Lau

    Man Tak Lau

    Chairman of the Board of Directors

 cc: Loeb & Loeb LLP

VCL Law LLP

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Linkers Industries Limited

March 26, 2024

Via EDGAR

Gregory Herbers, Geoffrey Kruczek

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, DC 20549

    Re:
    Linkers Industries Limited

    Registration Statement
    on Form F-1, as amended

    Initially Filed on December
    8, 2023

    File No.: 333-275953

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Act”), we, Revere Securities LLC, as the representative of the
several underwriters, hereby join in the request by Linkers Industries Limited that the effective date of the above-referenced
registration statement be accelerated so that it will be declared effective at 4 p.m., Eastern Time, on March 28,
2024, or as soon thereafter as practicable.

Pursuant to Rule 460 under
the Act, we, as representative of the several underwriters, wish to advise you that we have distributed to each underwriter and dealer
who is reasonably anticipated to participate in the distribution of the security to be offered a sufficient number of copies of the preliminary
prospectus dated January 29, 2024 as it appears to be reasonable to secure their adequate distribution.

We, the undersigned, as representative
of the several underwriters, confirm that we have complied and will continue to comply with, and we have been informed or will be informed
by the participating underwriters and dealers that they have complied or will comply with, Rule 15c2-8 promulgated under the Securities
Exchange Act of 1934, as amended.

Very truly yours,

Revere Securities LLC

    By:
    /s/
    Bill Moreno

    Name:
    Bill Moreno

    Title:
    Chief Executive Officer and Chairman

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December 20, 2023

Via Edgar Transmission

Mr. Gregory Herbers/ Mr. Geoffrey Kruczek

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

Washington, D.C. 20549

    Re:

    Linkers Industries Ltd

    Registration Statement on Form F-1

    Filed December 8, 2023

    File No. 333-275953

Dear Mr. Herbers/ Mr. Kruczek:

As counsel for the Company
and on its behalf, this letter is being submitted in response to the letter dated December 15, 2023 from the Securities and Exchange Commission
(the “Commission”) in which the staff of the Commission (the “Staff”) commented on the above-referenced
Registration Statement on Form F-1 (the “Form F-1”).

For the Staff’s convenience,
the Staff’s comment has been stated below in its entirety, with the Company’s response set out immediately underneath such
comment.

Registration Statement on Form F-1 filed December
8, 2023

Exhibits

 1. Refer to Exhibit 5.1. The opinion regarding the legality
of the issuance must address each transaction you are attempting to register. It appears the opinion you filed does not address the resale
transaction included in your fee table, given that the opinion does not opine that the shares to be resold are currently duly authorized,
validly issued and non- assessable. Please file a revised opinion.

Response: We
respectfully advise the Staff that we have updated Exhibit 5.1 to include the above.

 2. Refer to Exhibit 23.4. Please ask counsel to provide its
consent to each reference to its name. Currently, this exhibit does not include the reference on page 29.

Response: We
respectfully advise the Staff that we have updated Exhibit 23.4 to include consent to the reference on page 29.

 3. Refer to Exhibit 8.2 and 23.3. Please have counsel provide
an exhibit that includes its clear consent to each reference to its name in the registration statement and to the filing of this opinion
as an exhibit. Also, though this exhibit purports to be a tax opinion, it does not state that the statements in the disclosure beginning
on page 106 are counsel’s opinion. Please file a revised opinion.

Response: We
respectfully advise the Staff that we have updated Exhibit 8.2 and 23.3 to include clear consent, as well as to cover Malaysia taxation
disclosures as part of the circle-up in appendix VII to the opinion.

General

 4. Please revise to identify the natural person(s) who have
or share voting and/or dispositive powers with respect to the shares held by the entities in the table on page Alt-13.

Response: We
respectfully advise the Staff that we have revised page Alt-13 to disclose the above.

* * *

Please contact the undersigned
at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/ Lawrence S. Venick

    Lawrence S. Venick

    Direct Dial: +852.3923.1188

    Email: lvenick@loeb.com

United States securities and exchange commission logo
December 15, 2023
Man Tak Lau
Director and Chairman of the Board of Directors
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia
Re:Linkers Industries Ltd
Registration Statement on Form F-1
Filed December 8, 2023
File No. 333-275953
Dear Man Tak Lau:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our November 7, 2023 letter.
Registration Statement on Form F-1 filed December 8, 2023
Exhibits
1.Refer to Exhibit 5.1.  The opinion regarding the legality of the issuance must address each
transaction you are attempting to register.  It appears the opinion you filed does not
address the resale transaction included in your fee table, given that the opinion does not
opine that the shares to be resold are currently duly authorized, validly issued and non-
assessable.  Please file a revised opinion.
2.Refer to Exhibit 23.4.  Please ask counsel to provide its consent to each reference to its
name.  Currently, this exhibit does not include the reference on page 29.
3.Refer to Exhibit 8.2 and 23.3.  Please have counsel provide an exhibit that includes its
clear consent to each reference to its name in the registration statement and to the filing of
this opinion as an exhibit.  Also, though this exhibit purports to be a tax opinion, it does

 FirstName LastNameMan Tak Lau
 Comapany NameLinkers Industries Ltd
 December 15, 2023 Page 2
 FirstName LastName
Man Tak Lau
Linkers Industries Ltd
December 15, 2023
Page 2
not state that the statements in the disclosure beginning on page 106 are counsel's
opinion.  Please file a revised opinion.
General
4.Please revise to identify the natural person(s) who have or share voting and/or dispositive
powers with respect to the shares held by the entities in the table on page Alt-13.
            Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

United States securities and exchange commission logo
November 7, 2023
Man Tak Lau
Director and Chairman of the Board of Directors
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia
Re:Linkers Industries Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted October 26, 2023
CIK 1972074
Dear Man Tak Lau:
            We have reviewed your amended draft registration statement and have the following
comments.
            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 a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Form 1 submitted October 26, 2023
General
1.We note your response to prior comment 2. Please tell us how, going forward, the
company would determine whether more than 50 percent of its outstanding voting
securities are owned of record by U.S. residents for purposes of satisfying the foreign
private issuer definition. See Securities Act Rule 405 and Exchange Act Rule 3b-4;
Securities Act Rules Compliance and Disclosure Interpretation 203.17.
Use of Proceeds, page 39
2.We note your response to prior comment 4. Please additionally revise your disclosure,
here and throughout the registration statement, to include where you are in the acquisition
process, such as whether any understandings or agreements exist between you and any
target company or joint venture partner.

 FirstName LastNameMan Tak Lau
 Comapany NameLinkers Industries Ltd
 November 7, 2023 Page 2
 FirstName LastName
Man Tak Lau
Linkers Industries Ltd
November 7, 2023
Page 2
Diversified Customer Base, page 60
3.We note your response to prior comment 6. Please specifically identify the "key customers
who are renowned global brand name manufacturers and OEMs" described in this section.
Board of Directors, page 84
4.We note your response to prior comment 8. Please amend your disclosure prior to
effectiveness, with the identities of all independent directors.
            Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

United States securities and exchange commission logo
October 19, 2023
Man Tak Lau
Director and Chairman of the Board of Directors
Linkers Industries Ltd
Lot A99, Jalan 2A-3, A101 & A102, Jalan 2A, Kawasan Perusahaan MIEL
Sungai Lalang, 08000 Sungai Petani, Kedah Darul Aman, Malaysia
Re:Linkers Industries Ltd
Draft Registration Statement on Form F-1
Submitted September 22, 2023
CIK 1972074
Dear Man Tak Lau:
            We have reviewed your draft registration statement and have the following comments.
            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 a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Form F-1 submitted September 22, 2023
General
1.We note from page iv that you commissioned a report from Ken Research.  Please file
their consent as an exhibit.
2.We note that you are a foreign private issuer offering voting securities in the United
States.  Please tell us how would the company determine whether more than 50 percent of
its outstanding voting securities are owned of record by U.S. residents for purposes of
satisfying the foreign private issuer definition.  See Securities Act Rule 405 and Exchange
Act Rule 3b-4; Securities Act Rules Compliance and Disclosure Interpretation 203.17.
Industry and Market Data, page 34
3.You state that Ken Research Private Limited analysis shows that high inflation rates may
negatively affect the major appliances market in Asia-Pacific and Western Europe.  Please

 FirstName LastNameMan Tak Lau
 Comapany NameLinkers Industries Ltd
 October 19, 2023 Page 2
 FirstName LastName
Man Tak Lau
Linkers Industries Ltd
October 19, 2023
Page 2
expand to identify the principal factors contributing to the inflationary pressures the
company has experienced and clarify the resulting impact to the company.
Use of Proceeds, page 39
4.Please revise the first bullet to discuss in greater detail the potential acquisitions and joint
ventures.
Managements Discussion and Analysis of Financial Condition and Results of Operations, page
46
5.Please update your disclosure to identify actions planned or taken, if any, to mitigate
inflationary pressures.
Diversified customer base, page 60
6.Please identify the "key customers who are renowned global brand name manufacturers
and OEMs."  Also reconcile the "diversified customer base" with the concentration of
revenue percentages on page 17.
Management, page 81
7.Please update your disclosure to include compensation disclosure for your executive
officers.
Board of Directors, page 84
8.Please reconcile your disclosure here that a majority of your board will not be independent
with your disclosure that you do not intend to rely on controlled company provisions you
cite.
            Please contact Andi Carpenter at 202-551-3645 or Andrew Blume at 202-551-3254 if you
have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick