SecProbe.io

CORRESP
 1
 filename1.htm

 WEBUY GLOBAL LTD

 July 16, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, NE

 Washington, D.C., 20549

 Attn: Nicholas Nalbantian

 Taylor Beech

 Re:
 WEBUY GLOBAL LTD

 Registration Statement on Form F-1, as amended (File No. 333-288310)

 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, WEBUY GLOBAL LTD hereby requests an acceleration of the effectiveness of
the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become effective at 4:30
p.m., Eastern Time, on July 18, 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,

 WEBUY GLOBAL LTD

 By:
 /s/ Bin Xue

 Name:
 Bin Xue

 Title:
 Chief Executive Officer and Chairman of the Board of Directors

CORRESP
 1
 filename1.htm

 VIA EDGAR

 July 16, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, NE

 Washington, D.C. 20549

 Attn:
 Nicholas Nalbantian

 Taylor Beech

 Re:
 WEBUY GLOBAL LTD

 File No. 333-288310

 Registration Statement on Form F-1, as amended

 Ladies and Gentlemen:

 As the placement agent of
the proposed offering of Webuy Global Ltd (the "Company"), we hereby join the Company's request for acceleration of
the above-referenced Registration Statement, requesting effectiveness for 4:30 p.m., Eastern Time, on July 18, 2025, or as soon thereafter
as is practicable.

 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 it has 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,

 D. Boral Capital LLC

 By:
 /s/ Stephanie Hu

 Name:
 Stephanie Hu

 Title:
 Co-Head of Investment Banking

CORRESP
 1
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 WEBUY
GLOBAL LTD

 35 Tampines Street 92 Singapore 528880

 +65 8859 9762

 July 14, 2025

 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

 Taylor Beech

 Re:
 WEBUY GLOBAL LTD

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

 Filed July 1, 2025

 File No. 333-288310

 Dear Mr. Nalbantian,

 This letter is being submitted in response to
the letter dated July 11, 2025 from the U.S. Securities and Exchange Commission (the “ Commission ”) in which the staff
of the Commission (the “ Staff ”) commented on the above-referenced Post-Effective Amendment No. 1 to Registration Statement
on Form F-1 filed on July 1, 2025. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, the Post-Effective
Amendment No. 2 to Registration Statement on Form F-1 (“ POS AM No.2 ”) for filing with the Commission, which has been
revised to reflect the Staff’s comments as well as certain other updates to the POS AM No.2.

 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. Page references
below in the Company’s responses are to the page numbers in POS AM No.2. Capitalized terms used but not otherwise defined herein
have the meanings set forth in the POS AM No.2.

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

 Plan of Distribution, page 43

 1.
 We note that this is a best efforts offering and your disclosure in this section that you “intend to complete a closing of this offering but may undertake one or more additional closings for the sale of additional securities to the investors in the initial closing.” As this language suggests that the securities being registered are to be offered on a continuous basis, please check the Rule 415 box on the registration statement cover page and include Item 512(a) of Regulation S-K undertakings. Refer to Item 9. Undertakings. of Form F-1. Alternatively, please amend your disclosure or provide your analysis to how this would not constitute a continuous offering.

 RESPONSE : In response to the Staff’s
comment, we checked the Rule 415 box on the cover page of the registration statement and included the undertakings required under Item
512(a) of Regulation S-K in the POS AM No.2.

 We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact the Company’s securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq, or Yarona L. Yieh,
Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal, or yly@orllp.legal.

 Very truly yours,

 /s/ Bin Xue

 Name:
 Bin Xue

 Title:
 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 11, 2025

Bin Xue
Chief Executive Officer
WeBuy Global Ltd
35 Tampines Street 92
Singapore 528880

 Re: WeBuy Global Ltd
 Post-Effective Amendment No. 1 to Registration Statement on Form F-1
 Filed July 1, 2025
 File No. 333-288310
Dear Bin Xue:

 We have conducted a limited review of 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.

Post-Effective Amendment No. 1 to Registration Statement on Form F-1
Plan of Distribution, page 43

1. We note that this is a best efforts offering and your disclosure in this
section that you
 "intend to complete a closing of this offering but may undertake one or
more
 additional closings for the sale of additional securities to the
investors in the initial
 closing." As this language suggests that the securities being registered
are to be
 offered on a continuous basis, please check the Rule 415 box on the
registration
 statement cover page and include Item 512(a) of Regulation S-K
undertakings. Refer
 to Item 9. Undertakings. of Form F-1. Alternatively, please amend your
disclosure or
 provide your analysis to how this would not constitute a continuous
offering.
 July 11, 2025
Page 2

 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 Nicholas Nalbantian at 202-551-7470 or Taylor Beech at
202-551-
4515 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Yarona Yieh
</TEXT>
</DOCUMENT>

CORRESP
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 VIA EDGAR

 June 27, 2025

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, NE

 Washington, D.C. 20549

 Attn: Brian Fetterolf

 Re:
 Webuy Global Ltd

 File No. 333-288310
 Registration Statement on Form F-1, as amended

 Ladies and Gentlemen:

 As the placement agent of the
proposed offering of Webuy Global Ltd (the "Company"), we hereby join the Company's request for acceleration of the
above-referenced Registration Statement, requesting effectiveness for 4:30 p.m., Eastern Time, on June 27, 2025, or as soon thereafter
as is practicable.

 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 it has 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,

 D. Boral Capital LLC

 By:
 /s/ Stephanie Hu

 Name:
 Title:
 Stephanie Hu Co-Head
of Invest Banking

CORRESP
 1
 filename1.htm

 WEBUY GLOBAL LTD

 June 27, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, NE

 Washington, D.C., 20549

 Attn: Brian Fetterolf

 Re:
 WEBUY GLOBAL LTD

 Registration Statement on Form F-1, as amended (File No. 333-288310)
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, WEBUY GLOBAL LTD hereby requests an acceleration of the effectiveness of the
above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become effective at 4:30 p.m.,
Eastern Time, on June 27, 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,

 WEBUY GLOBAL LTD

 By:
 /s/ Bin Xue

 Name:
 Bin Xue

 Title:
 Chief Executive Officer and Chairman of the Board of Directors

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 18, 2025

Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
35 Tampines Street 92
Singapore 528880

 Re: WEBUY GLOBAL LTD
 Draft Registration Statement on Form F-1
 Submitted June 9, 2025
 CIK No. 0001946703
Dear Bin Xue:

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

 We request that you publicly file your registration statement 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 Brian Fetterolf at 202-551-6613 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Yarona Yieh
</TEXT>
</DOCUMENT>

CORRESP
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 WEBUY GLOBAL LTD

 35 Tampines Street 92

 Singapore 528880

 June 3, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C., 20549

 Attn: Ms. Rebekah Reed

 Re:
 WEBUY GLOBAL LTD

 Registration Statement on Form F-3 (File No. 333-287585)
 Request for Acceleration of Effectiveness

 Ms. Reed:

 In accordance with Rule 461 of the General
Rules and Regulations under the Securities Act of 1933, as amended, WEBUY GLOBAL LTD hereby requests an acceleration of the effectiveness
of the above-referenced Registration Statement on Form F-3, so that such Registration Statement will become effective
at 4:00 p.m., Eastern Time, on June 5, 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,

 WEBUY GLOBAL LTD

 By:
 /s/ Xue Bin

 Name:
 Xue Bin

 Title:
 Chief Executive Officer and Chairman

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

Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
35 Tampines Street 92
Singapore 528880

 Re: WEBUY GLOBAL LTD
 Registration Statement on Form F-3
 Filed May 27, 2025
 File No. 333-287585
Dear Bin Xue:

 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: Jason Ye
</TEXT>
</DOCUMENT>

December 2, 2024
Vincent Xue
Chief Executive Officer
WEBUY GLOBAL LTD
35 Tampines Street 92
Singapore 528880
Re:WEBUY GLOBAL LTD
Registration Statement on Form F-3
Filed November 20, 2024
File No. 333-283356
Dear Vincent Xue:
            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 Jenna Hough at 202-551-3063 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
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WEBUY GLOBAL LTD

35 Tampines Street 92

Singapore 528880

November 29, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C., 20549

Attn: Ms. Jenna Hough

    Re:
    WEBUY GLOBAL LTD

    Registration Statement on Form F-3 (File No. 333- 283356)

    Request for Acceleration of Effectiveness

Ms. Hough:

In accordance with Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended, WEBUY GLOBAL LTD 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 4:30
p.m., Eastern Time, on December 3, 2024, 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,

    WEBUY GLOBAL LTD

    By:
    /s/ Xue Bin

    Name:
    Xue Bin

    Title:
    Chief Executive Officer and Chairman

CORRESP
1
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WEBUY GLOBAL LTD

October 9, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C., 20549

Attn: Ms. Kate Beukenkamp

    Re:
    WEBUY GLOBAL LTD

    Registration Statement on Form F-1, as amended (File No. 333- 281605)

 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, WEBUY GLOBAL LTD hereby requests an acceleration of the effectiveness
of the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become effective
at 4:30 p.m., Eastern Time, on October 11, 2024, 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,

    WEBUY GLOBAL
    LTD

    By:
    /s/
    Xue Bin

    Name:
    Xue Bin

    Title:
    Chief Executive Officer
    and Chairman

CORRESP
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WEBUY GLOBAL LTD

35 Tampines Street 92

Singapore 528880

September 20, 2024

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4720

Attn: Kate Beukenkamp

    Re:

    WEBUY GLOBAL LTD

    Registration Statement on Form F-1

    Filed September 12, 2024

    File No. 333-281605

Dear Ms. Beukenkamp:

This letter is in response to the letter from
the Staff (the “Staff’”) of the U.S. Securities and Exchange Commission (“Commission”), dated September
17, 2024, in which you provided comments to Registration Statement on Form F-1 (the “Registration Statement”) of WEBUY GLOBAL
LTD (the “Company”) submitted to the U.S. Securities and Exchange Commission on September 12, 2024. On the date
hereof, the Company has filed with the Commission an Amendment to the Registration Statement on Form F-1 (“Amendment No. 2”).
We set forth below in bold the comments in your letter relating to the Registration Statement followed by our responses to the comments.

Registration Statement on Form F-1 filed
September 17, 2024

General

 1. We
note your response to prior comment 1 and reissue in part. Your revisions reflect a conversion price of the shares issuable upon conversion
of the Convertible Note to be “ninety percent (90%) of the average of the three (3) lowest daily VWAPs during the twenty (20) Trading
Days prior to the payment date per share selected by the Investor, provided that the conversion price may not be less than $0.029 (the
“Floor Price”).” However, as reflected in the Convertible Note, now filed as Exhibit 10.9, the Conversion Price is defined
as meaning $0.213 subject to certain adjustments and is not dependent on the market price of your outstanding shares. Please revise your
disclosure throughout this registration statement accordingly.

RESPONSE: We respectfully advise the Staff that
we have revised the disclosure regarding the conversion price throughout Amendment No. 2 to be consistent with the Convertible Note.
Specifically, the disclosure distinguished between the elections of the Investor and the Company as to how they would be able to either
convert or repay the Convertible Note. At the Company’s election, the monthly installments of the Convertible Note may be repaid
in cash or repayment shares, or a combination of both. The calculation of the repayment shares shall be the principal amount then outstanding
divided by 90% of the average of the 3 lowest daily VWAPs during the 20 trading days prior to the payment date selected by the Investor.
On the other hand, the Investor may at any time convert the Convertible Note in its sole discretion to the Company’s Class A ordinary
shares at $0.213, subject to certain adjustments, provided that the conversion price may not be less the Floor Price.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ BinXue

    Bin Xue

    Chairman

September 17, 2024
Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
35 Trampines Street
92 Singapore 528880
Re:WEBUY GLOBAL LTD
Amendment No. 1 to Registration Statement on Form F-1
Filed September 12, 2024
File No. 333-281605
Dear Bin Xue:
            We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our September 9, 2024 letter.
Amendment No. 1 to Form F-1 filed September 12, 2024
General
1.We note your response to prior comment 1 and reissue in part. Your revisions reflect a
conversion price of the shares issuable upon conversion of the Convertible Note to be
"ninety percent (90%) of the average of the three (3) lowest daily VWAPs during the
twenty (20) Trading Days prior to the payment date per share selected by the Investor,
provided that the conversion price may not be less than $0.029 (the “Floor Price”)."
However, as reflected in the Convertible Note, now filed as Exhibit 10.9, the Conversion
Price is defined as meaning $0.213 subject to certain adjustments and is not dependent on
the market price of your outstanding shares. Please revise your disclosure throughout this
registration statement accordingly.

September 17, 2024
Page 2
            Please contact Kate Beukenkamp at 202-551-3861 or Erin Jaskot at 202-551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Mengyi "Jason" Ye

CORRESP
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WEBUY GLOBAL LTD

35 Tampines Street 92

Singapore 528880

September 12, 2024

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

Washington, D.C. 20549-4720

Attn: Kate Beukenkamp

    Re:

    WEBUY GLOBAL LTD

    Registration Statement on Form F-1

    Filed August 16, 2024

    File No. 333-281605

Dear Ms. Beukenkamp:

This letter is in response to the letter from
the Staff (the “Staff’”) of the U.S. Securities and Exchange Commission (“Commission”), dated September
9, 2024, in which you provided comments to Registration Statement on Form F-1 (the “Registration Statement”) of WEBUY GLOBAL
LTD (the “Company”) submitted to the U.S. Securities and Exchange Commission on August 16, 2024. On the date hereof,
the Company has filed with the Commission an Amendment to the Registration Statement on Form F-1 (“Amendment No. 1”). We set
forth below in bold the comments in your letter relating to the Registration Statement followed by our responses to the comments.

Registration Statement on Form F-1 filed
August 16, 2024

Prospectus Summary

The Offering, page 9

 1. Please revise your disclosure
here and throughout your registration statement as necessary to accurately reflect the conversion price of the shares issuable upon conversion
of the Convertible Note. In this regard, we note that your disclosure here reflects that the conversion price will be 90% of the average
of the 3 lowest daily VWAPs during the 20 trading days prior to the payment date selected by the selling shareholder. However, as reflected
in the Senior Secured Convertible Promissory Note dated July 25, 2025 filed as Exhibit 10.2 to your Form 6-K filed July 30, 2024, and
elsewhere in your prospectus, it appears the conversion price is $0.213 subject to certain adjustments (e.g., stock splits and dividends)
and is not dependent on the market price of your outstanding shares. Further, please file the Convertible Note as an exhibit to this
registration statement.

RESPONSE: We respectfully advise the Staff
that we have revised the disclosure regarding the conversion price throughout Amendment No. 1 to be consistent with the Convertible
Note. We further advise the Staff that the securities purchase agreement and the Convertible Note have both been added to the exhibit list to
Amendment No. 1.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal,
jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ BinXue

    Bin Xue

    Chairman

September 9, 2024
Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
35 Trampines Street
92 Singapore 528880
Re:WEBUY GLOBAL LTD
Registration Statement on Form F-1
Filed August 16, 2024
File No. 333-281605
Dear Bin Xue:
            We have conducted a limited review of 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 August 16, 2024
Prospectus Summary
The Offering, page 9
1.Please revise your disclosure here and throughout your registration statement as
necessary to accurately reflect the conversion price of the shares issuable upon conversion
of the Convertible Note. In this regard, we note that your disclosure here reflects that the
conversion price will be 90% of the average of the 3 lowest daily VWAPs during the 20
trading days prior to the payment date selected by the selling shareholder. However, as
reflected in the Senior Secured Convertible Promissory Note dated July 25, 2025 filed as
Exhibit 10.2 to your Form 6-K filed July 30, 2024, and elsewhere in your prospectus, it
appears the conversion price is $0.213 subject to certain adjustments (e.g., stock splits and
dividends) and is not dependent on the market price of your outstanding shares. Further,
please file the Convertible Note as an exhibit to this registration statement.

September 9, 2024
Page 2
            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 Kate Beukenkamp at 202-551-3861 or Erin Jaskot at 202-551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Mengyi "Jason" Ye

CORRESP
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Webuy Global Ltd

April 26, 2024

VIA EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

Washington, DC 20549

Attn: Mr. Scott Anderegg

    Re:
    Webuy Global Ltd

    Registration Statement on Form F-1, as amended (File No. 333- 278744)

    Request for Acceleration of Effectiveness

Dear Mr. Anderegg:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Webuy Global Ltd 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 4:00 p.m., Eastern Time, on April 29, 2024, or as soon thereafter as practicable.

    Very truly yours,

    Webuy Global Ltd

    By:
    /s/ Bin Xue

    Name:
    Bin Xue

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
December 13, 2023
Bin Vincent Xue
Chief Executive Officer
Webuy Global LTD
35 Tampines Street 92
Singapore 528880
Re:Webuy Global LTD
Draft Registration Statment on Form F-1
Submitted December 8, 2023
CIK No. 0001946703
Dear Bin Vincent Xue:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours 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 Scott Anderegg at 202-551-3342 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
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webuy_corresp.htm

 VIA EDGAR

 September 27, 2023

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, NE

 Washington, D.C. 20549

 Attn: Ms. Kate Beukenkamp

   Re:

   Webuy Global Ltd

   File No. 333-271604

 Registration Statement on Form F-1, as amended

 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 (the “Securities Act”), EF Hutton, division of Benchmark Investments, LLC, acting as representative of the underwriters, hereby joins Webuy Global Ltd in requesting acceleration of the effective date of the above-referenced Registration Statement so that it will become effective on September 28, 2023, at 4:30 p.m. Eastern Time, or as soon thereafter as practicable.

 Pursuant to Rule 460 under the Securities Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated August 3, 2023, to selected dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

 The undersigned confirm that it has complied and will continue to comply with, and it has been informed or will be informed by participating dealers that it has 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,

 EF Hutton, division of Benchmark Investments, LLC

 By: /s/Sam Fleischman

 Name: Sam Fleischman

 Title:   Supervisory Principal

CORRESP
1
filename1.htm

webuy_corresp.htmWEBUY GLOBAL LTD

 September 27, 2023

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C., 20549

 Attn: Ms. Kate Beukenkamp

    Re:

   WEBUY GLOBAL LTD

   Registration Statement on Form F-1, as amended (File No. 333- 271604)

 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, WEBUY GLOBAL LTD hereby requests an acceleration of the effectiveness of the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become effective at 4:30 p.m., Eastern Time, on September 28, 2023, 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,

   WEBUY GLOBAL LTD

   By:

   /s/ Xue Bin

   Name:

   Xue Bin

   Title:

   Chief Executive Officer and Chairman

United States securities and exchange commission logo
May 9, 2023
Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
35 Tampines Street 92
Singapore 528880
Re:WEBUY GLOBAL LTD
Registration Statement on Form F-1
Filed May 3, 2023
File No. 333-271604
Dear Bin Xue:
            We have reviewed your 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.
Registration Statement on Form F-1 filed May 3, 2023
Capitalization, page 36
1.Please revise to include outstanding convertible notes payable in your capitalization table.
Dilution, page 37
2.We are reissuing comment 7 from our letter dated October 17, 2022.  Please include a
comparison of the public contribution under the proposed public offering and the effective
cash contribution of officers, directors, promoters and affiliated persons.  Refer to Item
9.E of Form 20-F.

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 May 9, 2023 Page 2
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
May 9, 2023
Page 2
Principal Shareholders, page 99
3.We note your response to prior comment 2, including that voting and dispositive power
over Wavemaker Pacific 3, L.P.'s investment decisions is determined by approval of a
majority of the three board members of this entity. Similarly, Rocket Internet Capital
Partners ii Scs's investment decisions are controlled by its five board members. Please
revise your disclosure to identify the natural persons comprising the board members of
each respective entity.
            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.
            You may contact Scott Stringer at 202-551-3272 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Mengyi Jason Ye

United States securities and exchange commission logo
March 3, 2023
Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
18 Tampines Industrial Crescent #04-03
Space@Tampines
Singapore 528605
Re:WEBUY GLOBAL LTD
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted February 17, 2023
CIK No. 0001946703
Dear Bin Xue:
            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
Prospectus Summary, page 2
1.We note your response to prior comment 1 and reissue in part. We note your revised
disclosure that you "are confident that these going concerns regarding [your] ability to
continue [your] business will be resolved over time and after this initial public offering as
[you] expand [your] presence in Southeast Asia." Please remove this revised disclosure
and explicitly disclose that your auditors have issued a going concern opinion on your
audited financial statements. Please discuss the uncertainties you face as noted in your
auditors opinion and discuss the consequences should you be unable to obtain additional

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 March 3, 2023 Page 2
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
March 3, 2023
Page 2
financing.
Principal Shareholders, page 107
2.We note your revisions to the Principal Shareholders table to include 5% or greater
shareholders. Please revise the footnotes to this table to identify the natural person(s) with
voting and/or investment control over the shares held by each of the entities named in
footnotes (1) - (6).
            You may contact Scott Stringer at 202-551-3272 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Mengyi Jason Ye

United States securities and exchange commission logo
January 26, 2023
Bin Xue
Chief Executive Officer
WEBUY GLOBAL LTD
18 Tampines Industrial Crescent #04-03
Space@Tampines
Singapore 528605
Re:WEBUY GLOBAL LTD
Amendment No. 1 to
Draft Registration Statement of Form F-1
Submitted January 6, 2023
CIK No. 0001946703
Dear Bin Xue:
            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
Prospectus Summary
Overview, page 3
1.We note your response to prior comment 2 and reissue. Please include the paragraph about
your sales and growth since inception and balance this disclosure by also discussing your
history of net losses for the relevant periods as well as the substantial doubt about your
ability to continue as a going concern. We note your disclosure under "Going Concern and
Capital Resources" on page 42.

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 January 26, 2023 Page 2
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
January 26, 2023
Page 2
2.We note your response to prior comment 11, including your revisions to page 66.
However, you continue to reference "marketing collaterals" on pages 3 and 71. For
consistency, please further revise your disclosure to reflect revisions made on page
66 regarding this term.
Business
Scalable Business Segments, page 70
3.We note your response to prior comment 13, including revisions to add a title to the
diagram provided here. Please further revise your disclosure to provide context for this
diagram within your operational activities, including a brief discussion of what this
diagram illustrates. For example, please briefly discuss which portions of the
technological divisions and structures represented (i.e., Customer APP, Group Leader
Web Portal, Merchant Web Portal, Backend Services, Technology Platform, Data
Platform & Algorithm, and Big Data (OLTP, OLAP)) are controlled by WeBuy and what
the inclusion of the logos of numerous other technology providers (e.g., Java, Spring and
Elastic) represents.
Leader and Customer Acquisition Cycle, page 72
4.We note your response to prior comment 15 as well as existing disclosure that states that
stores will display the WeBuy logo to increase awareness for your brand. Please further
revise this section to disclose whether these stores receive any monetary or other
compensation, in addition to attractive prices on fresh produce, for agreeing to sign on as
an affiliate of the WeBuy club.
Our Business Model
A. Groupbuy Model, page 74
5.We note your response to prior comment 16, including your statement that sales
commissions are earned by Group Leaders "through their work in promoting the Webuy
products to their community." Please briefly expand your discussion to provide additional
high-level detail regarding sales commissions. For example, please disclose whether all
Group Leaders receive sales commissions as a percentage of sales made by customers in
their community or upon achieving certain sales goals. Additionally, please disclose the
commission rates and quantify the sales commissions paid for the periods reflected in the
prospectus.

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 January 26, 2023 Page 3
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
January 26, 2023
Page 3
C. End-to-End Involvement in the Sale and Purchase Process
Our Customers, page 87
6.We note your response to prior comment 18 and revised disclosure on page 87. It appears
that "coins" and "assets" are analogous to your description of e-vouchers and sales
commissions, respectively, discussed on page 74 and referenced throughout your
disclosure. Please revise this section to make clear, if true, the relationship between these
two sets of terms (i.e., (i) coins and e-vouchers, and (ii) assets and sales commissions).
Note 2. Summary of Signification Accounting Policies
Revenue Recognition, page F-11
7.We note your response to comment 23.  Please revise your disclosure to clearly explain
the accounting and payment procedures surrounding the "Assets" you grant, similar to the
first paragraph of your response.
8.We note your response to comment 24.  The guidance in ASC 280-10-50-38 explicitly
states that ASC 280-10-50-40 applies to entities that have a single reportable segment.
You disclose on page 12 that you "offer a wide range of products on our platform,
including food and beverage, fresh produce, as well as lifestyle and other personal care
items."  Please disclose your revenues for each group of similar products and services.
Alternatively, if providing this disclosure is impracticable (which is expected to be rare),
please tell us the specific aspects of providing this disclosure that are impracticable and
explain in detail why each aspect is impracticable.  If your impracticability assertion for
one or more specific aspects surrounds excessive cost, please also demonstrate how you
determined the cost would be excessive.
9.Your disclosure on pages 74 and 87 indicates you offer e-vouchers and coins as shopping
perks that are redeemable in purchasing credits. Please explain to us how you account for
these perks and, to the extent significant, please expand your revenue recognition
accounting policy.
            You may contact Scott Stringer at 202-551-3272 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Mengyi Jason Ye

United States securities and exchange commission logo
October 17, 2022
Bin Xue
Chief Executive Officer and Chairman of the Board of Directors
WEBUY GLOBAL LTD
18 Tampines Industrial Crescent #04-03
Space@Tampines
Singapore 528605
Re:WEBUY GLOBAL LTD
Draft Registration Statement of Form F-1
Submitted September 21, 2022
CIK No. 0001946703
Dear Bin Xue:
            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 September 21, 2022
Prospectus Summary
Overview, page 3
1.Please revise your disclosure here and throughout your prospectus to make clear your
relationship with Group Leaders and Influencers, including whether these individuals are
employees of WeBuy or customers that receive rewards or other compensation for
engaging in certain business or customer activities. Please note our comment below
regarding disclosing the difference between Group Leaders and Influencers.

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 October 17, 2022 Page 2
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
October 17, 2022
Page 2
2.Please balance your disclosure in the second paragraph about your sales and growth since
inception by also disclosing your history of net losses for the relevant periods, as well as
the substantial doubt about your ability to continue as a going concern.
Our Business Model, page 4
3.We note your reference to both Group Leaders and Influencers in the diagram of your
business model on page 5. Please revise your disclosure in the prospectus summary and
throughout your filing to discuss the use of Influencers including, for example, how they
differ from Group Leaders, their role and activities within your business model and how
they are compensated or otherwise incentivized in their role.
4.In your diagram, you include text regarding "4a Drop Ship: Suppliers / sellers ship
products to WEBUY's GLs/users directly (*Launch in Q4)." Please revise your disclosure
to discuss the status of this service offering, including whether it was successfully
launched in the fourth quarter of your current fiscal year. If these activities have
commenced, please describe the role WeBuy plays in suppliers shipping products directly
to WeBuy Group Leaders and customers (e.g., technology, logistics or other supply chain
services). Additionally, please revise the diagram or disclosure, accordingly, to clarify the
meaning of "users," including whether users constitutes your customers or a different
category of individuals.
Risk Factors
Risks Related to our Business and Industry, page 11
5.We note that several of your risk factors on pages 20-22 discuss the significance of your
websites as integral to your business, including the statement that "[a]ll of your sales of
products are made online through our websites and mobile application, and the fulfillment
services we provide to customers are coordinated through our website and mobile
applications." However, the website you provide on page 9, www.webuysg.com, does not
appear to offer functionality for displaying products or customer sales and your disclosure
states that "[i]t is is included solely as an inactive textual reference." Please revise your
disclosure throughout your prospectus, including the Business section, to reflect the
significance of your websites to your business, including disclosing the websites.
Alternatively, please revise your risk factors to align with your business activities,
including the use of websites in conducting your business. We note the list of domain
names held by New Retail on page 81.
Risks Relating to this Offering and the Trading Market
Our management has broad discretion to determine how to use the funds..., page 27
6.Please expand your risk factor to explain in greater detail how management's broad
discretion to determine how to use the funds raised in the your initial public offering may
not improve your results of operations or enhance the market price of your ordinary
shares. We note that Item 105(b) of Regulation S-K asks registrants to concisely explain

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 Comapany NameWEBUY GLOBAL LTD
 October 17, 2022 Page 3
 FirstName LastNameBin Xue
WEBUY GLOBAL LTD
October 17, 2022
Page 3
how each risk affects the registrant or the securities being offered.
Dilution, page 36
7.Please include a comparison of the public contribution under the proposed public offering
and the effective cash contribution of officers, directors, promoters and affiliated persons.
Refer to Item 9.E of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Factors that Affect Operating Results, page 38
8.A key factor affecting your results and ability to generate revenue is the number and
volume of transactions completed by your customers.  Please explain how you track these
factors and what consideration you gave to disclosing any such statistical data or metrics
in the filing.  Refer to Item 5 of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Revenue, page 40
9.Please reconcile your statement here that you entered the Indonesia market in 2020 with
your statement on page 3 that your "official entry into the Indonesian market" was in
March 2022. Expand your disclosure, as necessary, to discuss the meaning of an official
entry versus your existing operations in Indonesia. We note that 16.4% of revenues were
derived from Indonesia for the fiscal year ended December 31, 2021.
Going Concern and Capital Resources, page 42
10.Please clearly disclose whether your working capital is sufficient for your present
requirements.  In doing so, include a more robust discussion of your material cash
requirements, capital requirements and operating expense obligations over the next twelve
months and in the long-term.  Refer to Item 5.B of Form 20-F.
Business
Overview, page 57
11.Please revise your disclosure to explain the meaning of and/or provide an example of
"marketing collaterals" used by Group Leaders to assist in you customer acquisitions
through offline roadshows.
B. Scalable Business Model
Emerging economies market, page 59
12.Please revise your disclosure to make clear the role of Warung in your business model,
including whether they serve as Group Leaders, suppliers of "group buy" goods sold to
customers, or some other role. We note that you state that Warung may account for up to

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 October 17, 2022 Page 4
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
October 17, 2022
Page 4
70% of the retail market in Indonesia but also that your "relations with our suppliers from
China gives us great value proposition to these Warung as prospective partners."
Scalable Business Segments, page 59
13.Please briefly provide context for the diagram provided on page 61 of this section. For
example, provide a title or disclosure stating what the diagram illustrates in the context of
this portion of your Business section.
C. Strong Client Acquisition and Retention, page 62
14.The two paragraphs under this subheading appear to be focused on your short video
review feature of your platform. Please revise this section to discuss how this portion of
your business relates to client acquisition and retention. Alternatively, please revise your
disclosure to provide these two paragraphs in an appropriate section of your Business
discussion.
Leader and Customer Acquisition Cycle, page 62
15.You discuss the benefits to physical stores to build relationships with WeBuy, including
signing on as an affiliate of the WeBuy club. We also note in your Use of Proceeds
section that you plan to use proceeds from the offering to establish the WeBuy club.
Please revise your disclosure to make clear the status of this aspect of your business
operations.
Our Business Model
A. Groupbuy Model, page 65
16.We note that customers may receive additional shopping perks in the form of e-vouchers
and sales commissions. Please revise your disclosure to explain whether these e-vouchers
are part of your product offering and available to all of your customers for purchase or are
a form of compensation to certain customers for engaging in business activities in
connection with your business model. If the latter applies, please discuss the relevant
business activities and how customers become eligible to receive e-vouchers.
Additionally, please expand your disclosure to discuss in greater detail the sales
commissions earned by customers, including what business activities customers engage in
to receive sales commissions.
17.Please expand your disclosure to discuss in greater detail how Group Leaders are
supported with "delivery services," including a description of who is providing delivery
services and your business arrangement(s) (e.g., contracts) with these entities as well as
whether GLs are receiving deliveries from these delivery services or using them to deliver
products to customers.

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 Comapany NameWEBUY GLOBAL LTD
 October 17, 2022 Page 5
 FirstName LastName
Bin Xue
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October 17, 2022
Page 5
C. End-to-End Involvement in the Sale and Purchase Process
Our Customers, page 78
18.Please expand your disclosure to explain in greater detail the meaning of "coins" that can
be used by customers to offset future purchase prices. Additionally, discuss how coins are
related, if at all, to the "Assets" granted to customers, which similarly allow holders to
offset future purchases as described in your Management's Discussion and Analysis on
page 78.
Principal Shareholders, page 98
19.We note the use of a footnote (3) below you principal shareholders tables. However, your
table reflects a reference to a footnote "1" in relation to your independent director
nominees. Please revise to provide an accurate footnote reference.
20.Please indicate whether your major shareholders have different voting rights, or an
appropriate negative statement in accordance with Item 7(A)(1)(c) of Form 20-F.
Consolidated Financial Statements
Consolidated Statements of Changes in Stockholders' Equity (Deficit), page F-5
21.Please explain in a footnote the nature and terms of your "Investment in Subsidiary".
 Also, tell us why this transaction resulted in an increase to accumulated deficit and an
increase in non-controlling interest.
Consolidated Statements of Cash Flows, page F-6
22.Please tell us how you determined the cash flows related to “increase in investment in
subsidiary” and “investment in subsidiaries by non-controlling interest” represent
investing activities, as opposed to financing activities. Refer to ASC 810-10-45-23 and
ASC 230-10-45-14(a) and 45-15(a).
Note 2. Summary of Signification Accounting Policies
Revenue Recognition, page F-11
23.You grant “Assets” to customers as commissions earned, which entitle the holders to
offset future purchases.  Such "Assets" are recorded in “Advances from customers” until
they are used.  Please explain your accounting for these "Assets", the guidance you relied
on, their nature, whether they are synonymous with points or loyalty rewards programs as
contemplated in ASC 606-10-55-41 through 55-49 regarding customer options to acquire
additional goods or service or consideration payable to a customer in ASC 606-10-32-25.
 If these “Assets” are akin to one of the aforementioned types, explain why you refer to
them as “Assets” and your consideration of the notion of breakage.  Also, explain how
"Advances from customers" differ from "Deferred revenue".  Please also clarify whether
the customers receiving commissions are your Group Leaders and/or other individuals and
explain any differences in your accounting for each type of recipient.

 FirstName LastNameBin Xue
 Comapany NameWEBUY GLOBAL LTD
 October 17, 2022 Page 6
 FirstName LastName
Bin Xue
WEBUY GLOBAL LTD
October 17, 2022
Page 6
24.Please disclose your revenues for each group of similar products and services.  Refer to
ASC 280-10-50-40.
Note 6. Intangible assets, page F-14
25.Please disclose the estimated remaining amortization expenses of your intangible assets
for the next five fiscal years in accordance with ASC 350-30-50-2.
General
26.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
27.Please tell us whether you anticipate being a controlled company under the Nasdaq listing
standards and, if so, whether you intend to utilize related exemptions to the  governance
rules under the listing standards. In this regard we note your "Voting Rights" disclosure on
page 10, the second paragraph of which suggests you may be a controlled company, as it
indicates that a currently unidentified shareholder will have the ability to control the
outcome of matters submitted to your shareholders for approval, including the election of
directors and the approval of change in control transactions. Please update your
disclosure, as necessary, throughout the prospectus to reflect controlled company status
and the use of goverance exemptions.
            You may contact Scott Stringer at 202-551-3272 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Mengyi Jason Ye