CORRESP


		1290 AVENUE OF THE AMERICAS NEW YORK, NY 10104-0050 TELEPHONE: 212.468.8000 FACSIMILE: 212.468.7900 WWW.MOFO.COM		morrison & foerster llp new york, san francisco, los angeles, palo alto, san diego, washington, d.c. northern virginia, denver, sacramento, walnut creek tokyo, london, beijing, shanghai, hong kong, singapore, brussels


May 28, 2009		Writer’s Direct Contact
		212.468.8025
		mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.
Legal Branch Chief
United States Securities and Exchange Commission
Mail Stop 7010
Washington, D.C. 20549-7010


Re:		Asia Pacific Wire & Cable Corporation Limited
		Post Effective Amendment No. 2 to
		Registration Statement on Form F-1
		Filed on May 13, 2009
		File No. 333-153796

Dear Mr. Ingram:

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

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

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

Very truly yours,

Michael J. Hagan


cc:		Mr. Yuan Chun Tang
		Jessica Kane, Esq.


		1290 AVENUE OF THE AMERICAS NEW YORK, NY 10104-0050 TELEPHONE: 212.468.8000 FACSIMILE: 212.468.7900 WWW.MOFO.COM		morrison & foerster llp new york, san francisco, los angeles, palo alto, san diego, washington, d.c. northern virginia, denver, sacramento, walnut creek tokyo, london, beijing, shanghai, hong kong, singapore, brussels


July 7, 2009		Writer’s Direct Contact
		212.468.8025
		mhagan@mofo.com

By Telefacsimile and Mail

Jay Ingram, Esq.
Legal Branch Chief
United States Securities and Exchange Commission
100 F Street, N.E., Mail Stop 7010
Washington, D.C. 20549


Re:		Asia Pacific Wire & Cable Corporation Limited (the “Company”)
		Post Effective Amendment No. 2 to
		Registration Statement on Form F-1
		Filed on May 13, 2009
		File No. 333-153796

Dear Mr. Ingram:

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

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

Mr. Jay Ingram
July 7, 2009
Page Two

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

Very truly yours,

Michael J. Hagan


cc:		Mr. Yuan Chun Tang
		Jessica Kane, Esq.