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                                                            December 5, 2024

Kam Choy Ho
Chief Executive Officer
TMD Energy Ltd
B-10-06, Block B, Plaza Mont Kiara
No. 2, Jalan Kiara, Mont Kiara
50480 Kuala Lumpur
Wilayah Persekutuan, West Malaysia

       Re: TMD Energy Ltd
           Amendment No. 3 to Draft Registration Statement on Form F-1
           Submitted November 14, 2024
           CIK No. 0002009714
Dear Kam Choy Ho:

     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. Unless we note otherwise, any references to prior comments are to
comments in
our August 2, 2024 letter.

Amendment No. 3 to Draft Registration Statement on Form F-1
Capitalization, page 50

1.     Please remove your proforma as adjusted (Full exercise of over-allotment
option)
       column. In addition, remove the similar column and related disclosures
in your
       dilution disclosure.
 December 5, 2024
Page 2
Dilution, page 51

2.     You appear to include deferred offering costs in your historical net
tangible book
       value of $17,212,343 as of June 30, 2024. Please revise to exclude such
costs from
       your net tangible book value.
Unaudited Condensed and Consolidated Statements of Cash Flows, page F-31

3.     Please tell us what the repayment to related party payables of
$7,426,919 for the June
       30, 2024 period represents, how it was calculated, and how it relates to
amounts
       disclosed on page F-42 and F-43.

       Please contact Robert Shapiro at 202-551-3273 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3222 with
any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
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