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United States securities and exchange commission logo





                             February 2, 2024

       Koon Kiat Sze
       Chief Executive Officer
       SKK Holdings Limited
       27 First Lok Yang Road
       Singapore 629735

                                                        Re: SKK Holdings
Limited
                                                            Registration
Statement on Form F-1
                                                            Filed January 29,
2024
                                                            File No. 333-276744

       Dear Koon Kiat Sze:

                                                        We have reviewed your
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.

       Form F-1 filed January 29, 2024

       Cover Page

   1.                                                   We note your response
to prior comment 1. Please disclose on the cover page and under
                                                        Risk Factors on page
26, that selling shareholders are also offering 1,647,999 shares for
                                                        resale.
       Exhibit 21.1

   2.                                                   We note the consent
from your auditors dated January 29, 2024, that refers to the auditor's
                                                        report dated September
30, 2023. Please revise to include a consent that refers to the
                                                        actual auditor's report
date of September 30, 2023, except for Notes 1 and 11, as to which
                                                        the date is January 8,
2024.
 Koon Kiat Sze
FirstName LastNameKoon   Kiat Sze
SKK Holdings  Limited
Comapany2,NameSKK
February   2024      Holdings Limited
February
Page 2 2, 2024 Page 2
FirstName LastName
Exhibit Index

3.       We note that you intend to use a portion of the net proceeds to repay
interest-free loans
         from Ms. Liao. Please file as an exhibit your debt agreements with Ms.
Liao. See Item
         601(b)(10)(ii)(A) of Regulation S-K. Also describe these loans under
Related Party
         Transactions.
4.       Please file as exhibits any material agreements relating to your bank
borrowings. See
         Item 601(b)(10)(i)(A) of Regulation S-K.
5.       We note your statement on page 61 that you have presented information
and data from an
         industry report commissioned by you from Frost & Sullivan. Please file
a consent as an
         exhibit to the registration statement pursuant to Rule 436 of the
Securities Act.
        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 Babette Cooper at 202-551-3396 or Isaac Esquivel at
202-551-3395 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713
with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Real
Estate & Construction
cc:      David L. Ficksman
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