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                            March 7, 2023

       Li Peng Leck
       Executive Chairwoman and Executive Director
       Davis Commodities Limited
       10 Bukit Batok Crescent
       #10-01, The Spire
       Singapore 658079

                                                        Re: Davis Commodities
Limited
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted February
28, 2023
                                                            CIK No. 0001949478

       Dear Li Peng Leck:

             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, filed
February 28, 2023

       Use of Proceeds, page 33

   1.                                                   We note your response
to comment 2 and reissue in part. Please also include the interest
                                                        rate and maturity of
the Maxwill Foodlink bank loans. Refer to Item 3.C.4 of Form 20-F,
                                                        incorporated by Item
4.a of Form F-1.
       Exhibits

   2.                                                   We note that in
previous versions of the registration statement you had included an
                                                        opinion from Raja &
Tann Singapore LLP regarding certain Singapore law matters, but
                                                        these entries have
since been removed. However, Raja & Tann Singapore LLP continues
 Li Peng Leck
Davis Commodities Limited
March 7, 2023
Page 2
      to provide advice on page 32 and is listed in the Legal Matters section
on page 147. Please
      revise to provide a consent for this information or clarify this
discrepancy.
       You may contact Patrick Kuhn at 202-551-3308 or Theresa Brillant at
202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Mara Ransom at 202-551-3264 with
any other
questions.



                                                           Sincerely,
FirstName LastNameLi Peng Leck
                                                           Division of
Corporation Finance
Comapany NameDavis Commodities Limited
                                                           Office of Trade &
Services
March 7, 2023 Page 2
cc:       Ying Li
FirstName LastName