July 31, 2024

Chew Kwang Yong
Chief Financial Officer
HomesToLife Ltd
6 Raffles Boulevard, #02-01/02
Marina Square, Singapore 039594

       Re: HomesToLife Ltd
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted July 17, 2024
           CIK No. 0002023153
Dear Chew Kwang Yong:

     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 June 28, 2024 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1
Use of Proceeds, page 33

1.     We note your revised disclosure and response pursuant to comment 4 and
reissue in part.
       Please state here, as you noted in your response, that you have not yet
identified specific
       assets or businesses to acquire.
Combined Financial Statements
Combined Statements of Operations, page F-4

2.     We read your response to prior comment 13. Please tell us and disclose
in a financial
       statement footnote the nature of the amounts included in the recovery
from over-accruals
       line item and the facts and circumstances resulting in the recovery from
over-accruals in
       each period presented. Also tell us:
           the nature and amounts of the related expenses originally accrued in
each period
 July 31, 2024
Page 2

           presented and the statement of operations line item(s) in which the
original expenses
           were included,
             why the recovery from over-accruals were not included in the same
line item(s) that
           the original expenses were included in, if true, and
             the GAAP literature you are relying upon for including the
recovery from over-
           accruals in other income, net.

       Please contact Valeria Franks at 202-551-7705 or Rufus Decker at
202-551-3769 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jenna Hough at 202-551-3063 or Lilyanna Peyser at 202-551-3222 with any
other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:   Jane Tam