SEC Staff Comments Letter (Nov. 3rd, 2004)

November 3, 2004 Brett R. Chapman, Esq. General Counsel WH Holdings (Cayman Islands) Ltd. P.O. Box 309GT Ugland House, South Church Street George Town, Grand Cayman, Cayman Islands Re: WH Holdings (Cayman Islands) Ltd. Registration Statement on Form S-1 File Number 333-119485 Dear Mr. Chapman: We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments.

Herbalife Correspondence (Nov. 9th, 2004)

VIA FACSIMILE AND EDGAR November 9, 2004 U.S. Securities and Exchange Commission Division of Corporation Finance Mail Stop 3-9 450 Fifth Street, N.W. Washington, D.C. 20549-0404 Attention: Jeffrey Riedler Re: WH Holdings (Cayman Islands) Ltd. Registration Statement on S-1 filed October 1, 2004 File No. 333-119485 Dear Mr. Riedler: On behalf of WH Holdings (Cayman Islands) Ltd., a Cayman Islands exempted limited liability company (the “ Company ”), we transmit herewith Amendment No. 2, to the Company’s Registration Statement on Form S-1, which was originally filed with the Securities and Exchange Commission on October 1, 2004 (the “ Registration Statement ”).

Herbalife Correspondence (Nov. 16th, 2004)

VIA HAND DELIVERY AND EDGAR November 16, 2004 U.S. Securities and Exchange Commission Division of Corporation Finance Mail Stop 3-9 450 Fifth Street, N.W. Washington, D.C. 20549-0404 Attention: Jeffrey Riedler Re: WH Holdings (Cayman Islands) Ltd. Registration Statement on S-1 filed October 1, 2004 File No. 333-119485 Dear Mr. Riedler: On behalf of WH Holdings (Cayman Islands) Ltd., a Cayman Islands exempted limited liability company (the " Company "), we transmit herewith Amendment No. 3 to the Company's Registration Statement on Form S-1 originally filed with the Securities and Exchange Commission on October 1, 2004 (the " Registration Statement ").

SEC Staff Comments Letter (Nov. 29th, 2004)

Dear Mr. Chapman: We have reviewed your amended filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.

Herbalife Correspondence (Dec. 2nd, 2004)

Dear Mr. Riedler: On behalf of Herbalife Ltd., a Cayman Islands exempted limited liability company formerly known as WH Holdings (Cayman Islands) Ltd. (the " Company "), we transmit herewith Amendment No. 4 to the Company's Registration Statement on Form S-1 originally filed with the Securities and Exchange Commission on October 1, 2004 (the " Registration Statement ").

SEC Staff Comments Letter (Dec. 7th, 2004)

Re: WH Holdings (Cayman Islands) Ltd. Amendment No. 4 to Registration Statement on Form S-1 File Number 333-119485 Dear Mr. Chapman: We have reviewed your amended filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.

Herbalife Correspondence (Dec. 10th, 2004)

Re: WH Holdings (Cayman Islands) Ltd. Registration Statement on S-1 filed October 1, 2004 File No. 333-119485 Dear Mr. Riedler: On behalf of Herbalife Ltd., f/k/a WH Holdings (Cayman Islands) Ltd., a Cayman Islands exempted limited liability company (the “ Company ”), we transmit herewith proposed changes to Amendment No. 4 to the Company’s Registration Statement on Form S-1 originally filed with the Securities and Exchange Commission on October 1, 2004 (the “ Registration Statement ”).

Herbalife Correspondence (Dec. 13th, 2004)

Re: Herbalife Ltd. Registration No. 333-119485 Dear Mr. Sir or Madam: In connection with the request for acceleration of Registration Statement of Herbalife Ltd. (the "Company") on Form S-1 (File No. 333-119485) transmitted to the Securities and Exchange Commission (the "SEC") on December 13, 2004, the Company hereby acknowledges:

Herbalife Correspondence (Dec. 14th, 2004)

Re: Herbalife Ltd. Registration Statement on S-1 filed October 1, 2004 File No. 333-119485 Dear Mr. Riedler: On behalf of Herbalife Ltd., f/k/a WH Holdings (Cayman Islands) Ltd., a Cayman Islands exempted limited liability company (the " Company "), we transmit herewith Amendment No. 5 to the Company's Registration Statement on Form S-1 originally filed with the Securities and Exchange Commission on October 1, 2004 (the " Registration Statement ").

SEC Staff Comments Letter (June 27th, 2007)

Re: Herbalife Ltd. Form 10-K for Fiscal Year Ended December 31, 2006 Filed February 27, 2007 File No. 001-32381 Dear Mr. Johnson: We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.

Herbalife Correspondence (Jul. 9th, 2007)

Dear Ms. Jenkins: Herbalife Ltd. (the “Company”, “we” or “our”) takes very seriously its responsibilities regarding the accuracy and completeness of the disclosures contained in its public filings. The Company appreciates Staff’s comments as well as the opportunity this process provides to improve the content of the Company’s public filings.

SEC Staff Comments Letter (Oct. 28th, 2008)

Re: Herbalife, Ltd. Form 10-K for Fiscal Year Ended December 31, 2007 Filed February 26, 2008 File No. 001-32381 Dear Mr. Goudis: We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.