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                              January 4, 2024

       Steven Lee
       Chief Financial Officer
       SOS Ltd
       Building 6, East Seaview Park, 298 Haijing Road, Yinzhu Street
       West Coast New District, Qingdao City, Shandong Province 266400
       People   s Republic of China

                                                        Re: SOS Ltd
                                                            Form F-1 filed
December 12, 2023
                                                            File No. 333-276006

       Dear Steven Lee:

              We have conducted a limited review of 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 December 12, 2023

       Cover Page

   1.                                                   Provide a description
of how cash is transferred through your organization. State whether
                                                        any transfers,
dividends, or distributions have been made to date between the holding
                                                        company and its
subsidiaries, or to investors, and quantify the amounts where applicable.
                                                        Provide
cross-references to the consolidated financial statements.
   2.                                                   Tell us whether any
investors have entered into agreements to purchase securities in this
                                                        offering.
       About this Prospectus, page ii

   3.                                                   Reference is made to
the last sentence on page ii and the eighth bullet on page iii. Clearly
                                                        disclose how you will
refer to the holding company, subsidiaries and other entities when
                                                        providing the
disclosure throughout the document so that it is clear to investors which
 Steven Lee
FirstName
SOS Ltd LastNameSteven Lee
Comapany
January    NameSOS Ltd
        4, 2024
January
Page 2 4, 2024 Page 2
FirstName LastName
         entity the disclosure is referencing and which subsidiaries or
entities are conducting the
         business operations. Refrain from using terms such as    we    or
our    when describing
         activities or functions of subsidiaries.
Prospectus Summary
Summary of Risk Factors
Risks Related to Doing Business in China, page 3

4.       In your summary of risk factors, we note your disclosure of some of
the risks that your
         corporate structure and being based in or having the majority of the
company   s operations
         in China poses to investors. Specifically discuss risks arising from
the legal system in
         China, including risks and uncertainties regarding the enforcement of
laws and that rules
         and regulations in China can change quickly with little advance
notice; and the risk that
         the Chinese government may intervene or influence your operations at
any time, or may
         exert more control over offerings conducted overseas and/or foreign
investment in China-
         based issuers, which could result in a material change in your
operations and/or the value
         of the securities you are registering for sale. Acknowledge any risks
that any actions by
         the Chinese government to exert more oversight and control over
offerings that are
         conducted overseas and/or foreign investment in China-based issuers
could significantly
         limit or completely hinder your ability to offer or continue to offer
securities to investors
         and cause the value of such securities to significantly decline or be
worthless.

5.       State affirmatively whether you have received all requisite
permissions or approvals and
         whether any permissions or approvals have been denied. Please also
describe the
         consequences to you and your investors if you, your subsidiaries: (i)
do not receive or
         maintain such permissions or approvals, (ii) inadvertently conclude
that such permissions
         or approvals are not required, or (iii) applicable laws, regulations,
or interpretations
         change and you are required to obtain such permissions or approvals in
the future.
Cash and Asset Flows through Our Organization, page 8

6.       In the final paragraph on page 8, quantify any cash flows and
transfers of other assets by
         type that have occurred between the holding company and its
subsidiaries, and
         the direction of transfer.
Risk Factors
In light of recent events indicating greater oversight by the CAC, over data
security..., page 31

7.       Reference is made to the penultimate paragraph on page 32. Please
revise your disclosure
         to explain how this oversight impacts your offering and to what extent
you believe that
         you are compliant with such regulation.
Company History and Structure, page 60

8.       Reference is made to the third paragraph on page 60 and elsewhere in
the
 Steven Lee
SOS Ltd
January 4, 2024
Page 3
         prospectus where you state, "As of the date of this prospectus, our
current corporate
         structure does not contain any VIE in mainland China and neither we
nor our subsidiaries
         has intention establishing any VIEs in mainland China in the future."
We note in the
         second paragraph on page 60 you state that you own YBT, "which
controls its variable
         interest entity, SOS Information Technology Co., Ltd (   SOS
Information   )." We also note
         from the second paragraph on page 61 that SOS Information Technology
Co.,
         Ltd. appears to have been sold. Finally, we note the final paragraph
on page 8 where you
         refer to VIE agreements. Please reconcile the disclosure throughout
the prospectus and
         confirm that the company's subsidiaries do not operate through VIE
contracts. Revise
         your disclosure, in this section and throughout, to discuss all
instances where you rely on
         contractual relationships or variable interests to exert control over
your operating
         subsidiaries in mainland China, or in Hong Kong. Make conforming
changes to your
         disclosure in the forepart.
        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 Todd Schiffman at 202-551-3491 or Christian Windsor at
202-551-3419
with any other questions.



FirstName LastNameSteven Lee                                  Sincerely,
Comapany NameSOS Ltd
                                                              Division of
Corporation Finance
January 4, 2024 Page 3                                        Office of Finance
FirstName LastName