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                               January 30, 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
                                                            Amendment No. 1 to
Form F-1 filed January 23, 2024
                                                            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.

       Amendment No. 1 to Form F-1

       Cover Page

   1.                                                   We reissue Comment 1 in
part. State whether any transfers of any type have been made to
                                                        date between the
holding company and its subsidiaries.
       Risks Related to Doing Business in China, page 3

   2.                                                   We reissue Comment 4 in
part. Please discuss the risk that the Chinese government may
                                                        exert more control over
offerings conducted overseas which could result in a material
                                                        change in 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. We note that
you added this disclosure on page 31 but not in this section.
 Steven Lee
SOS Ltd
January 30, 2024
Page 2



3.       We note your revised disclosure on page 48 in response to comment no.
5. Please revise
         this section to provide similar disclosure.
Cash and Asset Flows through Our Organization, page 9

4.       We reissue comment 6. We requested that you address more than just
dividends and
         distributions which you reference in the first sentence on page 9. Our
comment asked you
         to 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. Please
         revise or clarify that there have not been any other transfers, sales
or other transactions
         between your subsidiaries. If the dividends and distributions
referenced in your revised
         disclosure are the only inter party transfers, confirm that in your
response to this
         comment.
        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 30, 2024 Page 2                                       Office of Finance
FirstName LastName