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                             January 6, 2022

       Xiaowu He
       Chief Executive Officer
       Scienjoy Holding Corp
       3rd Floor, JIA No.34, Shenggu Nanli
       Chaoyang District, Beijing 100029
       China

                                                        Re: Scienjoy Holding
Corp
                                                            Amendment No. 3 to
Registration Statement on Form F-3
                                                            Filed December 27,
2021
                                                            File No. 333-259951

       Dear Mr. He:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
December 9, 2021 letter.

       Amendment No. 3 to Registration Statement on Form F-3

       Cover Page

   1.                                                   Please disclose here
and in the prospectus summary whether your auditor is subject to the
                                                        determinations
announced by the PCAOB on December 16, 2021 and whether and how
                                                        the Holding Foreign
Companies Accountable Act and related regulations will affect your
                                                        company.
   2.                                                   We note your risk
factors on pages 20 and 26, which discuss your reliance on dividends
                                                        and other distributions
paid by your PRC subsidiaries, and that you intend to retain most,
                                                        if not all, of your
available funds and future earnings and do not expect to pay dividends
 Xiaowu He
Scienjoy Holding Corp
January 6, 2022
Page 2
      in the foreseeable future after this offering. We also note your
disclosure on page 51,
      which states,    We are a holding company incorporated in the British
Virgin Islands and
      we gain substantial income by way of dividends paid to us from our PRC
      subsidiaries.    Please expand your disclosure on the prospectus cover
page to provide a
      description of how cash is transferred through your organization and
state whether any
      transfers, dividends, or distributions have been made to date. Similarly,
please expand
      your disclosure in the prospectus summary to provide a clear description
of how cash is
      transferred through your organization. Quantify any cash flows and
transfers of other
      assets by type that have occurred between you and your subsidiaries, and
the direction of
      the transfer. Quantify any dividends or distributions that a subsidiary
has made to you and
      which entity made such transfer, and their tax consequences. Similarly
quantify dividends
      or distributions made to U.S. investors, the source, and their tax
consequences. Your
      disclosure should make clear if no transfers, dividends, or distributions
have been made to
      date. Describe any restrictions on foreign exchange and your ability to
transfer cash
      between entities, across borders, and to U.S. investors. Describe any
restrictions and
      limitations on your ability to distribute earnings from your businesses
to the parent
      company and U.S. investors.
Risks Related to Doing Business in China, page 5

3.    Please revise here and in Risk Factors on page 16 to clarify that the
Chinese
      government may intervene or influence your operations at any time.
Risk Factors
Our shares may be delisted and prohibited from being traded under the Holding
Foreign
Companies Accountable Act..., page 17

4.    Please update your disclosure to reflect that the PCAOB has issued its
report notifying the
      Commission of its determination that it is unable to inspect or
investigate completely
      accounting firms headquartered in mainland China or Hong Kong.
5.    Please revise to include a discussion of the amendments adopted by the
SEC to finalize
      rules relating to the Holding Foreign Companies Accountable Act.

      Please contact Matthew Derby, Staff Attorney, at (202) 551-3334 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.



                                                           Sincerely,
FirstName LastNameXiaowu He
                                                           Division of
Corporation Finance
Comapany NameScienjoy Holding Corp
                                                           Office of Technology
January 6, 2022 Page 2
cc:       Lan Lou
FirstName LastName