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                              July 27, 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. 5 to
Registration Statement on Form F-3
                                                            Filed June 28, 2022
                                                            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
March 28, 2022 letter.

       Amendment No. 5 to Registration Statement on Form F-3

       Cover Page

   1.                                                   We note your response
to prior comment 2. Please revise to provide a cross-references to
                                                        the condensed
consolidating schedule and the consolidated financial statements.
       Select Condensed Financial Statements on Consolidated VIEs, page 10

   2.                                                   Please revise the
heading for each table presented to indicate these are consolidating
                                                        financial statements
rather than consolidated financial statements.
   3.                                                   You disclose that
Scienjoy Holding Corporation records its investments in its subsidiaries
 Xiaowu He
Scienjoy Holding Corp
July 27, 2022
Page 2
      under the equity method of accounting. Please revise your disclosures in
this section to
      clarify that you control and receives the economic benefits of the VIE
s business
      operations through contractual agreements between the VIE and your Wholly
Foreign-
      Owned Enterprises (WFOEs) and that those agreements are designed to
provide your
      WFOEs with the power, rights, and obligations equivalent in all material
respects to those
      it would possess as the principal equity holder of the VIEs. Please
refrain from implying
      that the contractual agreements are equivalent to equity ownership in the
business of the
      VIEs. Any references to control or benefits that accrue to you because of
the VIE should
      be limited to a clear description of the conditions you have satisfied
for consolidation of
      the VIE under U.S. GAAP.
4.    We note that on June 1, 2022, through your wholly-owned subsidiary, WXZJ,
entered into
      a series of contractual arrangements with Sixiang Qiyuan and its
shareholders, thereby in
      substance obtained control over all equity shares, risks and economic
benefits of Xiuli
      (Zhejiang) Culture Technology Co., Ltd., Leku (Zhejiang) Culture
Technology Co., Ltd.,
      Haifan (Zhejiang) Culture Technology Co., Ltd., Xiangfeng (Zhejiang)
Culture
      Technology Co., Ltd. and Hongren (Zhejiang) Culture Technology Co., Ltd.
Please revise
      your disclosures to clarify whether these entities were in existences as
of December 31,
      2021. In this respect, the Parent and WFOE and Subsidiaries should not
show any
      investment or share of income/(loss) from VIEs until commencement of the
contractual
      arrangements with the VIEs.
General

5.    We note that your definition of China or PRC, incorporated by reference
from your Form
      20-F filed May 16, 2022, excludes Hong Kong and Macau. Please revise your
Form F-3
      to include a definition of China or PRC that removes these exclusions.
Clarify that all the
      legal and operational risks associated with being based in and having
operations in the
      PRC also apply to operations in Hong Kong and Macau.
      You may 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
July 27, 2022 Page 2
cc:       Lan Lou
FirstName LastName