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                               April 30, 2020

       Jinlong Yang
       Chief Executive Officer
       MingZhu Logistics Holdings Limited
       27F, Yantian Modern Industry Service Center
       No. 3018 Shayan Road, Yantian District
       Shenzhen, Guangdong, China 518081

                                                        Re: MingZhu Logistics
Holdings Limited
                                                            Amendment No. 4 to
                                                            Registration
Statement on Form F-1
                                                            Filed April 23,
2020
                                                            File No. 333-233992

       Dear Mr. Yang:

             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.

       Form F-1/A filed April 23, 2020

       Risk Factors, page 8

   1.                                                   Please revise to
provide risk factor disclosure regarding the limited ability of U.S.
                                                        regulators to conduct
investigations and inspections within China.
 Jinlong Yang
FirstNameLogistics Holdings Yang
MingZhu LastNameJinlong Limited
Comapany NameMingZhu Logistics Holdings Limited
April 30, 2020
Page 30,
April 2 2020 Page 2
FirstName LastName
        You may contact Amy Geddes, Staff Accountant, at (202) 551-3304 or Lyn
Shenk,
Accounting Branch Chief, at (202) 551-3380 if you have questions regarding
comments on the
financial statements and related matters. Please contact Karina Dorin, Staff
Attorney, at (202)
551-3763 or Laura Nicholson, Special Counsel, at (202) 551-3584 with any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation
cc:      Jonathan Deblinger