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                            June 24, 2020

       Gang Lai
       Chief Executive Officer
       Universe Pharmaceuticals Inc.
       265 Jingjiu Avenue
       Jingii Jishu Kaifa District
       Jiangxi, China

                                                        Re: Universe
Pharmaceuticals Inc.
                                                            Draft Registration
Statement on Form F-1/A
                                                            Amended June 12,
2020
                                                            CIK 0001809616

       Dear Mr. Lai:

               We have reviewed your amended draft registration statement and
have the following
       comment. Please respond to this letter by providing the requested
information and either
       submitting an amended draft registration statement or publicly filing
your registration statement
       on EDGAR. If you do not believe our comment applies to your facts and
circumstances or do
       not believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       DRS/A Filed June 12, 2020

       Internal Controls, page 25

   1.                                                   Please expand your risk
factor disclosure to describe the remedial measures you have
                                                        already implemented and
to state the time period during which you expect to hire the
                                                        accounting staff needed
to remedy the material weakness.
 Gang Lai
Universe Pharmaceuticals Inc.
June 24, 2020
Page 2

       You may contact Michael Fay at 202-551-3812 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Paul Fischer at 202-551-3415 or Celeste M. Murphy at 202-551-3257 with any
other questions.



                                                         Sincerely,
FirstName LastNameGang Lai
                                                         Division of
Corporation Finance
Comapany NameUniverse Pharmaceuticals Inc.
                                                         Office of Life
Sciences
June 24, 2020 Page 2
cc:       Ying Li, Esq.
FirstName LastName