United States securities and exchange commission logo





                               October 9, 2020

       Kevin Chen
       Chief Executive Officer
       Edoc Acquisition Corp.
       7612 Main Street Fishers
       Suite 200
       Victor, NY 14564

                                                        Re: Edoc Acquisition
Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed September 15,
2020
                                                            File No. 333-248819

       Dear Mr. Chen:

              We have reviewed your 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.

       Registration Statement on Form S-1 filed September 15, 2020

       Cover page

   1.                                                   We note your disclosure
on page 102 that holders of your Class B common stock will
                                                        have the right to elect
all of your directors prior to your initial business combination and
                                                        that holders of a
majority of your founder shares may remove a director for any reason.
                                                        Please revise your
cover page and risk factors section to disclose the respective voting
                                                        rights of your Class B
and Class A ordinary shares.
       Summary, page 1

   2.                                                   You disclose that
Xiaoping Becky Zhang is the sole managing member of your sponsor,
                                                        American Physicians
LLC. From disclosure on page 34, it appears that all
 Kevin Chen
Edoc Acquisition Corp.
October 9, 2020
Page 2
      2,875,000 founder shares were issued to your sponsor. At page 95, you
further disclose
      that your "initial shareholders, sponsor and [y]our executive officers
and directors, may be
      deemed to be [y]our 'promoters'    under Rule 405 of Regulation C. As all
founder shares
      were issued to the sponsor and Ms. Zhang is the sole managing member,
please also
      describe the business experience of Ms. Zhang relevant to your business
strategy. See
      also Item 404(c) of Regulation S-K.
Business Strategy, page 3

3.    Please revise to disclose how I-Bankers' activities under the business
combination
      marketing agreement are part of your business strategy. On page 132 you
disclose that you
      will engage I-Bankers as an advisor in connection with your business
combination, to
      assist in evaluating possible acquisition candidates, assist in holding
meetings with your
      shareholders to discuss the potential business combination and the target
business
      attributes, and introduce you to potential investors that are interested
in purchasing your
      securities in connection with your initial business combination, among
other activities.
        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.

       You may contact Myra Moosariparambil, Staff Accountant, at (202)
551-3796 or Craig
Arakawa, Accounting Branch Chief, at (202) 551-3650 if you have questions
regarding
comments on the financial statements and related matters. Please contact Kevin
Dougherty,
Staff Attorney, at (202) 551-3271 or Loan Lauren Nguyen, Legal Branch Chief, at
(202) 551-
3642 with any other questions.



                                                            Sincerely,
FirstName LastNameKevin Chen
                                                            Division of
Corporation Finance
Comapany NameEdoc Acquisition Corp.
                                                            Office of Energy &
Transportation
October 9, 2020 Page 2
cc:       Jessica Yuan, Esq.
FirstName LastName