TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo August 19, 2022 Erqi Wang Chief Executive Officer Jin Medical International Ltd. No. 33 Lingxiang Road, Wujin District Changzhou City, Jiangsu Province People s Republic of China Re: Jin Medical International Ltd. Amendment No. 5 to Registration Statement on Form F-1 Filed August 10, 2022 File No. 333-259767 Dear Mr. Wang: 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 July 26, 2022 letter. Amendment No. 5 to Form S-1 filed August 10, 2022 General 1. We note your response to prior comment 1 and reissue in part. Any references to control or economic benefits that accrued to you because of the VIE should be limited to and clearly describe the conditions you met for consolidation of the VIE under U.S. GAAP and your disclosure should clarify that, for accounting purposes, you were the primary beneficiary. For example only, we note that your disclosure on pages F-8 and F-39 do not clarify that the control or economic benefits you receive from the VIE are "for accounting purposes" only. Erqi Wang Jin Medical International Ltd. August 19, 2022 Page 2 You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Please contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions. Sincerely, FirstName LastNameErqi Wang Division of Corporation Finance Comapany NameJin Medical International Ltd. Office of Life Sciences August 19, 2022 Page 2 cc: Ying Li, Esq. FirstName LastName