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United States securities and exchange commission logo





                           December 20, 2021

       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. 1 to
                                                            Registration
Statement on Form F-1
                                                            Filed December 10,
2021
                                                            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
November 16, 2021 letter.

       Form F-1A filed December 10, 2021

       Cover Page

   1.                                                   We note your response
to our prior comment 1. Please provide a description on the cover
                                                        page of how cash is
transferred through your organization and disclosure regarding your
                                                        intentions to
distribute earnings or settle amounts owed under the VIE agreements.
 Erqi Wang
FirstName
Jin MedicalLastNameErqi   Wang
            International Ltd.
Comapany20,
December   NameJin
              2021 Medical International Ltd.
December
Page 2    20, 2021 Page 2
FirstName LastName
Prospectus Summary, page 1

2.       We note your response to our prior comment 2. Please revise further to
replace all
         references to "your" VIE business operations with "the" VIE in the
Summary. For
         example, we refer to two references on page 2.
3.       We note your response to our prior comment 6. Please provide a clearer
description of
         how cash is transferred through your organization as depicted in the
organizational chart
         on page 1.
4.       We note your revised disclosure in response to our prior comment 10.
Please also provide
         a roll-forward of the investment in subsidiaries and VIE line item for
the fiscal year 2019.
Financial Statements, page F-1

5.       We note your audited financial statements are older than 12 months.
Please explain your
         consideration of Item 8.A.4 of Form 20-F and the corresponding
instructions which
         indicates that, in the case of an initial public offering, audited
financial statements should
         generally not be older than 12 months at the time of filing. Please
note that audited
         financial statements not older than 15 months may be permitted if you
are able to
         represent the following:
                The company is not required to comply with the 12 month
requirement for the age of
         financial statements in any other jurisdiction outside the United
States; and
                Complying with the 12 month requirement is impracticable or
involves undue
         hardship.
         If you meet the above criteria, please provide a representation from
management which
         indicates you meet the criteria and file that representation as an
exhibit to your registration
         statement. If you do not meet the criteria, please provide updated
audited financial
         statements and related disclosures.
 Erqi Wang
FirstName
Jin MedicalLastNameErqi   Wang
            International Ltd.
Comapany20,
December   NameJin
              2021 Medical International Ltd.
December
Page 3    20, 2021 Page 3
FirstName LastName
Note 12 Shareholders' Equity, page F-33

6.       We note that during the years ended September 30, 2020 and 2019, the
Company
         advanced cash to related parties that are controlled by the Company
s major shareholder,
         Mr. Wang. Please further explain the business purposes for these
advances and, with
         reference to the appropriate authoritative literature, explain why you
accounted for the
         forgiveness of these advances as a return of capital rather than as an
expense. Specifically
         address why, given the fact that Mr. Wang is the Company's CEO, the
forgiveness of the
         advances should not be recognized as compensation.

       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,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences
cc:      Ying Li, Esq.
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