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United States securities and exchange commission logo





                              May 3, 2023

       Howard Doong, M.D.
       Chief Executive Officer
       ABVC BioPharma, Inc.
       44370 Old Warm Springs Blvd.
       Fremont, CA 94538

                                                        Re: ABVC BioPharma,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed April 24,
2023
                                                            File No. 333-271416

       Dear Howard Doong:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment. In our comment, 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 comment applies 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 this comment, we may have additional comments.

       Registration Statement on Form S-1 filed April 24, 2023

       Cover Page

   1.                                                   We note that you intend
to register "up to $3,175,000 shares" of common stock issuable
                                                        upon conversion of a
secured, convertible note at an initial conversion price of $1.05 per
                                                        share. Please revise to
disclose the number of shares being registered, rather than a dollar
                                                        figure.
               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.
 Howard Doong, M.D.
ABVC BioPharma, Inc.
May 3, 2023
Page 2

       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.

       Please contact Tyler Howes at 202-551-3370 or Alan Campbell at
202-551-4224 with
any questions.



                                                           Sincerely,
FirstName LastNameHoward Doong, M.D.
                                                           Division of
Corporation Finance
Comapany NameABVC BioPharma, Inc.
                                                           Office of Life
Sciences
May 3, 2023 Page 2
cc:       Louis Taubman, Esq.
FirstName LastName
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