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                                                           January 2, 2020

Yongsheng Liu
Chief Executive Officer
Wealthbridge Acquisition Limited
Flat A, 6/F, Block A
Tonnochy Towers
No. 272 Jaffe Road
Wanchai, Hong Kong

       Re: Wealthbridge Acquisition Limited
           Preliminary Proxy Statement on Schedule 14A
           Filed December 6, 2019
           File No. 001-38799

Dear Mr. Liu:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A

Summary of the Proxy Statement, page 8

1.    Please provide organizational charts of Wealthbridge and Scienjoy before
and after the
      business combination to clarify the current ownership of Scienjoy and the
ownership of
      the company following the transaction. Disclose that you expect to be a
controlled
      company under the Nasdaq Stock Market Rules because Lavacano will control
more than
      50% of the voting power of your outstanding capital stock. Also, disclose
that if you are
      deemed to be a foreign private issuer under Rule 3b-4 of the Exchange Act
following the
      transaction, you plan to adopt a dual-class share structure that will
result in further
      concentration of Lavacano's control over the company. Provide
cross-references to the
      corresponding risk factors on pages 56 and 57, as well as a new risk
factor that addresses
      the disclosure and reporting requirements (e.g., no requirement to comply
with the proxy
 Yongsheng Liu
FirstName LastNameYongsheng Liu
Wealthbridge Acquisition Limited
Comapany2020
January 2, NameWealthbridge Acquisition Limited
Page 2
January 2, 2020 Page 2
FirstName LastName
         rules) and the exemptions from certain Nasdaq corporate governance
rules that are
         available to a foreign private issuer and whether you intend to use
them.
2.       You state that the Share Exchange Agreement provides that the minimum
remaining
         amount in your trust account is no less than $10,000,000 after giving
effect to payments to
         redeeming shareholders. Please disclose the maximum redemption amount
that you have
         calculated for the purpose of complying with such provision, and
describe what may
         happen if shareholder redemptions exceed such amount. In this regard,
you disclose on
         page 108 that you may need to obtain additional equity or debt
financing if you become
         obligated to redeem a significant number of your public shares upon
completion of the
         business combination.
Risk Factors, page 17

3.       You disclose that Scienjoy's business objective includes expanding its
business into
         overseas markets in Southeast Asia, the Middle East, and South
America. Please provide
         a risk factor addressing the material business, regulatory, and
economic risks in expanding
         its business outside China. Also, briefly explain the nature and scope
of the Chinese
         government's Belt and Road Initiative and the risks and limitations
related to the
         company's plan to align its geographic expansion strategy with such
initiative.
4.       To the extent your Second Amended and Restated Memorandum and Articles
of
         Association will contain anti-takeover provisions that materially
limit the rights of holders
         of your ordinary shares, please provide a risk factor that describes
those limitations. In
         this regard, we note your existing memorandum and articles of
association provide for the
         separation of your board of directors into two classes.
Scienjoy relies on its mobile application and PC application to provide
services . . ., page 29

5.       You disclose that the Showself Live Streaming mobile application,
which you
         characterize as Scienjoy's most popular platform in terms of
registered users and revenue,
         was once removed by Apple's App Store for unknown reasons and that
such incident
         caused a significant decrease in the number of downloads and had a
material adverse
         impact on Scienjoy's business and results of operations. Please
contextualize this
         disclosure by providing the date of removal and length of the
suspension. To the extent
         material, disclose the quantitative financial impact on the company.
Key performance metrics used by Scienjoy, such as QAUs, paying users, ARPPU and
paying
ratio, may overstate the number . . ., page 32

6.       You state that each of your three primary platforms has its own mobile
application.
         Please discuss whether registered users are required to separately
register for each
         platform and, if so, how this impacts the total number of registered
users, active users and
         paying users and whether these users are counted more than once for
purposes of
         calculating these metrics. To the extent that a user is registered or
has been active on
         more than one platform, please disclose how you measure unique users.
 Yongsheng Liu
FirstName LastNameYongsheng Liu
Wealthbridge Acquisition Limited
Comapany2020
January 2, NameWealthbridge Acquisition Limited
Page 3
January 2, 2020 Page 3
FirstName LastName
The Business Combination Proposal
Wealthbridge's Board's Reasons for the Approval of the Business Combination,
page 70

7.       You state that no reports as to the valuation of Scienjoy were
produced by any of your
         advisors. You, however, also state that your board of directors
received information from
         your legal and financial advisors prior to reaching the decision to
approve the Share
         Exchange Agreement and the transaction. Please explain why the
information that you
         received from your financial advisor does not qualify as a report,
opinion, or appraisal that
         is materially related to the transaction. Refer to Item 14(b)(6) of
Schedule 14A and Item
         1015(b) of Regulation M-A.
8.       You disclose that your management team and board of directors
recommended approval
         of the business combination, in part, because Scienjoy compares
favorably to three
         publicly traded Chinese live streaming platforms (HUYA, DouYu, and YY)
in terms of
         user scale and economics and that the pro forma equity market value of
the post-
         combination company, assuming no redemptions, will represent a
substantial discount to
         the equity market values of HUYA and DouYu. Please disclose whether
the board also
         considered the differences between Scienjoy and HUYA and DouYu in
connection with
         this analysis. For example, we note that HUYA and DouYu are companies
with greater
         revenue and a greater number of registered users, active users, and
paying users. We also
         note that HUYA and DouYu are primarily focused on the game live
streaming market,
         which may not necessarily be comparable to the show live streaming
market.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
Scienjoy Inc.
Key Factors Affecting Scienjoy's Results of Operations, page 130

9.       You stress the importance of user retention and engagement to
Scienjoy's business. Please
         tell us whether management of Scienjoy measures the operating
performance of the
         business in terms of active user retention and/or engagement, such as
average daily time
         spent on the platforms. If so, please provide those metrics for each
period presented and
         describe how they are calculated.
Revenue, page 133

10.      Please tell us why you do not provide revenue recognized from each of
your three primary
         platforms (i.e., Showself Live, Lehai Live, and Haixiu Live). Consider
disclosing the total
         number of paying users and by each of these three platforms.
Revenue Recognition, page 138

11.      You disclose that in the case of time-based virtual items, live
streaming revenue is
         recognized over the fixed period on a straight line basis. Please
disclose the fixed period
         or term. In addition, describe the nature or type of virtual items
that are time-based.
         Explain why recognizing revenue on a straight-line basis is
appropriate. Please also
 Yongsheng Liu
FirstName LastNameYongsheng Liu
Wealthbridge Acquisition Limited
Comapany2020
January 2, NameWealthbridge Acquisition Limited
Page 4
January 2, 2020 Page 4
FirstName LastName
         address the application of ASC 606 upon adoption. We refer you to ASC
606-10-25-27
         and 30.
12.      Please clarify the definition of "recharge" to describe when virtual
currency
         are purchased. Clarify how you account for any fees paid to or
retained by third-party
         platforms or distributors. Provide support for how each fee or charge
is presented and
         indicate why these fees are not reported as a reduction of revenue. In
addition, describe
         how you account for virtual currency purchased in advance and resold
by sale agents.
         Describe the payment terms of distributor receivables and describe
incentives or
         concessions provided. In this regard, we note that distributor
receivables are significant.
Liquidity and Capital Resources, page 141

13.      You disclose that as of June 30, 2019, Scienjoy had RMB93.617 million
in cash and cash
         equivalents that was deposited with major financial institutions
located in the PRC.
         Please disclose the material amounts of cash and short-term
investments disaggregated by
         currency denomination as of the most recent balance sheet date in each
jurisdiction in
         which your affiliated entities are domiciled. For entities within
China, disclose material
         amounts of cash held by VIEs separately from the amount of cash held
by other entities.
         In addition, please disclose the amount of cash and cash equivalents
held at the third party
         platform fund accounts. Tell us how you assess credit risk for these
accounts.
Directors, Executive Officers, Executive Compensation and Corporate Governance
Directors and Executive Officers After the Business Combination, page 156

14.      For each director, please briefly discuss the specific experience,
qualifications, attributes
         or skills that led to the conclusion that the person should serve as a
director in light of the
         business and structure of the post-combination company.
Certain Transactions, page 160

15.      Please clarify that Jining Li's relationship with Keen Nice
Communications and Star Jet
         Co. is the basis on which those parties are deemed to be related
parties.
ORGANIZATION AND PRINCIPAL ACTIVITIES
(b) Reorganization, page F-38

16.      Please provide your analysis that supports accounting for the
reorganization as
         combination of companies under common control. Provide a table that
shows the
         ownership interest in the companies before and after the
reorganization.
(c) Organization, page F-39

17.      Please include a description of the recognized and unrecognized
revenue-producing assets
         that are held by the VIE. These assets may include licenses,
trademarks, other intellectual
         property, facilities or assembled workforce. We refer you to ASC
810-10-50-5A.d.
 Yongsheng Liu
Wealthbridge Acquisition Limited
January 2, 2020
Page 5
SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
(c) Foreign Currency, page F-44

18.   Clarify why you utilize the US dollar for convenience translation while
the company's
      functional currency is the US dollar.
General

19.   You state in the forepart that the proxy statement contains information
and statistics
      related to China's economy and its entertainment live streaming industry
that derive from
      various publications issued by market research companies and PRC
governmental
      entities. Please identify each source of information and statistics cited
in the proxy
      statement by disclosing the name of the author as well as the title and
date of the
      publication. In this regard, we note your references to a Frost &
Sullivan industry report
      and a YIGUAN data report. Please also clarify whether these reports, or
any other
      reports, were commissioned by Wealthbridge or Scienjoy for use in
connection with this
      proxy statement.
        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.

       You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Bernard Nolan,
Attorney-Adviser, at (202) 551-6515 or, in his absence, Jan Woo, Legal Branch
Chief, at (202)
551-3453 with any other questions.



                                                           Sincerely,
FirstName LastNameYongsheng Liu
                                                           Division of
Corporation Finance
Comapany NameWealthbridge Acquisition Limited
                                                           Office of Technology
January 2, 2020 Page 5
cc:       Giovanni Caruso
FirstName LastName
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