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United States securities and exchange commission logo





                             November 30, 2023

       Hung To Pau, Ph.D.
       Chief Executive Officer
       Advanced Biomed Inc.
       689-87 Xiaodong Road
       Yongkang District
       Tainan, Taiwan

                                                        Re: Advanced Biomed
Inc.
                                                            Amendment No. 6 to
Registration Statement on Form S-1
                                                            Filed November 20,
2023
                                                            File No. 333-272110

       Dear Hung To Pau:

                                                        We have reviewed your
amended registration statement and have the following comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a 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 letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our November 6, 2023
letter.

       Amendment No. 6 to Form S-1

       Cover Page

   1.                                                   We note that on the
cover page you state that "[a]ny overseas offering and listing made by
                                                        an issuer that meets
both the following conditions will be determined as indirect offering
                                                        and listing in overseas
market and, therefore, be subject to filing requirement: (i) 50% or
                                                        more of the issuer   s
operating revenue, total profit, total assets or net assets as
                                                        documented in its
audited consolidated financial statements for the most recent accounting
                                                        year is accounted for
by domestic companies; and (ii) the main parts of the issuer   s
                                                        business activities are
conducted in the Mainland China, or its main places of business are
                                                        located in the Mainland
China, or the senior managers in charge of its business operation
                                                        and management are
mostly Chinese citizens or domiciled in the Mainland China" and
                                                        that you "do not
believe that [you] are required to obtain the approval from or complete
                                                        the filing with the
CSRC for this offering...based on the fact that [you] do not meet the
 Hung To Pau, Ph.D.
Advanced Biomed Inc.
November 30, 2023
Page 2
      explicit conditions set out in the Trial Measures to determine whether an
overseas offering
      shall be deemed as a direct or an indirect overseas offering and listing
by a domestic
      company." Please revise to expressly explain the criteria you considered
specific to your
      business that formed the basis of your determination that you do not meet
these conditions
      for filing. Please also revise to state whether you relied on an opinion
of counsel for this
      determination.
       Please contact Nudrat Salik at 202-551-3692 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551-7153 with any
other
questions.



                                                            Sincerely,

FirstName LastNameHung To Pau, Ph.D.                        Division of
Corporation Finance
                                                            Office of
Industrial Applications and
Comapany NameAdvanced Biomed Inc.
                                                            Services
November 30, 2023 Page 2
cc:       Fang Liu, Esq.
FirstName LastName
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