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September 1, 2023

VIA EDGAR

    Sasha Parikh, Staff Accountant

    Kevin Vaughn, Senior Associate Chief Accountant

    Doris Stacey Gama, Attorney

    Jason Drory, Attorney

    Office of Life Sciences

    Division of Corporation Finance

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549-7010

    Re:
    SINOVAC BIOTECH LTD

    Form 20-F for the Fiscal Year Ended December 31, 2022

    Filed May 1, 2023

    File No. 001-32371

Dear Ms. Parikh, Mr. Vaughn, Ms. Gama, Mr. Drory:

On behalf of our client, Sinovac Biotech Ltd. (the
 “Company”), we are submitting this letter setting forth the Company’s responses to the comments contained in
the letter dated July 21, 2023 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2022 (the “2022 20-F”).

For ease of review, the Staff’s comments
are repeated below in bold and are followed by the Company’s responses. We have included page references in the 2022 20-F where
the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth
in the 2022 20-F.

Amendment No. 1 to Annual Report on Form 20-F

Cash and Asset Flow Through Our Organization, page 2

 1. We note your response to prior comment 3 regarding how cash is transferred through your organization and reissue in part. Consistent
with your response, please revise your disclosure to disclose (i) Sinovac Antigua did not receive any dividend from its subsidiaries and
there was no cash transfer between Sinovac Antigua and its subsidiaries in 2022, (ii) Sinovac Antigua did not distribute any dividend
and did not distribute any dividend to investors, including U.S. investors, in 2020, 2021 and 2022, and has no intention to distribute
dividends in the near future and (iii) $263.2 million in dividends were paid by Sinovac Life Sciences Co., Ltd. to Sinovac Hong Kong and
its other shareholders.

In response to the Staff’s comment, the Company respectfully
advises the Staff that it will revise the disclosure in the fourth paragraph under “Item 3. Key Information — Cash and Asset
Flows through Our Organization” on page 2 of the 2022 20-F, with changes set forth in Annex A.

    Resident Partners:

    Amy E. Beckingham

    Andrew J. Bishop

    Benjamin B. R. Carale

    Derek S. H. Chua

    Simon J. Cooke

    Dominic A. Geiser

    Simon M. Hawkins

    Howard K. H. Lam

    Posit Laohaphan

    Dominik Sklenar

    Qiuning Sun

    Terris C. C. Tang

    Allen C. Wang

    Richard Watkins

    See Wah Wong

    Cheung Ying Yeung

    Registered Foreign Lawyers:

    Michael J. S. Hardy (England and
    Wales)

    Won Suk Kang (England and Wales)

    Ji Liu (California)

    Zhonghua Shi (New York)

    Benjamin P. Su (New York)

    Daying
    Zhang (New York)

    September 1, 2023

    Page 2

Item 16I. Disclosure Regarding Foreign Jurisdiction that Prevents
Inspection, page 94

 2. With respect to your disclosure pursuant to Item 16I(b)(5), we note that you have included language that such disclosure is “to
our knowledge.” Please supplementally confirm without qualification, if true, that your articles and the articles of your consolidated
foreign operating entities do not contain wording from any charter of the Chinese Communist Party.

In response to the Staff’s comment, the Company respectfully
advises the Staff that it will further revise the disclosure in the third paragraph under “ITEM 16I. Disclosure regarding Foreign
Jurisdictions That Prevent Inspections” on page 94 of the 2022 20-F, with accumulated changes set forth in Annex A.

* * *

    September 1, 2023

    Page 3

If you have any additional questions regarding
the 2022 20-F, please do not hesitate to contact me at benjamin.su@lw.com, +852 2912-2728 (work) or +852 9881-9371 (cell), or Ms. Zheng
Wang at zheng.wang@lw.com, +852 2912-2585 (work) or +852 9131-0464 (cell).

Thank you for your time and attention.

    Sincerely yours,

    /s/ Benjamin Su

    Benjamin Su

    of LATHAM & WATKINS LLP

    cc:
    Weidong Yin, Chairman and Chief Executive Officer

    Nan Wang, Chief Financial Officer

    Simon Anderson, Chairman of the Audit Committee

    Zheng Wang, Esq., Latham & Watkins LLP

    Zhibin Huang Grant Thornton Zhitong Certified Public Accountants LLP

Annex A

Response 1: to replace the current fourth paragraph under “Item
3. Key Information — Cash and Asset Flows Through Our Organization” on page 2 of the 2022 20-F:

“Under PRC laws, Sinovac Antigua may fund our PRC subsidiaries
only through capital contributions or loans, subject to satisfaction of applicable government registration and approval requirements.
In 2020, 2021 and 2022, no assets other than cash were transferred through our organization. . Sinovac Antigua did not receive
any dividend from its subsidiaries and there was no cash transfer between Sinovac Antigua and its subsidiaries in 2022. Sinovac Antigua
did not distribute any dividend to investors, including U.S. investors, in 2020, 2021 and 2022, and has no intention to distribute dividends
in the near future, except the cumulative preferential dividends entitled by the holders of Series B Preferred Shares pursuant to the
Rights Agreement (see “Item 10. Additional Information – B. Memorandum and Articles of Association – Series B Preferred
Shares). In 2022, $263.2 million in dividend were paid and US$121.9 million were deferred dividend payment by Sinovac LS and Sinovac Dalian
to their minority shareholders, and $439.5 million in dividend were paid and US$98.1 million were deferred dividend payment by such subsidiaries
to Sinovac Hong Kong. Sinovac Hong Kong did not further distribute such dividends to Sinovac Antigua.”

Response 13: to replace the current third paragraph
under “ITEM 16I. Disclosure regarding Foreign Jurisdictions That Prevent Inspections” on page 94 of the 2022 20-F:

“Sinovac Antigua has subsidiaries incorporated
in mainland China, Hong Kong, Singapore, Thailand, Philippines, Mexico, Peru, Colombia, Ecuador, Bangladesh, Indonesia, Chile and Pakistan.
As of the date of this annual report, to our knowledge, (i) no Antigua or PRC governmental entities owns any shares of Sinovac Antigua
or its subsidiaries, (ii) the no Antigua or PRC governmental entities have
do not have a controlling financial interest in Sinovac Antigua or its subsidiaries, and (iii) none
of the members of the board of directors of Sinovac Antigua or its subsidiaries is an official of the Communist Party of China,.
and (iv) none None of the currently effective memorandum and articles of association (or equivalent
organizing document) of Sinovac Antigua or its consolidated foreign operating entities subsidiaries
contains any wordings from any charter of the Communist Party of China. ”