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    BIMI
                                            INTERNATIONAL MEDICAL INC. (NASDAQ: BIMI)

February
23, 2023

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Ms. Nasreen Mohammed

    Re:
    BIMI International Medical Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2021

    Amendment No. 1 to Form 10-K Filed August 31, 2022

    Form 10-Q for the Quarterly Period ended September
    30, 2022

    File No.:  001-34890                                                                          

Dear
Ladies and Gentlemen:

We
are submitting this letter in response to your letter dated January 24, 2023 in which the staff of the Division of Corporation Finance
(the “Staff”) provided comments to Amendment No. 1 (the “Amendment”) to the Form 10-K we filed on August 31,
2022 and to our Form 10-Q for the Quarterly Period ended September 30, 2022.

Set
forth below are our responses to the comments. For your convenience, the text of each of such comments are reproduced in italics before
our response.

Amendment
No. 1 to Form 10-K Filed August 31, 2022

Item
1. Business

The
Company, page 1

    1.
    We note your revisions to comment 1. In future filings
    please further revise to clearly state that you are not a Chinese operating company and that this structure involves unique risks
    to investors.

In
future filings we will further revise to clearly state that our company is not a Chinese operating company and that this structure involves
unique risks to investors.

    2.
    We note your revisions to pages 2 and 16 in response
    to our prior comment 8. In future filings, revise this section to clearly identify BIMI Medical International Inc. as the entity
    in which investors hold shares of your common stock and that, as a holding company, BIMI Medical International Inc. does not conduct
    any of your operations.

In
future filings we will further revise this section to clearly identify BIMI Medical International Inc. (the “Company”) as
the entity in which investors hold shares of our common stock and that, as a holding company, the Company does not conduct any of our
operations.

    3.
    We note your response to comment 11 and note the
    revisions to your disclosure on pages 2 and 46 to affirmatively state that you do not use a VIE structure. However, your risk factor
    on page 46 titled in part “PRC regulations on loans and direct investments by offshore holding companies to PRC entities...”
    includes two references to a variable interest entity. Please revise your disclosure in future filings to reconcile these statements.

In
future filings we will revise the disclosure to reconcile the statements.

    4.
    In future filings, please include the ownership
    of BIMI International Medical Inc. in the diagram on page 2.

In
future filings we will include the ownership of our Company in the diagram.

Holding
Foreign Companies Accountable Act and Related Legislation and Regulations, page 5

    5.
    We note your response to comment 3. In future filings
    please revise the cross-reference on page 5 to your risk factor related to the HFCCA to include the full title of this related risk
    factor. Specifically, the title of the risk factor on page 43 includes an additional sentence beginning with “Pending legislation
    would reduce...”

In
future filings we will revise the cross-reference to the risk factor related to the HFCCA to include the full title of the related risk
factor.

Cash
Transfers and Dividend Distributions, page 8

    6.
    We note your response to comment 4, including your
    revisions beginning on page 8, and reissue in part. In future filings please indicate whether there have been any cash flows or transfers
    of assets from your subsidiaries and the holding company. Also revise your disclosure to describe any restrictions on your ability
    to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your ability
    to distribute earnings from your company, including your subsidiaries, to the holding company and U.S. investors. Additionally, provide
    a cross-reference to the condensed consolidating schedule and consolidated financial statements.

In
future filings we will indicate whether there have been any cash flows or transfers of assets from our subsidiaries and the holding company
and describe whether there are restrictions on our ability to transfer cash between entities, across borders, and to U.S. investors.
We will also describe any restrictions and limitations on our ability to distribute earnings to the holding company and U.S. investors.
We will also provide a cross-reference to the condensed consolidating schedule and consolidated financial statements.

Cash
Management Policies and Procedures, page 10

    7.
    We note your response to comment 6. In future filings
    please revise your disclosure in this section to clarify whether there are any restrictions on your ability to transfer cash to you,
    BIMI Medical International, as a Delaware incorporated holding company. Further, please clarify which holding company you are referring
    to in this section, where you state “[t]o date, none of our subsidiaries have made any distributions or paid any dividend to
    the holding company.” We note your table of subsidiaries on page 1 identifies you as a holding company as well as three additional
    holding companies.

In
future filings we will indicate whether there are any restrictions on the ability of our subsidiaries to transfer cash to the Delaware
holding company and will identify the holding company as Delaware entity.

    2

Permissions
Required from the PRC Authorities for Our Operations, page 10

    8.
    We note your revisions in response to prior comment
    9. In future filings please further revise this section to state whether you or your subsidiaries are covered by permissions requirements
    from the Cyber Administration of China (CAC) and explain how you arrived at your conclusion and the basis for your conclusion. We
    note your discussion of CAC under your subsection titled “Recent Regulatory Developments in China” and well as in your
    Risk Factors section. Please also name counsel where you note that your conclusion that you are not required to seek approval from
    the PRC is based on the advice of counsel. Please supplementally provide us with draft disclosure showing how you will present this
    disclosure in future filings.

We
are providing the requested supplemental draft disclosure in Appendix “A” hereto.

Item
1A. Risk Factors

Risk
Related to Doing Business in China

PRC
regulations on loans and direct investments by offshore holdings companies..., page 46

    9.
    We note your response to comment 7, including providing
    a cross-reference to the relevant risk factor. In future filings please further revise this risk factor to address the risk that
    if funds or assets in your business are in the PRC or Hong Kong or a PRC or Hong Kong entity, the funds or assets may not be available
    to fund operations or for other use outside of the PRC or Hong Kong due to interventions in or the imposition of restrictions and
    limitation on the ability of you or your subsidiaries by the PRC government to transfer cash or assets. We note that your current
    risk factor is limited to addressing the transfer of cash or assets from your offshore holdings companies to PRC or Hong Kong entities.

In
future filings we will address the Staff’s comments with respect to the risk factor.

Results
of Operations

Operating
expenses, page 62

    10.
    We note your response to comment 14 and reissue
    the comment in part. Your revised disclosure states operating expenses consist mainly of the amortization of convertible notes and
    other items. However, your Consolidated Statements of Operations were amended to reclassify this amortization to non-operating expenses.
    In addition, goodwill impairment was reclassified to operating expenses. In future filings, please revise to identify the intermediate
    causes and also describe the underlying reasons for the changes in operating expenses. Refer to Item 303(b) of Regulation S-K.

In
future filings we will identify the intermediate causes and also describe the underlying reasons for the changes in operating expenses.

    3

Consolidated
Statements of Operations and Comprehensive Loss, page F-5

    11.
    We reviewed your revisions in response to comment
    16. Please reconcile the amortization of convertible notes to the amounts presented in the Statements of Cash Flows for both fiscal
    2021 and 2020.

In
response to the Staff’s comment we revisited the revisions provided in the Amendment. We determined that we omitted to extract
the amount attributable to the amortization of the convertible notes in 2020 from “General and administrative expenses” and
include such amount in the line item “Amortization of convertible notes” in “Other Income (Expense)”. As a result,
we intend to file a further amendment to our Form 10-K for the year ended December 31, 2021 and to amend our Form 10-K for the year ended
December 31, 2020 reflecting such reclassification and will revise the Statement of Cash Flows in both annual reports to reflect such
amortization as separate line items.

Note
5. The Acquisition of the Guoyitang Hospital, page F-21

    12.
    We note your response
    to comment 19 and reissue the comment in part. Disclosure is unclear on the amount of consideration paid for Guoyitang hospital and
    the subsequent acquisitions and how the consideration paid relates to the net assets acquired. Please reconcile the consideration
    paid to the net assets acquired presented in the tables for all of the acquisitions.

Guoyitang
Hospital

We
acquired all the issued and outstanding shares of the Guoyitang Hospital for RMB 100,000,000, payable by the issuance of 2,000,000 shares
of our common stock and the payment of RMB 60,000,000 in cash, subject to the attainment of certain performance milestones. Upon the
initial closing of the agreement, we issued 2,000,000 shares of common stock valued at $3,820,000 ($1.91 per share) and RMB 20 million
($3,048,780) in cash to the seller. The total consideration paid to the seller at such time was $6,916,119.

At
the time of the initial closing of the acquisition, Guoyitang had net assets of $1,293,029, and net liabilities of $1,531,303. We recorded
$ 3,579,277 as additional paid-in capital due to the issuance of the 2,000,000 shares valued at $3,820,000 less $238,723, which was the
difference between the net assets acquired and the net liabilities assumed. We recorded $7,154,393 (the sum of the purchase price and
the difference between the assets acquired and liabilities assumed) as Goodwill.

    4

Guanzan
Group

We
acquired all the issued and outstanding shares of the Guanzan Group for RMB 100,000,000, payable by the issuance of 950,000 shares of
our common stock and the payment of RMB 80,000,000 in cash, subject to the attainment of certain performance milestones. Upon the initial
closing of the acquisition, we issued 950,000 shares of common stock valued at $2,717,000 based on the market price of $2.86 per share
and paid RMB 40,000,000 ($5,687,635) in cash. The total consideration paid to the seller at such time was $8,404,635.

At
the time of the acquisition, the Guanzan Group had net assets of $5,567,637 and net liabilities of $4,879,688. We recorded $2,716,050
as additional paid-in capital due to the issuance of the 950,000 shares valued at $2,717,000. We recorded $7,716,686 as Goodwill.

Zhongshan
Hospital

We
acquired all the issued and outstanding shares of the Zhongshan Hospital for RMB 80,000,000, payable by the issuance of 2,000,000 shares
of our common stock valued at $3,480,000 based on the market price of $1.74 per share and the payment of RMB 40,000,000 ($6,171,887)
in cash to the seller. The total consideration paid to the seller at such time was $9,651,887.

At
the time of the acquisition, Zhongshan had net assets of $2,213,193, and net liabilities of $3,004,800. We recorded $2,686,393 as additional
paid-in capital due to the issuance of the 2,000,000 shares valued at $3,480,000 less $791,607, which was the difference between the
net assets acquired and the net liabilities assumed. We recorded $10,443,494 (the sum of the purchase price and the difference between
the assets acquired and liabilities assumed) as Goodwill.

Zhouda
Hospital

We
acquired all the issued and outstanding shares of the Zhouda Hospital in consideration for the issuance of 2,200,000 shares of our common
stock. Upon the closing of the transaction, the 2,200,000 shares of common stock were valued at $1,498,200 based on a market price of
$0.681 per share.

At
the time of the acquisition, Zhouda Hospital had net assets of $1,947,998, and net liabilities of $1,374,540. We recorded $1,496,000
as additional paid-in capital due to the issuance of the 2,200,000 shares valued at $1,498,200. We recorded $924,741 (the purchase price
less the difference between the assets acquired and liabilities assumed) as Goodwill.

Quangsheng,
Eurasia and Minkang Hospitals

We
acquired all the issued and outstanding shares of all these three hospitals for RMB 162,000,000, payable by the issuance of 4,000,000
shares of our common stock and the payment of RMB 84,000,000 in cash, subject to the attainment of certain performance milestones. Upon
the initial closing of the transaction, cash consideration of RMB 20,000,000 ($3,136,910) was paid and 4,000,000 shares of common stock
were issued valued at $5,600,000 based on a market price of $1.40 per share. The total consideration was $8,736,911.

At
the time of the acquisition, the three hospitals had net assets of $3,073,186 and net liabilities of $3,403,805. We recorded $5,265,381
as additional paid-in capital due to the issuance of the 4,000,000 shares valued at $5,600,000 less $330,619, which was the difference
between the net assets acquired and the net liabilities assumed. We recorded $ 9,067,529, the sum of the purchase price and the difference
between the assets acquired and liabilities assumed as Goodwill.

    5

Form
10-Q for the Quarterly Period Ended September 30, 2022

Consolidated
Statements of Equity, page 3

    13.
    We noted you only present a statement for the nine
    months ended September 30, 2022. An analysis of the changes in each caption of stockholders’ equity and noncontrolling interests
    presented in the balance sheets shall be given in a note or separate statement. This analysis shall be presented in the form of a
    reconciliation of the beginning balance to the ending balance for each period for which a statement of comprehensive income is required
    to be filed with all significant reconciling items described by appropriate captions. Please revise future filings. Refer to Rules
    8-03(a)(5) and 3-04 of Regulation S- X.

In
future filings we will provide the requested analysis.

Notes
to the Unaudited Condensed Consolidated Financial Statements

1.
Organization and Business Background, page 5

    14.
    Reference is made to the last paragraph on page
    6. Please tell us how you accounted for the June 9, 2022 issuance of the $5 million subordinated promissory note. In this regard,
    it doesn’t appear to be reflected in your Condensed Consolidated Balance Sheet or your Consolidated Statement of Cash Flows.

The
$5 million subordinated promissory note was issued on June 9, 2022 and converted into 1,250,000 shares of the Company’s common
stock on July 18, 2022, upon obtaining shareholder approval for the transaction. The issuance of the common stock is reflected in the
Consolidated Statement of Cash Flows as “Issuance of common stocks” in the “Cash Flows from Financing Activities.”
A portion of the cash prov