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CORRESP
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    Dykema
    Gossett PLLC

    111
    E. Kilbourn Ave.

    Suite
    1050

    Milwaukee,
    WI 53202

    www.dykema.com

    Tel:
    414-488-7300

    Kate
    Bechen

    Direct
    Dial: (414) 488-7333

    Email:
    KBechen@dykema.com

February
6, 2025

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Daniel Crawford, Tim Buchmiller, Tracie

Mariner,
and Sasha Parikh

    Re:
    Scienture
    Holdings, Inc.

    Amendment
    No. 2 to Registration Statement on Form S-1

    Filed
    January 13, 2025

    File
    No. 333-283591

Dear
Mr. Crawford, Mr. Buchmiller, Ms. Mariner and Ms. Parikh:

This
response letter (this “Response”) is submitted on behalf of Scienture Holdings, Inc. (the “Company”)
in response to the comments that the Company received from the staff of the Division of Corporation Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “SEC”) in a letter addressed to Mr. Ajjarapu, dated February 5,
2025 (the “Comment Letter”), with respect to the Company’s registration statement on Form S-1 (the “Registration
Statement”), filed with the SEC on January 30, 2025. The Company is concurrently submitting a third amendment to the
Registration Statement (“Amendment No. 3”), which reflects the changes discussed in this Response that the Company
made to address the Staff’s comments and other updates.

For
reference purposes, each of the Staff’s numbered comments from the Comment Letter is set forth in bold text below, followed by
the Company’s response to each comment. All capitalized terms used but not defined in this Response have the meanings ascribed
to them in Amendment No. 3.

The
responses below are based on information provided to Dykema Gossett PLLC by the Company.

Amendment
No. 2 to Registration Statement on Form S-1

Use
of Proceeds, page 44

    1.
    We
    note from your response to prior comment 3 that you do not intend to use offering proceeds for your planned Phase 1 single dose study
    in healthy adults that you disclose on page 57. Please revise to state the source of funding for the Phase 1 trial. Refer to Instruction
    3 to Item 504 of Regulation S-K.

Response:
In response to the Staff’s comments, the Company advises the Staff that it has reconsidered the Company’s intended use
of proceeds for the offering and determined that the Company intends to use a portion of the offering proceeds in connection with its
planned Phase 1 single dose study in healthy adults. The Company has also determined that it will use a portion of the offering proceeds
to fund clinical trials, BLA approval, and the launch of SCN-106. Furthermore, the Company intends to use a portion of the offering proceeds
to fund the in-licensing and launch of yet to be identified third party products. The Company does not anticipate that it will require
a material amount of other funds necessary to accomplish the specified purposes for which the proceeds are to be used as disclosed in
Amendment No. 3. In this regard, the Company has revised the disclosure in the footnotes of the table set forth on page 44 of Amendment
No. 3.

Thank
you for your review and consideration of the matters set forth in this Response and in Amendment No. 3. If you have any questions, please
contact the undersigned at (414) 488-7333 or KBechen@dykema.com.

    Sincerely,

    Dykema
    Gossett PLLC

    /s/
    Kate Bechen

    Kate
    Bechen, Esq.

    cc:
    Surendra
    Ajjarapu

    Chief
    Executive Officer

    Scienture
    Holdings, Inc.