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United States securities and exchange commission logo
April 29, 2020
Kai Gui
Chief Financial Officer
Advanced Biomedical Technologies, Inc.
350 Fifth Ave, 59th Floor
New York, NY 10118
Re:Advanced Biomedical Technologies, Inc.
Form 10-K for the Fiscal Year Ended October 31, 2019
Filed March 20, 2020
File No. 000-53051
Dear Mr. Gui:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended October 31, 2019
Item 9A. Controls and Procedures , page 25
1.We note that you have concluded your internal control over financial reporting was not
effective as of October 31, 2019.  Consistent with Item 308(a)(3) of Regulation S-K,
please describe to us the material weaknesses in the your internal control over financial
reporting and revise future filings to disclose them.
            In closing, 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.

 FirstName LastNameKai  Gui
 Comapany NameAdvanced Biomedical Technologies, Inc.
 April 29, 2020 Page 2
 FirstName LastName
Kai  Gui
Advanced Biomedical Technologies, Inc.
April 29, 2020
Page 2
            You may contact Tara Harkins at (202) 551-3639 or or Kevin Kuhar, Accounting Branch
Chief, at (202) 551-3662 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences