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July 12, 2023
Zhuowei Zhong
President & Chairman of the Board
JRSIS HEALTH CARE Corp
3/F Building A , De Run Yuan
No. 19 Chang Yi Road , Chang Ming Shui
Wu Gui Shan , Zhong Shan City 528458
Re:JRSIS HEALTH CARE Corp
Form 10-K for Fiscal Year Ended December 31, 2022
Filed April 17, 2023
File No. 001-36758
Dear Zhuowei Zhong:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Part I
Item 1. Business, page 1
1.At the onset of Part I, please disclose prominently that you are not a Chinese operating
company but a Florida holding company with operations conducted by your subsidiary.
2.Provide prominent disclosure about the legal and operational risks associated with being
based in or having the majority of the company’s operations in China. Your disclosure
should make clear whether these risks could result in a material change in your operations
and/or the value of your securities or could significantly limit or completely hinder your
ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless. Your disclosure should address how
recent statements and regulatory actions by China’s government, such as those related to

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data security or anti-monopoly concerns, have or may impact the company’s ability to
conduct its business, accept foreign investments, or list on a U.S. or other foreign
exchange.
3.Please disclose the location of your auditor’s headquarters and whether and how the
Holding Foreign Companies Accountable Act, as amended by the Consolidated
Appropriations Act, 2023, and related regulations will affect your company.  In addition,
disclose that trading in your securities may be prohibited under the Holding Foreign
Companies Accountable Act if the PCAOB determines that it cannot inspect or investigate
completely your auditor, and that as a result an exchange may determine to delist your
securities.  For additional information refer to https://www.sec.gov/hfcaa.
4.Clearly disclose how you will refer to the holding company and subsidiaries when
providing the disclosure throughout the document so that it is clear to investors which
entity the disclosure is referencing and which subsidiaries or entities are conducting the
business operations. For example, disclose, if true, that your subsidiaries conduct
operations in China.
5.Provide a clear description of how cash is transferred through your organization. Disclose
your intentions to distribute earnings. Quantify any cash flows and transfers of other
assets by type that have occurred between the holding company and its subsidiaries, and
direction of transfer. Quantify any dividends or distributions that a subsidiary have made
to the holding company and which entity made such transfer, and their tax consequences.
Similarly quantify dividends or distributions made to U.S. investors, the source, and their
tax consequences. Your disclosure should make clear if no transfers, dividends, or
distributions have been made to date. Describe any restrictions on foreign exchange and
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 the
company, including your subsidiaries, to the parent company and U.S. investors.
Item 1A. Risk Factors
Risks Related to Doing Business in China, page 5
6.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or having the majority of the company’s operations in China poses to investors.
In particular, describe the significant regulatory, liquidity, and enforcement risks. For
example, specifically discuss risks arising from the legal system in China, including risks
and uncertainties regarding the enforcement of laws and that rules and regulations in
China can change quickly with little advance notice; and the risk that the Chinese
government may intervene or influence your operations at any time, or may exert more
control over offerings conducted overseas and/or foreign investment in China-based
issuers, which could result in a material change in your operations and/or the value of
your securities. Acknowledge any risks that any actions by the Chinese government to
exert more oversight and control over offerings that are conducted overseas and/or foreign
investment in China-based issuers could significantly limit or completely hinder your

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ability to offer or continue to offer securities to investors and cause the value of your
securities to significantly decline or be worthless.
7.We note your disclosure on page 8 about the Holding Foreign Companies Accountable
Act. Please expand your risk factors to disclose that the Holding Foreign Companies
Accountable Act, as amended by the Consolidated Appropriations Act, 2023, decreases
the number of consecutive “non-inspection years” from three years to two years, and thus,
reduces the time before your securities may be prohibited from trading or delisted. We
also note your disclosure that the Commission conclusively identified you as a
“Commission Identified Issuer” on May 13, 2022.  Please revise your disclosure to
explain why you were identified and provide any additional context necessary for
investors to understand the meaning and significance to your operations of this
determination. Update your disclosure to describe the potential consequences to you if the
PRC adopts positions at any time in the future that would prevent the PCAOB from
continuing to inspect or investigate completely accounting firms headquartered in
mainland China or Hong Kong.
8.Given the Chinese government’s significant oversight and discretion over the conduct of
your business, please revise to highlight separately the risk that the Chinese government
may intervene or influence your operations at any time, which could result in a material
change in your operations and/or the value of your securities. Also, given recent
statements by the Chinese government indicating an intent to exert more oversight and
control over offerings that are conducted overseas and/or foreign investment in China-
based issuers, acknowledge the risk that any such action could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of your securities to significantly decline or be worthless.
9.In light of recent events indicating greater oversight by the Cyberspace Administration of
China (CAC) over data security, particularly for companies seeking to list on a foreign
exchange, please revise your disclosure to explain how this oversight impacts your
business and your securities and to what extent you believe that you are compliant with
the regulations or policies that have been issued by the CAC to date.
PRC Laws and Regulations Affecting Our Business, page 5
10.We note your disclosure here regarding several PRC laws and regulations that could affect
your business. Please revise to disclose each permission or approval that you or your
subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer securities to foreign investors. State whether you or your subsidiaries are covered
by permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve your operations, and state affirmatively whether you have received all
requisite permissions or approvals and whether any permissions or approvals have been
denied. Please also describe the consequences to you and your investors if you or your
subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)

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inadvertently conclude that such permissions or approvals are not required, or (iii)
applicable laws, regulations, or interpretations change and you are required to obtain such
permissions or approvals in the future.
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 19
11.We note that during your fiscal year 2022 you were identified by the Commission
pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C.
7214(i)(2)(A)) as having retained, for the preparation of the audit report on the financial
statements included in the Form 10-K, a registered public accounting firm that has a
branch or office that is located in a foreign jurisdiction and that the Public Company
Accounting Oversight Board had determined it is unable to inspect or investigate
completely because of a position taken by an authority in the foreign jurisdiction.  Please
provide the documentation required by Item 9C(a) of Form 10-K in the EDGAR
submission form “SPDSCL-HFCAA-GOV” or tell us why you do not believe you are
required to do so.  Refer to the Staff Statement on the Holding Foreign Companies
Accountable Act and the Consolidated Appropriations Act, 2023, available on our website
at https://www.sec.gov/corpfin/announcement/statement-hfcaa-040623
General
12.To the extent that one or more of your officers and/or directors are located in China
or Hong Kong, please create a separate Enforceability of Civil Liabilities section for
the discussion of the enforcement risks related to civil liabilities due to your officers
and directors being located in China or Hong Kong. Please identify each officer
and/or director located in China or Hong Kong and disclose that it will be more difficult
to enforce liabilities and enforce judgments on those individuals. For example, revise
to discuss more specifically the limitations on investors being able to effect service
of process and enforce civil liabilities in China, lack of reciprocity and treaties, and cost
and time constraints. Also, please disclose these risks in a separate risk factor, which
should contain disclosures consistent with the separate section.
            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 LastNameZhuowei Zhong
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 FirstName LastName
Zhuowei Zhong
JRSIS HEALTH CARE Corp
July 12, 2023
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            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters. Contact
Christopher Dunham at 202-551-3783 if you have any questions about comments related to your
status as a Commission-Identified Issuer during your most recently completed fiscal year. Please
contact Jessica Ansart at 202-551-4511 or Abby Adams at 202-551-6902 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Robert Brantl