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JRSIS HEALTH CARE CORP.

3/F Building A, Derunyuan

No. 19 Changyi Road, Changmingshui

Wuguishan, Zhongshan City 528458

People’s Republic of China

July 26, 2023

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

    Attention:

    Jessica Ansart

    Abby Adams

    Christopher Dunham

    Jeanne Baker

    Terence O’Brien

Re: JRSIS Health Care Corp.

Form 10-K for Fiscal Year Ended December 31,
2022

Filed April 17, 2023

File No. 001-36758

Ladies and Gentlemen,

JRSIS Health Care Corp. (“JRSIS”)
submits this letter in connection with the Company’s filing today of Amendment No. 1 (the “Amendment”)
to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022. Set forth below in italics you will find copies
of the Staff’s comments from its letter dated July 12, 2023 (the “Comment Letter”), followed by information
and page reference to the location within the Amendment where responsive disclosure can be found.

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.

Response to Comment 1

As requested, the following disclosure has
been added at page  4 of the Amendment:

JRSIS IS A HOLDING
COMPANY INCORPORATED IN THE STATE OF FLORIDA. IT HAS NO OPERATIONS. JRSIS IS THE DIRECT OWNER OF ONE SUBSIDIARY, JRSIS-BVI, WHICH HAS
NO OPERATIONS BUT IS THE DIRECT OWNER OF ONE SUBSIDIARY, RUNTENG, RUNTENG HAS NO OPERATIONS BUT IS THE DIRECT OWNER OF LAIDIAN. LAIDIAN
IS ORGANIZED IN THE PRC AND CARRIES OUT ALL OF ITS OPERATIONS IN THE PRC. ACCORDINGLY, INVESTORS IN JRSIS ARE NOT THE OWNERS OF A FLORIDA
CORPORATION WITH OPERATIONS IN CHINA, BUT RATHER ARE OWNERS OF A FLORIDA HOLDING COMPANY WHOSE PROSPERITY WILL DEPEND ON ITS INDIRECT
OWNERSHIP THROUGH OFFSHORE ENTITIES OF AN ENTITY ORGANIZED UNDER CHINESE LAW THAT CARRIES ON OPERATIONS IN THE PRC.

 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 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.

Response
to Comment 2

As requested, the following disclosure has been added at
page 5 of the Amendment:

WE FACE VARIOUS LEGAL
AND OPERATIONAL RISKS AND UNCERTAINTIES RELATED TO HAVING OUR OPERATIONS IN CHINA. THE PRC GOVERNMENT HAS SIGNIFICANT AUTHORITY TO REGULATE
A COMPANY, SUCH AS LAIDIAN, THAT IS ORGANIZED IN CHINA. FOR EXAMPLE, WE FACE RISKS ASSOCIATED WITH ANTI-MONOPOLY REGULATORY ACTIONS, AS
WELL AS OVERSIGHT ON CYBERSECURITY AND DATA PRIVACY. IN ADDITION, THE PRC GOVERNMENT HAS SIGNIFICANT OVERSIGHT AND DISCRETION OVER THE
CONDUCT OF LAIDIAN’S BUSINESS AND MAY INTERVENE WITH OR INFLUENCE THE OPERATIONS OF OUR BUSINESS AS THE GOVERNMENT DEEMS APPROPRIATE
TO FURTHER REGULATORY, POLITICAL AND SOCIETAL GOALS. THE PRC GOVERNMENT HAS RECENTLY PUBLISHED NEW POLICIES THAT SIGNIFICANTLY AFFECTED
CERTAIN INDUSTRIES SUCH AS THE EDUCATION AND INTERNET INDUSTRIES, AND WE CANNOT RULE OUT THE POSSIBILITY THAT IT WILL IN THE FUTURE RELEASE
REGULATIONS OR POLICIES REGARDING LAIDIAN’S INDUSTRY THAT COULD ADVERSELY AFFECT ITS BUSINESS, FINANCIAL CONDITION AND RESULTS OF
OPERATIONS.

MOREOVER, THE PRC
GOVERNMENT, BY ITS AUTHORITY OVER LAIDIAN, HAS THE ABILITY TO EXERT INFLUENCE ON THE ABILITY OF JRSIS, TO ACCEPT FOREIGN INVESTMENTS OR
LIST ON U.S. OR OTHER FOREIGN EXCHANGES. SUCH RISKS COULD RESULT IN A MATERIAL CHANGE IN OUR OPERATIONS AND/OR THE VALUE OF JRSIS COMMON
STOCK OR COULD SIGNIFICANTLY LIMIT OR COMPLETELY HINDER OUR ABILITY TO OFFER, OR CONTINUE TO OFFER, OUR COMMON STOCK AND/OR OTHER SECURITIES
TO INVESTORS AND CAUSE THE VALUE OF SUCH SECURITIES TO SIGNIFICANTLY DECLINE OR BE WORTHLESS. FOR EXAMPLE, ON FEBRUARY 17, 2023, THE CHINA
SECURITIES REGULATORY COMMISSION, OR CSRC, ISSUED THE TRIAL ADMINISTRATIVE MEASURES OF OVERSEAS SECURITIES OFFERING AND LISTING BY DOMESTIC
COMPANIES, OR THE “TRIAL MEASURES”, WHICH BECAME EFFECTIVE ON MARCH 31, 2023. PURSUANT TO THE TRIAL MEASURES, COMPANIES ORGANIZED
IN CHINA THAT SEEK TO OFFER OR LIST SECURITIES OVERSEAS, BOTH DIRECTLY OR INDIRECTLY THROUGH A PARENT COMPANY, MUST FULFILL A FILING PROCEDURE
AND REPORT RELEVANT INFORMATION TO THE CSRC. TO DATE, WE HAVE NOT RECEIVED ANY INQUIRY, NOTICE, WARNING OR SANCTIONS FROM THE CSRC OR
ANY OTHER PRC GOVERNMENTAL AUTHORITIES RELATING TO THE LISTING OF JRSIS COMMON STOCK ON THE OTC PINK MARKET. AS THE TRIAL MEASURES ARE
NEWLY PUBLISHED AND THERE IS UNCERTAINTY WITH RESPECT TO THE FILING REQUIREMENTS AND THE IMPLEMENTATION, IF WE ARE REQUIRED TO SUBMIT
TO THE CSRC AND COMPLETE THE FILING PROCEDURES IN CONNECTION WITH ANY FUTURE SECURITIES OFFERING BY JRSIS, WE CANNOT BE SURE THAT WE WILL
BE ABLE TO COMPLETE SUCH FILINGS IN A TIMELY MANNER. ANY FAILURE OR PERCEIVED FAILURE BY US TO COMPLY WITH SUCH FILING REQUIREMENTS UNDER
THE TRIAL MEASURES MAY RESULT IN FORCED CORRECTIONS, WARNINGS AND FINES AGAINST US AND COULD MATERIALLY HINDER OUR ABILITY TO OFFER JRSIS
SECURITIES.

    Page 2 of 15

IN ADDITION, CHANGES
IN THE LEGAL, POLITICAL AND ECONOMIC POLICIES OF THE CHINESE GOVERNMENT, THE RELATIONS BETWEEN CHINA AND THE UNITED STATES, OR CHINESE
OR U.S. REGULATIONS MAY MATERIALLY AND ADVERSELY AFFECT OUR BUSINESS, FINANCIAL CONDITION AND RESULTS OF OPERATIONS. ANY SUCH CHANGES
COULD SIGNIFICANTLY LIMIT OR COMPLETELY HINDER OUR ABILITY TO OFFER OR CONTINUE TO OFFER JRSIS SECURITIES TO INVESTORS AND COULD CAUSE
THE VALUE OF OUR SECURITIES TO SIGNIFICANTLY DECLINE OR BECOME WORTHLESS. FOR EXAMPLE, ON DECEMBER 28, 2021, THE CYBERSPACE ADMINISTRATION
OF CHINA (THE “CAC”) JOINTLY WITH THE RELEVANT AUTHORITIES FORMALLY PUBLISHED MEASURES FOR CYBERSECURITY REVIEW (2021) WHICH
TOOK EFFECT ON FEBRUARY 15, 2022 AND REPLACED THE FORMER MEASURES FOR CYBERSECURITY REVIEW (2020). MEASURES FOR CYBERSECURITY REVIEW (2021)
STIPULATES THAT OPERATORS OF CRITICAL INFORMATION INFRASTRUCTURE PURCHASING NETWORK PRODUCTS AND SERVICES AND ANY ONLINE PLATFORM OPERATOR
WHO CONTROLS MORE THAN ONE MILLION USERS’ PERSONAL INFORMATION MUST GO THROUGH A CYBERSECURITY REVIEW BY THE CYBERSECURITY REVIEW
OFFICE IF IT SEEKS TO HAVE ITS SECURITIES LISTED IN A FOREIGN COUNTRY. GIVEN THAT: (I) WE DO NOT POSSESS PERSONAL INFORMATION ON MORE
THAN ONE MILLION USERS IN OUR BUSINESS OPERATIONS; AND (II) DATA PROCESSED IN OUR BUSINESS DOES NOT HAVE A BEARING ON NATIONAL SECURITY
AND THUS MAY NOT BE CLASSIFIED AS CORE OR IMPORTANT DATA BY THE AUTHORITIES, WE DO NOT BELIEVE AN OFFERING OF SECURITIES BY JRSIS WOULD
NECESSITATE AN APPLICATION FOR A CYBERSECURITY REVIEW UNDER THE MEASURES FOR CYBERSECURITY REVIEW (2021).

HOWEVER, SINCE THESE
STATEMENTS AND REGULATORY ACTIONS BY THE PRC GOVERNMENT AUTHORITIES ARE NEWLY PUBLISHED AND THE OFFICIAL GUIDANCE AND RELATED IMPLEMENTATION
RULES HAVE NOT BEEN ISSUED, IT IS HIGHLY UNCERTAIN WHAT THE POTENTIAL IMPACT SUCH MODIFIED OR NEW LAWS AND REGULATIONS WILL HAVE ON OPERATIONS
OF LAIDIAN, ITS ABILITY TO ACCEPT FOREIGN INVESTMENTS AND THE ABILITY OF JRSIS TO MAINTAIN A LISTING IN THE U.S. WITHOUT RECRIMINATION
BY THE PRC AUTHORITIES. IF THE CSRC, CAC OR OTHER REGULATORY AGENCIES IN THE FUTURE PROMULGATE LAWS, REGULATIONS OR IMPLEMENTING RULES
REQUIRING THAT WE OBTAIN THEIR APPROVALS FOR A SECURITIES OFFERING, THERE IS NO ASSURANCE THAT WE CAN OBTAIN THE APPROVAL, AUTHORIZATIONS,
OR COMPLETE REQUIRED PROCEDURES OR OTHER REQUIREMENTS IN A TIMELY MANNER, OR AT ALL. IN THE EVENT THAT LAIDIAN (I) DOES NOT RECEIVE OR
MAINTAIN ANY REQUISITE PERMISSIONS OR APPROVALS, (II) INADVERTENTLY CONCLUDES THAT SUCH PERMISSIONS OR APPROVALS ARE NOT REQUIRED, OR
(III) APPLICABLE LAWS, REGULATIONS, OR INTERPRETATIONS CHANGE AND LAIDIAN IS REQUIRED TO OBTAIN SUCH PERMISSIONS OR APPROVALS IN THE FUTURE,
LAIDIAN MAY BE SUBJECT TO SANCTIONS IMPOSED BY THE RELEVANT PRC REGULATORY AUTHORITY, INCLUDING FINES AND PENALTIES, REVOCATION OF THE
LICENSES AND SUSPENSION OF ITS BUSINESS, RESTRICTIONS OR LIMITATIONS ON THE ABILITY OF JRSIS TO PAY DIVIDENDS OUTSIDE OF CHINA, REGULATORY
ORDERS, INCLUDING INJUNCTIONS REQUIRING LAIDIAN TO CEASE BUSINESS OPERATION, LITIGATION OR ADVERSE PUBLICITY, AND OTHER FORMS OF SANCTIONS,
WHICH MAY RESULT IN A MATERIAL CHANGE IN THE OPERATIONS OF LAIDIAN, SIGNIFICANTLY LIMIT OR COMPLETELY HINDER THE ABILITY OF JRSIS TO OFFER
SECURITIES TO INVESTORS, AND THE MARKET PRICE OF JRSIS COMMON STOCK MAY SUBSTANTIALLY DECLINE OR BECOME WORTHLESS.

 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.

    Page 3 of 15

Response to Comment 3

As requested, the following disclosure has been inserted
at page 13 of the Amendment:

PRC Policies Regarding PCAOB Inspection of
Auditors

Pursuant to the Holding Foreign Companies Accountable
Act (“HFCAA”), as adopted by the United States Congress, the Public Company Accounting Oversight Board (the “PCAOB”)
issued a Determination Report on December 16, 2021 which found that the PCAOB was unable to inspect or investigate completely registered
public accounting firms headquartered in: (1) mainland China of the People’s Republic of China because of a position taken by one
or more authorities in mainland China; and (2) Hong Kong, a Special Administrative Region and dependency of the PRC, because of a position
taken by one or more authorities in Hong Kong. In addition, the PCAOB’s report identified the specific registered public accounting
firms which are subject to these determinations. Our registered public accounting firm, Centurion ZD CPA & Co. is headquartered in
Hong Kong and was identified in this report as a firm subject to the PCAOB’s determination. As a result, on May 13, 2022, the SEC
listed JRSIS as a Commission-Identified Issuer under the HFCAA, which made JRSIS subject to sanctions if the Hong Kong authorities continued
to prevent the PCAOB from inspecting our auditor. Under the HFCAA (as amended by the Consolidated Appropriations Act – 2023), JRSIS
securities may be prohibited from trading on a U.S. stock exchange or facility if our auditor is not inspected by the PCAOB for two consecutive
years, and this ultimately could result in JRSIS common stock being removed from the OTC Pink Market.

On August 26, 2022, the China Securities Regulatory
Commission (“CSRC”), the Ministry of Finance of China, and the PCAOB signed a protocol governing inspections and investigations
of audit firms based in China and Hong Kong. On December 15, 2022, the PCAOB issued
a new Determination Report which: (1) vacated the December 16, 2021 Determination Report; and (2) concluded that the PCAOB had been able
to conduct inspections and investigations completely in Hong Kong in 2022. The December 15, 2022 Determination Report cautions, however,
that authorities in Hong Kong might take positions at any time that would prevent the PCAOB from continuing to inspect or investigate
completely. As required by the HFCAA, if in the future the PCAOB determines it no longer can inspect or investigate completely because
of a position taken by an authority in Hong Kong, the PCAOB will act expeditiously to consider whether it should issue a new determination.
If the PCAOB is not able to fully conduct inspections of our auditor’s work papers in China, you may be deprived of the benefits
of such inspection which could result in limitation or restriction to our access to the U.S. capital markets and trading of JRSIS securities
may be prohibited under the 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.

Response to Comment 4

As requested, the following disclosure has been inserted
at page 4, and the remainder of the Amendment has been edited to comply with the nomenclature described in that disclosure.

Identification of Consolidated Entities

JRSIS Health Care Corporation is a Florida corporation
whose business operations are carried out in the People’s Republic of China (“China” or the “PRC”) by Laidian
Technology (Zhongshan) Co., Ltd. JRSIS Health Care Corporation owns 100% of the equity in Laidian Technology (Zhongshan) Co., Ltd. through
two wholly owned subsidiaries: JRSIS Health Care Limited and Runteng Medical Group Company Limited.

In this Report, JRSIS Health Care Corporation
and its subsidiaries are identified as follows:

 ● “JRSIS” identifies JRSIS Health Care Corporation,
a Florida corporation.

 ● “JRSIS–BVI” identifies JRSIS Health Care Limited,
a wholly-owned subsidiary of JRSIS that is organized in the British Virgin Islands (“BVI”).

    Page 4 of 15

 ● “Runteng” identifies Runteng Medical Group Company
Limited, a wholly-owned subsidiary of JRSIS-BVI that is organized in Hong Kong.

 ● “Laidian” identifies Laidian Technology (Zhongshan)
Co., Ltd., a wholly-owned subsidiary of Runteng that is organized in the PRC.

 ● “Company” identifies JRSIS, JRSIS-BVI, Runteng and
Laidian as an entity consolidated for financial reporting purposes.

 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.

Response to Comment 5

As requested, the following disclosure has been added at page 10 of
the Amendment:

Intra-Company Transfer of Funds

In the Spring of 2022 JRSIS spun-off Jiarun Hospital,
the PRC entity that had been JRSIS’ sole operating company, and organized Laidian to serve as its sole operating company for the
immediate future. Since that restructuring, no funds have been transferred from JRSIS (or its subsidiaries) to Laidian or from Laidian
to JRSIS (or its subsidiaries), nor has any attempt been made to effect suc