SecProbe.io

Mail Stop 4631

July 20, 2017

Luisa Ingargiola
Chief Financial Officer
Avalon GloboCare Corp.
83 South Street, Suite 101
Freehold, NJ 07728

Re: Avalon GloboCare Corp.
Amendment No. 1 to Registration Statement on Form S -1
Filed July 7, 2017
  File No. 333 -217809

Dear Ms. Ingargiola :

We have reviewed your registration statement  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 this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not bel ieve an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Prospectus Summary, page 1

Common Stock Offered by Us, page 2

1. We note your response to comment 5 of our letter dated June 5, 2017.  We reissue our
comment.  Based on disclosure in your risk factor entitled “There is no minimum raise
required . . .” on page 15 and in your Us e of Proceeds on page 19, it appears that if you
raise $2,000,000 or less, you will use proceeds only for general and administrative
expenses and working capital, and will not be able to implement your business plan.
However, narrative disclosure on pages  2 and 19  states that if you sell any less than
$5,000,000, you will utilize the proceeds in your operations, but will not be able to
implement your business plan.  Please reconcile these disclosures, and clarify the
minimum amount you will need to be abl e to begin implementing your business plan, as
opposed to only covering general and administrative expenses and working capital.

Luisa Ingargiola
Avalon GloboCare Corp.
July 20, 2017
Page 2

 Terms of the Offering, page 21

2. This section describes the plan of distribution for the company’s offering.  Please
consider adding this discussion to the discussion of the selling shareholder’s plan of
distribution under “Plan of Distribution” on page 51, or otherwise revising the title of this
section to indicate that this is your plan of distribution for the company’s offe ring and the
section on page 61 is the plan of distribution for the selling shareholders.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
23

Critical Accounting Policies and Estimates, page 24
Stock -based Compe nsation, page 25

3. We note your response to prior comment ten where you stated that “the revaluation does
not apply to these shares issued to the attorney and consultants.”  In this regard, please
revise your registration statement to delete the last sentence in the second paragraph of
your disclosure.  This comment also applies to your related significant accounting policy
in Note 3 on pages F -10 and F -28.

Cash Flows, page 30

4. We note that you removed your discussion of cash flows for the year ended December
31, 2016 as compared to the period from May 18, 2015 ( date of inception) through
December 31, 2015 .  Your discussion of cash flows should be provided for both the
annual and interim periods.  Please revise your registration statement to reinstate your
previous disclosure.

Consolidated Financial Statements, page F -1

Note 11 – Commitments and Contingencies, page F -35
Real property purchase agreement, page F -36

5. Please expand your disclosure to address the business purpose for purchasing the
property.

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.

Refer to Rules 460 and 461 regarding reques ts for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Luisa Ingargiola
Avalon GloboCare Corp.
July 20, 2017
Page 3

 You may contact Dale Welcome, Staff Accountant , at (202) 551 -3865  or Kevin Stertzel,
Staff Accountant , at (202) 551 -3723  if you have questions regarding comments on the financial
statements and related matters.  Please contact Sergio Chinos, Staff Attorney,  at (202) 551 -7844
or me at (202) 551 -3765  with any other questions.

Sincerely,

 /s/ Pamela A. Long

 Pamela A. Long
Assistant Director
Office of Manufacturing and
Construction

cc: Stephen M. Fleming, Esq.