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        Giovanni Caruso

        Partner

        345 Park Avenue

        New York, NY 10154

        Direct

        Main

        Fax

                          212.407.4866

                          212.407.4000

                          212.937.3943

    gcaruso@loeb.com

Via Edgar

December 11, 2018

        Edward M. Kelly

        Division of Corporation Finance Office of

        Manufacturing and Construction

        U.S. Securities & Exchange Commission

        100 F Street, NE

        Washington, D.C. 20549

 Re: Chardan Healthcare Acquisition Corp.

Draft Registration Statement on Form S-1

Filed on November 26, 2018

File No. 333-228533

Dear Mr. Kelly:

On behalf of our client, Chardan Healthcare
Acquisition Corp. (the “Company”), we hereby provide a response to the comments issued in a letter dated December 11,
2018 (the “Staff’s Letter”) regarding the Company’s draft Registration Statement on Form S-1 (the “Registration
Statement”). Contemporaneously, we are submitting the amended draft Registration Statement via Edgar (the “Amended
S-1”).

In order to facilitate the review by the
Commission’s staff (the “Staff”) of the Amended S-1, we have responded, on behalf of the Company, to the comments
set forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s
comments and correspond to the numbered paragraph in the Staff’s Letter.

Los Angeles      New York      Chicago      Nashville
     Washington, DC      Beijing      Hong Kong      www.loeb.com

A limited liability partnership including
professional corporations

        Edward M. Kelly

        December 11, 2018

        Page 2

Pre-effective Amendment 1 to Registration
Statement on Form S-1 filed December 4, 2018

Exhibit 3.2, page 6

 1. We note that your forum selection provision identifies the Court of Chancery of the State of
Delaware as the exclusive forum for certain litigation, including any “derivative action.”  Please disclose whether
this provision applies solely to state law claims.  If it does not apply to solely state law claims, then please note that
Section 27 of the Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any duty or liability created
by the Exchange Act or the rules and regulations thereunder, and Section 22 of the Securities Act creates concurrent jurisdiction
for federal and state courts over all suits brought to enforce any duty or liability created by the Securities Act or the rules
and regulations thereunder.  If this provision applies to claims arising under the Securities Act, please disclose that there
is uncertainty as to whether a court would enforce such provision and to state that shareholders will not be deemed to have waived
the company’s compliance with the federal securities laws and the rules and regulations thereunder.  If this provision
does not apply to actions arising under the Securities Act or Exchange Act, please ensure that the exclusive forum provision in
the governing documents states this clearly.

In addition, under an appropriately
titled risk factor please describe the exclusive forum provision and the types of actions to which it relates, and disclose that
such a provision may limit a shareholder's ability to bring a claim in a judicial forum that it finds favorable for disputes with
the company and its directors, officers, or other employees and may discourage lawsuits with respect to such claims.

Response: Article Tenth of Exhibit
3.2 was removed in its entirety in response to the Staff’s comments.

Please call me at 212
407-4866 if you would like additional information with respect to any of the foregoing. Thank you.

Sincerely,

/s/ Giovanni Caruso

Giovanni Caruso

Partner