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Zhongchao
Inc.

Nanxi
Creative Center, Suite 218

841
Yan’ An Middle Road

Jing’
An District

Shanghai,
China 200040

November
21, 2019

VIA
EDGAR

Paul
Fischer

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Telecommunications

100
F Street, N.E.

Mail
Stop 4631

Washington,
DC 20549

 Re: Zhongchao
                                         Inc.

    Draft
                                         Registration Statement on Form F-1/A

    Amended
                                         on November 6, 2019

    CIK
                                         0001785566

Dear
Mr. Fischer:

Zhongchao
Inc. (the “Company”, “Zhongchao,” “we”, “us” or “our”)
hereby transmits its response to the letter received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”), dated November 15, 2019 regarding our Registration Statement on Form F-1 (the
“Registration Statement”) previously submitted on August 19, 2019 and amended on September 27, 2019 and November
6, 2019. For ease of reference, we have repeated the Commission’s comments in this response and numbered them accordingly.
An amended F-1 submitted in confidentiality accompanying this Response Letter is referred to as Form F-1.

Please
note that new language we are including in Form F-1 pursuant to your comments, is indicated in this letter in bold, italicized
font; any deletions from the initial Registration Statement are indicated in this letter as strikethrough font.

Amendment
No. 2 to Draft Registration Statement Filed November 6, 2019

Consolidated
Statements of Income and Comprehensive Income, page F-4

 1. Please
                                         revise your earnings per share here and elsewhere throughout the filing to round it to
                                         the nearest whole cent.

Response:
In response to the Staff’s comment, we have revised the earnings per share to round it to the nearest whole cent on page
F-4, F-29, F-38, and F-49 in the Form F-1.

Unaudited
Consolidated Financial Statements for the Six Months Ended June 30, 2019 and 2018

2.
Summary of Significant Accounting Policies

(c)
Revenue recognition, page F-43

 2. You
                                         indicated that for contracts engaged with non-for-profit organizations (“NFP”),
                                         you provide assistance in operation of patient aid projects and training courses and
                                         materials to doctors. We further note on page 68 that you also establish individual websites
                                         for these customers. Please quantify the amount of revenue recognized under these arrangements
                                         during 2018 and the most recent interim period presented. To the extent these revenues
                                         are material to any of the periods presented, please address the following:

 ● Explain
how you determined that the individual services provided under these arrangements should be combined into a single performance
obligation. Please refer to ASC 606-10-25-14 through 25-22.

 ● Disclose
if these arrangements are typically structured as fixed price contracts or if the transaction price includes any variable consideration.
Please refer to ASC 606- 10-50-17.

 ● Tell
us the time period over which you typically recognize revenues for these arrangements.

Response:
In response to the Staff’s comment, the amount of revenue recognized for the year ended December 31, 2018 and six months
ended June 30, 2019 were $nil and $1,785,484, respectively.

 Ÿ Explain how you determined that the individual
services provided under these arrangements should be combined into a single performance obligation. Please refer to ASC 606-10-25-14
through 25-22.

Response:

Our assistance
in operation of patient aid projects mainly consists of provision of training and knowledge of certain drugs to doctors, review
of patients’ applications, track of patients’ usage of drugs and collection of these information. The series of services
require the Company to provide management over the project period to integrate all activities so as to meet the purpose of the
patient aid project, i.e., qualified patients could get free drugs. Moreover, in practice, the Company has enforceable rights to
payments from customers until the free drugs are distributed to patients. Referring to ASC606-10-25-21(a), the Company believes
these activities are not separately identifiable in the context of the contract, and should be combined as one performance obligation.

Though we are
required to establish websites for the customers, we could only provide the series of services as described above to the customers
after the establishment of the websites. As such the Company believes the activity to establish websites does not transfer products
or services to the customers, and thus customers cannot benefit from such activity. Referring to ASC 606-10-25-17, the establishment
of websites is an administrative or set-up activity and is not identified as a performance obligation

 Ÿ Disclose if these arrangements are typically
structured as fixed price contracts or if the transaction price includes any variable consideration. Please refer to ASC 606-10-50-17.

Response:
These arrangements are structured as fixed-price contracts. The priced is determined as stated in contracts. The Company
did not identify variable consideration, noncash consideration and consideration payable to customers or significant financing
component in the contracts.

We have revised
the disclosure on page F-43 and page 80 of Form F-1 to clarify the determination of transaction price.

    2

Page F-43 and
Page 80

“Assistance in operation
of patient-aid projects

The Company is
engaged by not-for-profit organizations (“NFP”) to assist in operation of patient aid projects with a purpose to facilitate
qualified patients to obtain free drug treatment from NFPs. The Company is responsible to provide doctors with access to training
courses or training materials in connection with the drug treatment, review the completeness of application documents from patients,
and other ad-hoc works. These arrangements are structured as fixed-price contracts. The price is determined as stated in
contracts and does not include any variable consideration. The Company identifies a single performance obligation from
contracts and recognizes revenue over a period of time during which the Company provides the assistance to the NFPs till the free
drugs are completely delivered. The Company uses an input-based method to measure the progress, by reference to the cost incurred
in performing the obligation.”

 Ÿ Tell us the time period over which you
typically recognize revenues for these arrangements.

Response:
Pursuant to the contracts with customers, the Company recognizes revenues for these arrangements over the period from the
date the Company established the website to the earlier of the date when all drugs are delivered to patients or a predetermined
service end date in the contract. As we just launched these new projects in late 2018, the predetermined service end date is estimated
around 12 to 15 months from the signing of the contracts. However, in practice, all drugs are typically delivered to patients and
the contract expired within 6 months after the websites are established.

We
thank the Staff for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail
to our counsel, Arila Zhou at azhou@htflawyers.com or by telephone at 212-530-2207.

    Very
    truly yours,

    /s/
    Pei Xu

    Pei
        Xu

        CFO

 cc: Hunter
Taubman Fischer & Li LLC

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