SecProbe.io

October 11, 2019
Chris Chang Yu
Chief Executive Officer
AnPac Bio-Medical Science Co., Ltd.
801 Bixing Street, Bihu County
Lishui, Zhejiang Province 323006
People's Republic of China
Re:AnPac Bio-Medical Science Co., Ltd.
Draft Registration Statement on Form F-1
Submitted September 20, 2019
CIK 0001786511
Dear Dr. Yu:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted September 20, 2019
General
1.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
Jurisdiction and Arbitration, page 162
2.We note your disclosure that "the arbitration provisions do not preclude ADS holders
from pursuing claims under the U.S. federal securities laws in federal courts."  Please

 FirstName LastNameChris Chang Yu
 Comapany NameAnPac Bio-Medical Science Co., Ltd.
 October 11, 2019 Page 2
 FirstName LastName
Chris Chang Yu
AnPac Bio-Medical Science Co., Ltd.
October 11, 2019
Page 2
ensure that this provision in the deposit agreement clearly states that, if true, the
arbitration provisions do not apply to the U.S. federal securities laws.
Undertakings, page II-2
3.Please provide the undertakings required by Item 512(a)(5)(ii) and Item 512(a)(6) of
Regulation S-K.  Item 512(a)(5)(ii) is required for any prospectus filed in reliance on Rule
430C and Item 512(a)(6) is required for any offering that involves an initial distribution of
securities pursuant to Rule 159A.  For guidance, refer to Securities Act Rules Compliance
and Disclosure Interpretation, Question 229.01.
            You may contact Jonathan Burr at 202-551-5833 or Brigitte Lippmann at 202-551-3713
with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Shuang Zhao