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Sentage Holding Inc.

501, Platinum Tower 233 Taicang Road

HuangPu, Shanghai City 200001, People’s
Republic of China

October 18, 2023

VIA EDGAR

Ms. Aisha Adegbuyi

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

    Re:
    Sentage Holdings Inc.

    Annual Report on Form 20-F for Fiscal Year Ended December 31, 2022

    Response dated September 15, 2023

    File No. 001-40580

Dear Ms. Adegbuyi:

This letter is in response to the letter dated
October 3, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Sentage Holdings Inc. (the “Company”, “we”, or “our”). For ease of reference, we have
recited the Commission’s comments in this response and numbered them accordingly.

Annual Report on Form 20-F for the Fiscal Year Ended December 31,
2022

Item 5. Operating and Financial Review and Prospects

Operating expenses, page 97

    1.

    Please refer to prior comment 12. We note
that your proposed disclosure in your response is nearly the same as the existing disclosure on page 97 of your Form 20-F for the year
ended December 31, 2022. Please revise future filings, and provide us with a draft of your proposed disclosure, to disclose the individual
material components which make up your total selling, general and administrative expenses for the reporting periods presented. For example,
your disclosure should:

 ● identify and quantify each individually significant component
of selling, general and administrative expenses;

 ● quantify the change in each respective component during each
period; and

 ● discuss the reasons for the increases or decreases in the
specific dollar amounts for each of the components identified.

RESPONSE: We acknowledge the Staff’s
comment and will provide the required disclosures per the Staff’s comment in future filings. Please see a draft of our proposed
disclosure as follows:

 Our selling, general and administrative expenses
mainly consisted of professional expenses, employee compensation, rental expenses, depreciation expenses, office expenses and other expenses,
such as travel expenses and entertainment expenses, etc.

 For the fiscal years ended December 31, 2022 and
2021, our selling, general and administrative expenses amounted to $2,714,546 and $3,006,859, respectively. For fiscal year 2022, there
was a decrease of $292,313, or 9.7%, as compared with fiscal year 2021. The decrease was primarily attributable to the following: (i)
a decrease in the professional fees, due to the fact that the Company incurred one-time professional fees of $543,894 in relation to its
initial public offering in fiscal year 2021; (ii) an increase of $161,184 in employee compensation, such as basic salaries, social insurance,
and remuneration for the Company’s directors, which the Company did not incur prior to its initial public offering in fiscal year
2021; (iii) an increase in the rental expenses of $119,269, due to the new lease contracts signed in October 2021; and (v) a decrease
of $28,872 in the other expenses, such as office expenses, R&D expenditure, and travel expenses, as a result of decreased business
activities due to COVID-19 lock-downs in fiscal year 2022.

Convenience translation, page F-13

    2.
    Please refer to prior comment 16. We note in your proposed disclosure that you perform translation for income and expense items using the average exchange rate for “the next financial year.” Please tell us how this policy complies with the guidance in ASC 830 or, if accurate, revise your disclosure to clarify that your translation of income and expense items uses an average exchange rate for the periods presented in the consolidated financial statements. Refer to ASC 830-10-55-10 and 55-11.

RESPONSE: We acknowledge the Staff’s
comment, and will revise the related disclosure in the next filling as follows:

The functional and reporting currency of the Company
is the United States Dollar (“US$”). The Company’s operating subsidiaries in China uses Renminbi (“RMB”)
as the functional currency.

The consolidated financial statements of the Company
and its subsidiaries are translated into US$ using the exchange rate as of the balance sheet date for assets and liabilities, and using
the average exchange rate for income and expense items for the financial year. Assets and liabilities denominated in foreign currencies
at the balance sheet date are translated at the applicable rates of exchange in effect at that date. The equity denominated in the functional
currency is translated at the historical rate of exchange at the time of capital contribution. Because cash flows are translated based
on the average translation rates, amounts related to assets and liabilities reported on the consolidated statements of cash flows will
not necessarily agree with changes in the corresponding balances on the consolidated balance sheets. Translation adjustments arising from
the use of different exchange rates from period to period are included as a separate component of accumulated other comprehensive income
(loss) included in the consolidated statements of changes in shareholders’ equity. Translation gains and losses are recognized in
the consolidated statements of comprehensive income and other comprehensive income (loss) as other comprehensive income or loss.

Except for the shareholders’ equity, the
consolidated balance sheet accounts on December 31, 2022 and 2021 were translated at RMB6.8972 and RMB6.3757 to $1.00, respectively. The
shareholders’ equity accounts were translated at their historical rate. The average translation rate applied to consolidated statements
of comprehensive income and other comprehensive income (loss) for the years ended December 31, 2022 and 2021 was RMB6.7290 to $1.00 and
RMB6.4508 to $1.00, respectively. Consolidated cash flows were also translated at average translation rates for the periods. Therefore,
amounts reported on the consolidated statements of cash flows will not necessarily agree with changes in the corresponding balances on
the consolidated balance sheets.

General

    3.
    We note that you responded to prior comments 1, 2, 4 and 7 with a statement that you will make the requested changes in future filings. Provide us with an example of the responsive disclosure to each comment in your response to this comment letter.

RESPONSE: Please see our proposed revised disclosure in response
to prior comments 1, 2, 4 and 7 as follows:

Introduction, page ii:

    1.
    In future filings, disclose each permission or approval that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors. State whether you, your subsidiaries, or VIEs are covered by permissions requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that is required to approve the VIE’s operations, and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors if you, your subsidiaries, or the VIEs: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

RESPONSE: We acknowledge the Staff’s comment, and will
provide the below disclosure under “Introduction” in the next filing:

    2

Permissions from the PRC Authorities

As of the date of this annual report, we, our
PRC subsidiary, and the VIEs have received from PRC authorities all requisite licenses, permissions, and approvals needed to engage in
the businesses currently conducted in the PRC, and no such permission or approval has been denied. These licenses, permissions, and approvals,
which have been successfully obtained, are: (1) business licenses; and (2) third-party payment license. However, in the future, if any
additional approvals or permissions are required, we cannot assure you that any of these entities will be able to receive clearance of
compliance requirements in a timely manner, or at all. Any failure to fully comply with any compliance requirements may cause our PRC
subsidiary, or the VIEs, to be unable to operate their businesses in the PRC, subject them to fines, relevant businesses or operations
suspension for rectification, or other sanctions.

On December 28, 2021, 13 governmental departments
of the PRC, including the CAC, issued the revised Cybersecurity Review Measures, which became effective on February 15, 2022. The Cybersecurity
Review Measures require that any network platform operator which possesses the personal information of at least one million users must
apply for a cybersecurity review by the CAC if it intends to be listed in foreign countries. As advised by our PRC counsel, the operations
of the PRC operating entities (our PRC subsidiary and the VIEs) and our continued listing will not be affected and that we will not be
subject to cybersecurity review by the CAC, given that the PRC operating entities (i) possess personal data of fewer than one million
individual clients; (ii) do not collect data that affects or may affect national security in their business operations, as of the date
of this annual report; and (iii) do not anticipate that they will be collecting over one million users’ personal information or
data that affect or may affect national security in the near future. However, as uncertainties remain regarding the interpretation and
implementation of these laws and regulations, we cannot assure you that we will be able to comply with such regulations in all respects,
and we may be ordered to rectify or terminate any actions that are deemed illegal by regulatory authorities. We may also become subject
to fines and/or other sanctions and the costs of compliance with, and other burdens imposed by such laws and regulations may limit the
use and adoption of our products, which may have material adverse effects on our business, operations, and financial condition.

In addition, on February 17, 2023, the CSRC promulgated
the Trial Administrative Measures of Overseas Securities Offering and Listing by Domestic Enterprises (the “Trial Measures”)
and released five supporting guidelines, which took effect on March 31, 2023. Pursuant to the Trial Measures, PRC domestic companies that
seek to offer or list securities overseas, both directly and indirectly, shall file with the CSRC pursuant to the requirements of the
Trial Measures within three working days following submission of relevant application for listing or completion of any subsequent offerings.
If a domestic company fails to complete required filing procedures or conceals any material facts or falsifies any major content in its
filing documents, such domestic company may be subject to administrative penalties, such as an order to rectify, warnings, and fines,
and its controlling shareholders, actual controllers, and the person directly in charge and other directly liable persons may also be
subject to administrative penalties, such as warnings and fines. The CSRC also held a press conference for the release of the Trial Measures
and issued the CSRC Notice, which, among other things, clarified that PRC domestic companies that were listed overseas before the effective
date of the Trial Measures shall be deemed to be “Existing Issuers”, who would not be required to complete the filing procedure
with the CSRC immediately, but shall be required to file with the CSRC for any subsequent offerings. Based on the foregoing, we are an
Existing Issuer, and will be required to file with the CSRC within three working days following the completion of any subsequent overseas
offerings.

As of the date of this annual report, we believe
that, except as described above, none of the Company, our PRC subsidiary, or the VIEs, will be required to obtain permission from the
CSRC, the CAC, or any other Chinese authorities to offer our securities based on PRC laws and regulations currently in effect, and we
have not been denied such permission by any Chinese authorities. However, we cannot assure you that the PRC regulatory agencies, including
the CAC or the CSRC, would take the same view as we do, and there is no assurance that our PRC subsidiary, or the VIEs, will always be
able to successfully update or renew the licenses or permits required for the relevant business in a timely manner or that these licenses
or permits are sufficient to conduct all of their present or future business. If our PRC subsidiary, or the VIEs (i) do not receive or
maintain required permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii)
applicable laws, regulations, or interpretations change and our PRC subsidiary, or the VIEs, are required to obtain such permissions or
approvals in the future, they could be subject to fines, legal sanctions, or an order to suspend their relevant services, which may materially
and adversely affect our financial condition and results of operations and cause our securities to significantly decline in value or become
worthless.

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    2.
    In your next 20-F, provide a clear description of how cash is transferred through your organization. Disclose your intentions to distribute earnings or settle amounts owed under the VIE agreements. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company, its subsidiaries, and the consolidated VIEs, and direction of transfer. Quantify any dividends or distributions that a subsidiary or consolidated VIE 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. 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 and/or the consolidated VIEs, to the parent company and U.S. investors as well as the ability to settle amounts owed under the VIE agreements. Affirmatively state if you have requested approval to transfer cash to the WFOE or to entities outside of China, and if you have requested permission, and identify specifically any time when permission was denied or the relevant authority otherwise declined to provide permission.

RESPONSE: We acknowledge the Staff’s
comment, and will provide the following disclosure under the Introduction” section in the next filing:

Distributions and
Dividends

Under existing PRC foreign
exchange regulations, payment of current account items, such as profit distributions and trade and service-related foreign exchange transactions,
can be made in foreign currencies without prior approval from the State Administration of Foreign Exchange, or the SAFE, by complying
with certain procedural requirements. Therefore, our PRC subsidiary is able to pay dividends in foreign currencies to us without prior
approval from the SAFE, subject to the condition that the remittance of such dividends outside of the PRC complies with certain procedures
under PRC foreign exchange regulations, such as the overseas investment registrations by our shareholders or the ultimate shareholders
of our corporate shareholders who are PRC residents. Approval from, or registration with, appropriate government authorities is, however,
required where the RMB is to be converted into foreign currency and remitted out of China to pay capital expenses such