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    Rooms 4301-10, 43/F., Gloucester Tower, The Landmark

    15 Queen’s Road Central, Hong Kong SAR, PRC

    Tel: +852 2820 5600 Fax: +852 2820 5611

    Beijing · Shanghai · Shenzhen · Hong Kong ·
    Haikou · Wuhan · Singapore · New York · Silicon Valley

    www.hankunlaw.com

August 5, 2025

Mr. Patrick Kuhn

Mr. Joel Parker

Mr. Scott Anderegg

Mr. Dietrich King

Office of Trade & Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    POMDOCTOR LIMITED (CIK No. 0001877971)

    Response to the Staff’s Comment on Amendment No. 3
                                                     to Registration Statement on

                                                     Form F-1 (File No. 333-285771) Filed on July 15, 2025

Dear Mr. Kuhn, Mr. Parker, Mr. Anderegg, Mr. King:

On behalf of our client, POMDOCTOR
LIMITED, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s response to the comment contained in the Staff’s letter dated July 24, 2025 on amendment
No. 3 to the Company’s registration statement on Form F-1 filed on July 15, 2025 (the “Registration Statement”).
Concurrently with the submission of this letter, the Company is filing its revised registration statement on Form F-1 (the “Revised
Registration Statement”) via EDGAR with the Commission.

Set forth below is the Company’s
response to the Staff’s comment. For convenience, the Staff’s comment is repeated below in bold, followed by the Company’s
response to such comment. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement.

Comment in Letter Dated July 24, 2025

Amendment No. 3 to Registration Statement on
Form F-1 filed July 15, 2025

Cover Page

 1. We note your revised disclosure that six ADS will represent
one class A ordinary shares. As such, it appears an investor could purchase a numbers of ADSs that is not divisible by six, and that
purchase would result in the investor having a fractional interest in an ordinary share. Please revise your disclosure to address the
material aspects of any such fractional interests.

In response to the Staff’s
comment, the Company advises the Staff that:

Under the Company’s
post-offering memorandum and articles of association, the Company’s directors may issue fractions of a share. If issued, a fractional
share shall carry proportionally the same liabilities, rights (including voting and participation rights), and other attributes as a whole
Class A ordinary share. If more than one fraction of a Class A ordinary share is issued to or acquired by the same shareholder, such fractions
shall be accumulated.

Pursuant to Section 2.3 and
Section 2.7 of the deposit agreement for the ADSs to be entered into immediately prior to the completion of this offering, the depositary
will not accept for deposit a number of Class A ordinary shares which upon application of the ADS to Class A ordinary share ratio would
give rise to fractional ADSs. In addition, the depositary will not accept a surrender of ADSs representing less than one full Class A
ordinary share. If an ADS holder surrenders ADSs representing a fractional share, the depositary will deliver whole shares for the portion
of the ADSs representing the whole number of Class A ordinary shares, and either (i) return the ADSs representing any remaining fractional
shares, or (ii) sell the fractional shares that those ADSs represent and distribute the net proceeds (after fees, taxes, and expenses)
to the holder.

The Company has revised the
disclosure on pages 156, 170 and 171 of the Revised Registration Statement accordingly.

* * *

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If you have any questions
regarding the Revised Registration Statement, please contact Steve Lin at steve.lin@hankunlaw.com, +86 10 8524 5826 (work) or +86 186
1049 5593 (cell).

Thank you for your time and
attention.

    Very truly yours,

    /s/ Steve Lin

    Steve Lin

    c.c.
    Zhenyang Shi, Chief Executive Officer, POMDOCTOR LIMITED

    Li Xu, Chief Financial Officer, POMDOCTOR LIMITED

    Steve Lin, Esq., Partner, Han Kun Law Offices
    LLP

    Dinglei Xiao, Partner, Marcum Asia CPAs LLP

    Richard I. Anslow, Esq., Partner, Ellenoff Grossman
    & Schole LLP

    Jonathan Deblinger, Esq., Partner, Ellenoff Grossman
    & Schole LLP

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