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Eshallgo Inc

12F Block 16, No.1000 Jinhai Road

Pudong New District

Shanghai, China 201206

December 18, 2023

Division of
Corporation Finance

Office of Trade &
Services

U.S. Securities
and Exchange Commission

Washington, D.C. 20549-4720

Attn: Scott Anderegg

    Re:
    Eshallgo Inc

    Amendment No. 5 to Registration Statement on Form F-1

    Filed November 20, 2023

    File No. 333-271478

Dear Mr. Anderegg:

This letter is in response to your letter on
November 15, 2023 in which you provided a comment to the Registration Statement on Form F-1 (the “Registration Statement”)
of Eshallgo Inc (the “Company”) filed with the U.S. Securities and Exchange Commission on November 20, 2023. On the date
hereof, the Company has submitted Amendment No. 6 to Registration Statement on Form F-1 (“Amendment No. 6”).
We set forth below in bold the comment in your letter relating to the F-1 followed by our response to the comment.

Amendment No. 5 to Registration Statement on Form F-1 filed
November 20, 2023

PRC laws and regulations governing our current business operations
are sometimes vague and uncertain. ..., page 48

    1.
    We note your revisions to your disclosure in response
    to our comment 2. However, we believe that you have not restored all of the disclosure we referenced. For example, you continue to
    state that the legal environment and/or system "has some differences" and you generally reference "differences,"
    rather than "uncertainties" in the PRC legal system. It is unclear to us that there have been changes in the regulatory
    environment in the PRC since the review of your amendment filed on June 30, 2023 warranting revised disclosure to mitigate the challenges
    you face and related disclosures. Please restore your disclosures here and in all other places where you discuss the legal risks
    of operating in China to the disclosures as they existed in the registration statement as of June 30, 2023.

RESPONSE:  We note the Staff’s comment,
and in response hereto, respectfully advise the Staff that we have revised the following PRC-related risk factors entitled to largely
restore to the previously submitted Amendment No. 4 on June 30, 2023:

 · We
                                            are subject to competitive pricing pressure from our customers on page 23.

 · A
                                            downturn in the Hong Kong, China or global economy, and economic and political policies of
                                            China could materially and adversely affect our business and financial condition on page
                                            27.

 · Market,
                                            economic and other conditions in China may adversely affect the demand for our products and
                                            services on page 37.

 · If
                                            the PRC government deems that the contractual arrangements in relation to Junzhang Shanghai
                                            or Junzhang Beijing, our consolidated variable interest entities, do not comply with PRC
                                            regulatory restrictions on foreign investment in the relevant industries, or if these regulations
                                            or the interpretation of existing regulations change in the future, we could be subject to
                                            severe penalties or be forced to relinquish our interests in those operations on
                                            page 41.

 · Our
                                            contractual arrangements are governed by PRC law. Accordingly, these contracts would be interpreted
                                            in accordance with PRC law, and any disputes would be resolved in accordance with PRC legal
                                            procedures on page 43

 · Any
                                            failure by Junzhang Shanghai and Junzhang Beijing, our consolidated VIEs, or their shareholders
                                            to perform their obligations under our contractual arrangements with them would have a material
                                            adverse effect on our business on page 44.

 · PRC
                                            laws and regulations governing our current business operations are sometimes vague and uncertain.
                                            Rules and regulations in China may change quickly with little advance notice. Uncertainties
                                            in the interpretation and enforcement of PRC laws and regulations could limit the legal protection
                                            available to you and us. Any changes in such laws and regulations may impair our ability
                                            to operate profitably on page 49.

We further respectfully advise the Staff that,
as communicated telephonically on December 13, 2023, when disclosure involving a comparison of the PRC jurisdiction to other jurisdictions
is made, we have not restored to the exact Amendment No. 4 disclosure to the extent that the PRC law system is “not as developed”
as compared to other jurisdictions, as it is not an accurate statement. However, we have revised the disclosure to emphasize the uncertainties
surrounding the PRC legal system as instructed under the Sample Letters to China-Based Companies.

We hope this response has addressed all of the
Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein,
please contact our securities counsel William S. Rosenstadt, Esq., Jason Ye, Esq. or Yarona Yieh, Esq. of Ortoli Rosenstadt
LLP at wsr@orllp.legal, jye@orllp.legal or yly@orllp.legal.

    Sincerely,

    /s/ Qiwei Miao

    Qiwei Miao

    Chief Executive Officer