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July 5, 2023
Hung To Pau, Ph.D.
Chief Executive Officer
Advanced Biomed Inc.
689-87 Xiaodong Road
Yongkang District
Tainan, Taiwan
Re:Advanced Biomed Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed June 20, 2023
File No. 333-272110
Dear Hung To Pau:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our June 7, 2023 letter.
Form S-1/A Filed June 20, 2023
Our Industry, page 69
1.We note in your discussions of Grand View Research, Inc.'s market analysis report, on
pages 11, 69, and 70, that the market size was "anticipated to grow at a CAGR of 13.5%
during the forecast period..." which appears to be 2020-2028.  Please revise this
discussion to clarify the "forecast period" and disclose whether the market value has
grown, as forecasted, since publication.  Please also discuss any material assumptions
underlying this market size calculation.

 FirstName LastNameHung To Pau, Ph.D.
 Comapany NameAdvanced Biomed Inc.
 July 5, 2023 Page 2
 FirstName LastName
Hung To Pau, Ph.D.
Advanced Biomed Inc.
July 5, 2023
Page 2
Business
Commercialization Preparation, page 78
2.We note your response to previous comment 5 and reissue in part.  Please revise to clarify
the rights and obligations of the parties engaged in the research project equipment use
contract with TSRI.  To the extent that the "design and test production of certain flow
channel" mentioned on page 36 is a subset of the tasks listed on page 78 (your use of
"their semiconductor manufacturing equipment and precision micro-nano processing
equipment for chip technology research and development such as concept presentation of
each R&D process, cross-scale composite structure production, rapid wafer trial
production, material testing, and thin film production") please revise to clarify this.
National Medical Insurance Program, page 92
3.We note your response to previous comment 7.  We also note your statement on page 92:
“Although we strive to make our products covered by the NMIP in the future, there is no
guarantee that the NHSA will approve our applications.”  Please revise to state, as you do
in your response letter dated June 20, 2023, that A+LCGuard is the only product for
which you are applying for National Medical Insurance Program coverage.
Note 1. Organization and Principal Activities, page F-22
4.We note your response to comment 11.  It appears that Advanced Biomed Inc. (Taiwan)
as well as Advanced Biomed Inc. were not under common control until June 8, 2022 upon
which date Sglcell Ltd transferred all of its 8,000,000 shares to Dr. Yi Lu for total
consideration of $8,000.  Given that your disclosures indicate that the financial statements
include the results of operations of Advanced Biomed Inc. (Taiwan) for two operating
periods, please tell us what consideration you gave to ASC 805-50-45-5 which states
that comparative information in prior years shall only be adjusted for periods during
which the entities were under common control.

Note 11. Restatement, page F-32
5.We note your response to comment 10.  Please also address whether
a material weakness was identified, and if so, what consideration was given to including a
risk factor describing the material weakness, resulting restatement, and any associated
remediation procedures.

 FirstName LastNameHung To Pau, Ph.D.
 Comapany NameAdvanced Biomed Inc.
 July 5, 2023 Page 3
 FirstName LastName
Hung To Pau, Ph.D.
Advanced Biomed Inc.
July 5, 2023
Page 3
            You may contact Nudrat Salik at 202-551-3692 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Benjamin Richie at 202-551-7857 or Margaret Schwartz at 202-551-7153 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Fang Liu, Esq.