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November 30, 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. 6 to Registration Statement on Form S-1
Filed November 20, 2023
File No. 333-272110
Dear Hung To Pau:
            We have reviewed your amended registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our November 6, 2023 letter.
Amendment No. 6 to Form S-1
Cover Page
1.We note that on the cover page you state that "[a]ny overseas offering and listing made by
an issuer that meets both the following conditions will be determined as indirect offering
and listing in overseas market and, therefore, be subject to filing requirement: (i) 50% or
more of the issuer’s operating revenue, total profit, total assets or net assets as
documented in its audited consolidated financial statements for the most recent accounting
year is accounted for by domestic companies; and (ii) the main parts of the issuer’s
business activities are conducted in the Mainland China, or its main places of business are
located in the Mainland China, or the senior managers in charge of its business operation
and management are mostly Chinese citizens or domiciled in the Mainland China" and
that you "do not believe that [you] are required to obtain the approval from or complete
the filing with the CSRC for this offering...based on the fact that [you] do not meet the

 FirstName LastNameHung To Pau, Ph.D.
 Comapany NameAdvanced Biomed Inc.
 November 30, 2023 Page 2
 FirstName LastName
Hung To Pau, Ph.D.
Advanced Biomed Inc.
November 30, 2023
Page 2
explicit conditions set out in the Trial Measures to determine whether an overseas offering
shall be deemed as a direct or an indirect overseas offering and listing by a domestic
company." Please revise to expressly explain the criteria you considered specific to your
business that formed the basis of your determination that you do not meet these conditions
for filing. Please also revise to state whether you relied on an opinion of counsel for this
determination.
            Please 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.