SecProbe.io

CORRESP
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    Unit 2901, 29F, Tower C

    Beijing Yintai Centre

    No. 2 Jianguomenwai Avenue

    Chaoyang District, Beijing 100022

    People’s Republic of China

    Phone: 86-10-6529-8300

    Fax: 86-10-6529-8399

    Website: www.wsgr.com

    中国北京市朝阳区建国门外大街2号

    银泰中心写字楼C座29层2901室

    邮政编码: 100022

    电话: 86-10-6529-8300

    传真: 86-10-6529-8399

    网站: www.wsgr.com

Confidential

January 25, 2023

Ms. Li Xiao

Ms. Angela
Connell

Mr. Jimmy McNamara

Mr. Jason
Drory

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:        YishengBio Co., Ltd (CIK No. 0001946399)

Response to the Staff’s Comments on

Amendment No. 1 to Registration Statement on
F-4

Filed on January 13, 2023

File No. 333-269031

Dear Ms. Li Xiao, Ms. Connell,
Mr. McNamara and Mr. Drory,

On behalf of our client, YishengBio
Co., Ltd, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are hereby
submitting to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated January 19, 2023 on
the Company’s amendment No. 1 to registration statement on Form F-4 filed on January 13, 2023. Concurrently with the submission
of this letter, the Company is filing its Amendment No. 2 to the registration statement on Form F-4 (the “Registration Statement”)
and certain exhibits via EDGAR to the Commission.

To facilitate your review,
we have separately sent to you via email today a copy of the Registration Statement, marked to show changes to the amendment No. 1 to
registration statement on Form F-4, and will, upon your request, deliver paper copies of the same to you.

The Staff’s comments
are repeated below in bold and are followed by the Company’s responses. We have included page references in the Registration Statement
where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings
set forth in the Registration Statement.

Wilson Sonsini Goodrich &
Rosati, Professional Corporation

威尔逊· · 桑西尼· ·古奇 ··罗沙迪律师事务所

austin   beijing   boston   brussels   hong kong   london   los angeles   new york   palo alto

san diego   san francisco   seattle   shanghai   washington, dc   wilmington, de

Page 2

Unaudited Pro Forma Condensed Combined Financial Information

Note 1. Basis of Presentation, page 335

 1. We note your response to our prior comment 2 and the revisions made to your pro forma financial information,
including changes to the periods presented in your Pro Forma Condensed Combined Statements of Operations (i.e., year ended December 31,
2021 and the nine months ended September 30, 2022.) Please note that the age of the pro forma financial information included in a registration
statement should be based on the age of financial statements requirement applicable to the registrant. Accordingly, as YS Biopharma is
the registrant, it is unclear why you have not presented your Pro Forma Condensed Combined Statements of Operations for the year ended
March 31, 2022 and the six months ended September 30, 2022 consistent with the financial statements presented for YS Biopharma beginning
on page F-42. Please revise accordingly.

RESPONSE: In
response to the Staff’s comment, the Company has revised the Pro Forma Condensed Combined Statement of Operations on pages
13, 54, 55, 56, 57, 327 and 330-338 of the Registration Statement.

The unaudited pro forma condensed
combined statement of operations for the fiscal year ended March 31, 2022 combines the unaudited condensed statement of operations
of Summit for twelve months ended March 31, 2022 with the audited condensed consolidated statement of operations of YS Biopharma for
the fiscal year ended March 31, 2022. Summit’s results for its 12-month period are derived by adding the results of the
three-month period ended March 31, 2022, to its income statement for the year ended December 31, 2021, and subtracting the results
of the three-month period ended March 31, 2021.

The unaudited pro forma condensed combined
statement of operations for the six months ended September 30, 2022 combines the unaudited condensed statement of operations of Summit
for the six months ended September 30, 2022 with the unaudited condensed consolidated statement of operations of YS Biopharma for the
six months ended September 30, 2022.

General

 2. Please revise throughout where you discuss the Holding Foreign
Companies Accountable Act (the "HFCA Act") to reflect the HFCA Act timeline for a potential trading prohibition was shortened
from three years to two years, as part of the "Consolidated Appropriations Act, 2023," signed into law on December 29, 2022.

RESPONSE: In response
to the Staff’s comment, the Company has revised the disclosure on cover page and pages 103 and 104 of the Registration Statement.

***

Page 3

If you have any questions
regarding the Registration Statement, please contact the undersigned by telephone at +86-10-6529-8308 or via e-mail at douyang@wsgr.com.

    Very truly yours,

    /s/ Dan Ouyang

    Dan Ouyang

Enclosures

cc:

Mr. Hui Shao, Director, President and Chief Executive Officer, YishengBio.,
Co., Ltd

Mr. Bo Tan, Director, Chief Executive Officer and Co-Chief Investment
Officer, Summit Healthcare Acquisition Corp.

Mr. Ken Poon, Director, President and Co-Chief Investment Officer,
Summit Healthcare Acquisition Corp.

Will H. Cai, Esq., Cooley LLP

Yiming Liu, Esq., Cooley LLP

Timothy Pitrelli, Esq., Cooley LLP

Anthony S. Chan Director, Assurance and Advisory Service, Wei, Wei
 & Co., LLP