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August 2, 2024

Via EDGAR

Division of Corporation Finance

Office of Life Sciences

Securities and Exchange Commission

Washington, D.C. 20549

    Attn.:
    Ibolya Ignat

    Mary Mast

    Doris Stacey Gama

    Joe McCann

    Re:

    Jyong Biotech Ltd.

    Response to the Staff’s Comments on

    Registration Statement on Form F-1/A

    Filed on June 21, 2024 (File No. 333-277725)

Dear Sir and Madam:

On behalf of our client, Jyong
Biotech Ltd., a Cayman Islands exempted company (the “Company”), we submit to the staff (the “Staff”)
of the Securities and Exchanges Commission (the “Commission”) this letter setting forth the Company’s responses
to the comments contained in the Staff’s letter dated July 19, 2024 on the Company’s registration statement on Form F-1/A
filed on June 21, 2024 (the “Registration Statement”). Concurrently with the submission of this letter, the Company
is filing amendment No.3 to Registration Statement (the “Amendment No.3”) via EDGAR to the Commission.

The Staff’s comments
are repeated below in bold and are followed by the Company’s responses. We have included page references in the Amendment No.3 where
the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth
in the Amendment No.3.

Prospectus Summary

Overview, page 1

1. Please revise the discussion of your current plans to develop MCS-2 (API-2) to clarify the FDA’s
concerns communicated on pages 1-2 of its February 23, 2024 correspondence, which you provided in response to our May 31, 2024 request.
The communication indicates that your proposed plan to conduct one phase 1 study and one phase 3 efficacy study using your product containing
API-2 faces significant challenges. Please update your Summary to briefly describe the FDA’s concerns and provide a more fulsome
discussion of these concerns in the Business section.

Response: In response to the Staff’s comments,
the Company has revised the disclosure on page 3 and page 120 of the Amendment No.3.

We understand FDA concerns on the failure of our MCS-2-US-a
study using API-1, so we planned to conduct an additional Phase III pivotal study (MCS-2-US-b) and a Phase I PK study in the US using
API-2. U.S. FDA reviewed the protocol and on Feb. 23, 2024, provided comments on our protocol revisions. Based upon FDA’s recommendations,
we have revised the Phase III protocol and developed the PK study protocol for submission to the U.S. FDA for their further review. They
suggested on May 23, 2024 that we provide a complete CMC information for the API-2, and a plan to establish comparability between API-1
and API-2 to enable them to review and possibly reach agreement on the protocols the Company designed to establish the safety and efficacy
of MCS-2.

2. We note your response to prior comment 1 and reissue in part. Please revise your disclosure throughout
your filing to remove language indicating that the comparability is an inevitable conclusion, such as “[O]nce the US FDA is convinced
about the comparability of API-1 and API-2....” You may discuss what happens if you are able to demonstrate comparability, but you
must indicate that to date you have not been able to do so and what your path forward is if you are unable to demonstrate comparability.

Please also state if you have had discussions with the
Taiwan regulator about the substitution of API-2 for API-1 in MCS-2. If you have not, or if the Taiwan regulator also requires comparability
studies, it is not appropriate to indicate that you have completed Phase 1 studies for PCP (API-1).

Response: In response to the Staff’s comments, the
Company has revised the disclosure on page 1, page 6, page 59, and page 113 of the Amendment No.3.

 Firstly, the botanical substance is under the same patent
owned by the company, we fully understand the harvesting, raw material preparation and API processing operations, thus we know and control
the steps that are relevant to the comparability analysis. We have done a series of analytical testing of characterization, specification
of the comparative API-1 and API-2. Thus, we are confident in the comparability between API-1 and API-2. We are continuing to collect
the necessary information from the API-2 supplier. Per FDA requirement in the FDA-WRO-20240523, we are presently drafting
our plan to establish comparability between API-1 and API-2. We will then request a CMC meeting with FDA later this year to provide complete
CMC documentation to the Agency.

 Secondly, The PCP Phase II study using API-1 has been completed.
We have not yet discussed API-2 with TFDA because the PCP Phase II study using API-1 is in the late stage of Source Data Verification
(“SDV”). Once the Clinical Study Report for PCP using API-1 is available, and the comparability between API-1 and API-2 is
confirmed, we will meet with TFDA to talk about the feasibility of a Phase III PCP study.

3. In response to prior comment 1 you state that you are preparing CMC information for API-2, are planning
to establish comparability between API-1 and API-2, and once the FDA is convinced about the comparability you will then initiate the MCS-2
Phase III and Phase I PK study. Please revise your disclosure to state that you currently do not have an API-2 supplier and that you cannot
proceed until you identify a supplier of API-2. Please also include such disclosure throughout your prospectus where you discuss PCP,
including but not limited to pages 6, 109, and 124. Additionally include a risk factor discussion addressing the potential consequences
if the FDA does not agree that API-1 is comparable to API-2.

Response: In response to the
Staff’s comments, the Company has revised the disclosure on page 1, page 7, page 113, page 117, page 133, and page 137 of the
Amendment No.3.

We do have an API-2 supplier that we
are currently working with to collect the batch information and CMC documentation. We are performing analytical testing for batch analysis
and comparison. We will then request a CMC meeting with FDA to provide complete CMC documentation to the Agency.

If the U.S. FDA concur that API-1 and
API-2 are similar and comparable, we will sign the quality agreement with this API-2 supplier. If there is any possibility that FDA does
not agree that API-1 and API-2 are comparable, we may work with another supplier who is able to meet the comparability.

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4. In response to prior comment 4 you state that you plan to demonstrate that API-1 and API-2 are comparable
to be able to rely on all prior trials. You also state that due to a failed MCS-2-US-a study you will conduct an additional Phase III
pivotal study in the US using API-2. Please clarify, if accurate, that you must first conduct API-1 and API-2 comparability studies and
if the FDA accepts such results and determines that API-1 and API-2 are comparable, only then will you be able to conduct the additional
Phase III pivotal study using API-2. Further, you also state that your plans will be discussed at the CMC meeting. Clarify, as you do
on page 2, that you received a denial notice from the FDA on May 23, 2024 for a CMC meeting.

Response: In response to the Staff’s
comments, the Company has revised the disclosure on page 1, page 3, page 7, page 113, page 117, page 133, and page 137 of the Amendment No.3.

Yes. We must conduct API-1 and API-2
comparability studies first and if the FDA accepts such results and determines that API-1 and API-2 are comparable, only then we will
be able to conduct the additional Phase III pivotal study using API-2.

FDA did not deny our CMC meeting request.
In fact, we have not submitted the request yet. We requested a Type B meeting on May 14, 2024 to discuss about the Phase I and Phase III
study protocols. FDA indicated in the May 23, 2024 notice that it is premature for this stage of drug development. FDA suggested that
instead we provide complete CMC information for API-2 and our plan to establish comparability between API-1 and API-2.

We are presently drafting the comparability
plan to include all the necessary data between API-1 and API-2. After we have collected all the comparability CMC data and documentation,
we will request the CMC meeting with FDA. After FDA accepts the comparability data, we will initiate the Phase I PK and Phase III pivotal
study using API-2. If FDA does not agree that API-1 and API-2 are comparable, we will need to work with other API vendor to demonstrate
the comparability that meet U.S. FDA’s requirements.

5. We note your response to comment 5 and 6. Your pipeline table should provide one line for each product
candidate being developed to address a single indication. The purpose of the pipeline table is not to depict the alternative ways you
may develop the same product candidate. Currently, your table depicts three lines depicting MCS-2 being developed to address BPH/LUTS.
Please revise your table to remove two of the lines depicting MCS-2 for BPH/LUTS as they are not additional candidates, they are alternative
ways that you may attempt to develop MCS-2 for BPH/LUTS. The line item that should be depicted in the table is the one that depicts the
method of development you are actively pursuing with the FDA.

If you are able to rely on trials performed using
API-1, it is not appropriate to include a separate line item in your table indicating that you have a separate product candidate for MCS-2
(API-1). If the FDA determines that API-1 and API-2 are sufficiently comparable to rely on the clinical trials performed using API-1,
then you may reflect the completion of the successful trials using API-1 in your pipeline table for the line item depicting the development
of MCS-2 (API-2). Until the FDA has made that comparability determination, such results relating to API-1 relate to a development pathway
that you are not currently able to pursue due to the fact that API-1 is currently not available. Similarly, if the new Phase III study
using API-2 is successful and you are able to demonstrate to the FDA that API-1 and API-2 are sufficiently comparable, then you will be
able to rely on the MCS-2-TWN-a study in the pipeline table if you have been able to re-analyze the data from the study to successfully
demonstrate to the FDA that it is reliable.

We also note your table indicates you are developing
PCP (API-1) for Prostate Cancer in Taiwan. Please explain how you are pursuing this using API-1 given that API-1 is not currently available.
Alternatively, remove it from your pipeline table.

Response: In response to the Staff’s
comments, the Company has revised the disclosure on page 3, page 4 and page 110 of the Amendment No.3.

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Each of the lines are important to
our plans. Although the pipeline table depicts three lines for MCS-2, the first two lines properly depict the completed four Phase III
studies using API-1. Another line depicts the alternative forthcoming studies using API-2, once FDA agrees with our comparability determination.
At that time, Phase III studies using API-1 would be applicable to the overall approval process informing the later studies using API-2

We have revised the pipeline table,
separating the drug candidates using API-1 and API-2. We have clarified in the table that the clinical results of the candidates using
API-1 can only be used if the U.S. FDA is convinced of the comparability of API-1 and API-2. As of this date, the Company is still in
the process of preparing the information required by the U.S. FDA and has not yet have the CMC meeting with FDA to discuss about the comparability
of API-1 and API-2.

The Phase II PCP study was initiated
in Taiwan in 2014 using API-1, and the study enrollment and treatment phase is completed without being affected by the currently unavailable
API-1. If the U.S. FDA concur that API-1 and API-2 are comparable, and when the CSR for the PCP study is available, we will discuss with
TFDA about conducting the Phase III PCP study. Therefore, it is also important to keep this line.

6. We note your response to prior comment 8 and reissue our comment. Please refer to page 2 of 7 from
the FDA correspondence dated June 26, 2023 you provided in response to our request on May 31, 2024, which states:

“Because of the heterogeneous nature of a botanical
drug and uncertainty about its active constituents a critical issue for botanical drugs is ensuring that the therapeutic effect for drug
batches is consistent. In general, therapeutic consistency can be supported by a ‘totality of the evidence’ approach, including botanical
raw material control, quality control, by chemical test(s), manufacturing control, a biological assay (if needed) and clinical data. Seemingly
minor changes in the API source and/or manufacturing process may result in a meaningful difference in the clinical effects and raise concerns
about the applicability of earlier pharmacological, nonclinical and clinical data.”

See also pages 2-3 of 10 which states, “any changes
(e.g. changes in the agricultural sites, agricultural and collection practices and/or processing/manufacturing methods) should be assessed
carefully to determine if the BDS and the botanical drug product (BDP) batches produced after such a proposed change would be sufficiently
similar pharmacologically and/or therapeutically to batches prior to such a change.”

Please note the potential impact of these “seemingly
minor changes” apply to changes in suppliers of the active pharmaceutical ingredient as well as the change in the active pharmaceutical
ingredient provided by the supplier of API-1 prior to its relocation and following its relocation. Therefore, in order to produce MCS-2
using API-1 following a relocation, you would have to demonstrate comparability again. Please revise your disclosure to clarify that if
you intend to develop MCS-2 using API-1 if it becomes available, you will have to demonstrate comparability again. If you are unable to
demonstrate comparability, you will have to perform more clinical trials.

Response: In response to the Staff’s
comments, the Company has revised the disclosure on page 5, page 111 and page 126 of the Amendment No.3.

 We interpret the FDA’s use of the word “source”
to not be a reference to the physical location of a manufacturing facility but rather to the entity responsible for manufacturing an API,
the raw materials used to produce the API, the manufacturing process, and compliance with FDA’s current good manufacturing practices
(GMPs). Therefore, in the case that the same entity manufactures an API in different physical locations but uses identical raw materials
and the same patented manufacturing process in compliance with FDA’s GMPs, the mere difference in the location of the manufacturing
site is unlikely to result in significant differences in the final API. We understand FDA advice in the 20230626-WRO, which is a kind
reminder to ensure comparability from any change. We will work with the API vendors to follow FDA guidance to demonstrate comparability.

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7. Please provide us with a copy of the FDA meeting minutes from your January 20, 2013 CMC meeting in
which the FDA staff encouraged you to select multiple vendors for the botanical raw material and advised you to identify more raw material
vendors to avoid any potential supply shortages in the early stages. The June 26, 2023 FDA correspondence you provided indicates that
“minor changes in the API source and/or manufacturing process may result in a meaningful difference in the clinical effects and raise
concerns about the applicability of earlier pharmacological, nonclinical and clinical data” which appears inconsistent with this
advice.

Response: In response to the Staff’s
comments, we have uploaded the FDA meeting minutes to the SEC document sharing system.

During the EOP2 CMC meeting held on January 30,
2013, FDA encouraged us to select multiple vendors of the botanical raw material for making the
multipl