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CORRESP
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    Graubard
                                            Miller

    The
    Chrysler Building

    405
    Lexington Avenue

    New
    York, N.Y. 10174-4499

    (212)
    818-8800

    (212)
    818-8881

    (212)
    818-8638

    email
    address

    jgallant@graubard.com

October
21, 2024

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Industrial Applications and Services

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Bowen
    Acquisition Corp

    Amendment
    No. 1 to Registration Statement on Form S-4

    Filed
    October 4, 2024

    File
    No. 333-282021

Ladies
and Gentlemen:

On
behalf of Bowen Acquisition Corp (“Company”), we respond as follows to the Staff’s comment letter, October 9, 2024,
relating to the above-captioned Registration Statement on Form S-4 (“Registration Statement”). Captions and page references
herein correspond to those set forth in the amended Registration Statement, a copy of which has been marked with the changes from the
original draft submission of the Registration Statement.

Please
note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the Company’s response
to each comment immediately thereafter.

    Securities and Exchange Commission

October
                                            21, 2024

Page 2

Amendment
No. 1 to Registration Statement on Form S-4 filed October 4, 2024

SPAC
Sponsor Compensation, page v

1. We
                                            note your response to prior comment 2, and your statement on page 15: “based on the
                                            value of the Bowen securities invested in and the amount of the loans and unreimbursed expenses
                                            as set forth above, the aggregate amount that the SPAC Sponsors and Bowen’s officers
                                            and directors have at risk is $[3,442,820 ($3,434,570 by Createcharm and $8,250 by Bowen
                                            Holding)].” Please expand this section of the shareholder letter to add disclosure
                                            of all compensation received or to be received by the SPAC sponsors, their affiliates, and
                                            promoters in connection with the de-SPAC transaction or any related financing transaction,
                                            including the nature and amounts of any reimbursements to be paid to the Sponsors, their
                                            affiliates, and any promoters upon the completion of the de-SPAC transaction, such as the
                                            loans to the Sponsors and out-of-pocket expenses due to the Sponsors, or advise. We understand
                                            from your response that there are not currently any outstanding amounts owed under any unsecured
                                            promissory notes.

The
Staff’s comment is duly noted. We have revised the disclosure on pages 15, 32 and 114 of the Registration Statement to clarify
that there are not currently any amounts outstanding under any loans payable to the SPAC Sponsors or Bowen’s officers and directors
and there are no fees due or out-of-pocket expenses to be repaid by Bowen. However, if any are incurred after the date of the Registration
Statement, they would not be repaid unless Bowen consummates the Business Combination within the required time period.

Potential
Dilution to Non-Redeeming Bowen Public Shareholders, page 109

2. We
                                            note your revised disclosure to include a dilution table pursuant to Item 1604(c) of Regulation
                                            S-K. Please revise your presentation to clearly show the unadjusted net tangible book value
                                            per share as of the most recent balance sheet date filed, the nature and amount of each specific
                                            adjustment to net tangible book value, and the total number of adjusted shares used to determine
                                            net tangible book value per share, as adjusted. In this regard, we note that it is not clear
                                            from your current presentation whether you have made any adjustments to net tangible book
                                            value per share for transaction expenses, repayment or conversion of any outstanding loans
                                            due to your sponsors or as a result of a reclassification from the trust account, or the
                                            total number of as-adjusted shares used to calculate as-adjusted net tangible book value
                                            per share and how the level of redemptions impacts this number. Finally, outside of the table,
                                            please describe each material potential source of future dilution that non-redeeming shareholders
                                            may experience by electing not to tender their shares in connection with the de-SPAC transaction,
                                            including sources not included in the table with respect to the determination of net tangible
                                            book value per share, as adjusted. This presentation should include the 1,400,000 Earnout
                                            Shares if their issuance is not considered a materially probable or consummated transaction
                                            for purposes of the tabular disclosure.

We
have revised the disclosure on page 109 of the Registration Statement as requested.

    Securities and Exchange Commission

October
                                            21, 2024

Page 3

General

3. We
                                            note the consent of Frost & Sullivan filed as Exhibit 99.7 mentions an investor presentation,
                                            and an investor presentation is mentioned on page 118 as well. Please revise to provide any
                                            material information from this presentation that is not included in your registration statement
                                            and describe the purpose of this presentation.

We
wish to advise the Staff that the presentation referred to in Exhibit 99.7 and page 118 of the Registration Statement was prepared by
Qianzhi Group Holding (Cayman) Limited and Shenzhen Qianzhi Biotechnology Co., Ltd. (collectively, “Qianzhi”). Qianzhi prepared
the presentation for use in connection with its efforts to secure additional financing pursuant to a PIPE transaction, as described in
the Registration Statement. The Company and Qianzhi confirm that the material information contained in the presentation is included in
the Registration Statement. However, such presentation has not been used to date. The Company and Qianzhi intend to file such presentation
with the SEC if and when such presentation is used by Qianzhi as described above.

*
* * * * * * * * *

If
you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

    Sincerely,

    /s/
    Jeffrey M. Gallant

    Jeffrey
    M. Gallant

    cc:
    Jiangang
    Luo, CEO

    Liangwen
    Wang, CFO