SecProbe.io

August 1, 2024
Haimei Wu
Chief Executive Officer
Baird Medical Investment Holdings Limited
Room 202, 2/F, Baide Building, Building 11, No.15
Rongtong Street, Yuexiu District, Guangzhou, People's Republic of China
Re:Baird Medical Investment Holdings Limited
Amendment No. 5 to Registration Statement on Form F-4
Filed July 19, 2024
File No. 333-274114
Dear Haimei Wu:
            We have reviewed your amended registration statement and have the following
comments.
            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 July 8, 2024 letter.
Amendment No. 5 to Form F-4 filed July 19, 2024
Enhanced Research and Development Capabilities through Collaboration with Market
Participants, page 271
1.We note your revised disclosure on pages 271 and 291 that you hold two Class III
registration certificates you hold for the microwave therapeutic instrument and accessories
and disposable microwave ablation needle, the Class III certificate you recently obtained
for MWA needles and one Class II registration certificate in relation to disposable sterile
biopsy needles. Please revise to clarify, if true, that the two Class III registration
certificates you currently hold for your microwave therapeutic instrument and disposable
microwave ablation needles include the Class III certificate you recently obtained for
MWA needles in July 2023. We refer to your CFDA 20183011581 and 20233010963
registration certificate numbers, respectively.

August 1, 2024
Page 2
Customers, page 290
2.We acknowledge your revised disclosure in response to prior comment 8. Please revise
your disclosure to address the following issues:

•Please disclose when you entered into this agreement with the Top Distributor and the
term of the agreement. We refer to section 18 of the agreement, which states that the
agreement expired on December 31, 2023. Please confirm whether you have entered
into a supplementary agreement with the Top Distributor to renew the distribution
agreement, and if so, please file any such agreement as an exhibit to the registration
statement as required by Item 21 of Form F-4 and Item 601(b)(10) of Regulation S-K
and revise your disclosure accordingly; and

•We note that certain portions of Exhibit 99.9 have been redacted. Please include a
statement at the top of the first page of such redacted exhibit stating that certain
information has been excluded because it is both not material and the type of
information that the registrant treats as private or confidential and also ensure that
such exhibit is in the proper text-searchable format. Refer to Item 601(b)(10)(iv) of
Regulation S-K and Item 301 of Regulation S-T.
Pubco's Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 341
3.We note your response to comment 10.  Please address the following:
•Pursuant to Item 5A of the Form 20-F, please disclose the specific significant factors
that materially impacted revenues in a similar manner to your response with
quantification regarding the extent to which revenues were impacted. You should
specifically discuss the extent to which fluctuations in revenues were attributable to
changes in prices, changes in the volume or amount of products being sold, or to the
introduction of new products; and
•In light of the limitations you note regarding your distributor inventory reports, please
help us better understand your basis for stating that you are not aware of any material
amount of unsold inventory held by your deliverers and its distributors, including how
you determined what would be material.
The Aging of Accounts Receivable, page 349
We note your responses to comments 13 and 14 and the corresponding expanded
disclosures.  Specifically you refer to customers being contractually entitled to a credit
period of 30 to 90 days, but in practice, you may, on a case-by-case basis, approve an
extended credit period upon request.  Given that the approval of an extended credit period
appears to not be as infrequent as your disclosures indicate, we continue to believe that
additional quantitative disclosures should be provided regarding your actual collection
period for your receivables.  For example, an analysis of days sales outstanding or other
quantitative analysis could be helpful along with clear disclosure of how these
calculations are determined.  Include the information in your response to comment 14 in
the disclosure on page 350. We also note your continued reference to the impact of the
COVID-19 outbreak.  Please further clarify in your disclosures why and how you are 4.

August 1, 2024
Page 3
continuing to be impacted by this outbreak in recent periods. Also, please expand your
disclosure to explain why you have any outstanding receivables from distributors given
the provision in Section 6.2 of the Distribution Agreement in Exhibit 99.9 that products
are not shipped to the distributor until after you have received payment.
5.Please provide us with a rollforward of your Accounts Receivable balances from
December 31, 2022 to December 31, 2023 which separately shows all significant activity
in these balances including the impact of revenue, VAT, and actual collections.
            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
Jane Park at 202-551-7439 or Lauren Nguyen at 202-551-3642 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Stephen Leitzell, Esq.