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CORRESP
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November 28, 2023

VIA EDGAR

Tracey Houser

Jeanne Baker

Conlon Danberg

Lauren Nguyen

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, D.C. 20549

 Re: Baird Medical Investment Holdings Limited

Registration Statement on Form F-4

Filed August 21, 2023

File No. 333-274114

Dear Mr. Newberry:

This letter is in response
to the comments of the staff of the United States Securities and Exchange Commission (the “Staff”) contained in your
letter dated September 20, 2023, regarding the Registration Statement on Form F-4 (the “Registration Statement”),
which was filed by Baird Medical Investment Holdings Limited (the “Company”) with the United States Securities and
Exchange Commission (the “Commission”) on August 21, 2023.

The Company has filed today
Amendment No. 1 to the Registration Statement (“Amendment No. 1”) together with this letter via EDGAR correspondence.
For the convenience of the Staff, the numbering of the paragraphs below corresponds to the numbering of the comment in the Comment Letter,
the text of which we have incorporated into this response letter in italicized type, and which is followed by the Company’s response.
Unless otherwise indicated, all page references in the responses are to page numbers in Amendment No. 1. Capitalized terms
used herein but not defined shall have the meanings ascribed to them in Amendment No. 1.

Registration Statement on Form F-4, filed
August 21, 2023

Cover Page

 1. Comment: We note your cover page disclosure
that PubCo will be a “controlled company” under the listing rules of Nasdaq and may be exempt from certain corporate
governance requirements other than those exemptions available to foreign private issuers. Please revise to disclose on the cover page and
in the prospectus summary whether you intend to rely on any exemptions as a controlled company and identify the controlling shareholder
and the shareholder's total voting power. We refer to your disclosure on page 135.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on the cover page of the proxy statement/prospectus and on page 39
of the prospectus summary of Amendment No. 1 in response to the Staff’s comment.

 2. Comment: Given that the Nasdaq listing approval as a closing condition is waivable, please revise
your cover page to prominently disclose that shareholders will not have certainty at the time they vote regarding whether the PubCo
ordinary shares will be listed on a national securities exchange following the business combination. Please revise your risk factor on
page 122 accordingly.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on the cover page of the proxy statement/prospectus and on page 131
of Amendment No. 1 in response to the Staff’s comment.

 3. Comment: We note your disclosure that “[b]ecause most of the operations of PubCo will
be conducted in Mainland China through its wholly-owned subsidiary Tycoon and its subsidiaries, the business is subject to PRC laws and
regulations and supervision and potential intervention by the Chinese government,” and your cross reference to your risk factors.
Please revise your disclosure to more clearly highlight that, because the business is subject to PRC laws and regulations, there are legal
and operational risks associated with being based in or having the majority of the company’s operations in China. In addition, we
note your disclosure that “potential intervention by the Chinese government . . . could result in a material change in The Target
Group’s operations and/or the value of PubCo’s Ordinary Shares after the Business Combination.” Given that you are also
registering PubCo warrants on this registration statement, please revise this disclosure, as appropriate, to include a reference to PubCo
warrants.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on the cover page of the proxy statement/prospectus in response to the Staff’s
comment.

 4. Comment: On your cover page, state whether any transfers, dividends, or distributions have been
made to date between the holding company and its subsidiaries, or to investors, and quantify the amounts where applicable. Provide cross-references
to the condensed consolidating schedule and the consolidated financial statements. As a related matter, please amend the disclosure in
your Summary of the Proxy Statement/Prospectus to include a clear description of how cash is transferred through your organization. Quantify
any cash flows and transfers of other assets by type that have occurred between the holding company and its subsidiaries, and the direction
of transfer. Quantify any dividends or distributions that a subsidiary has made to the holding company and which entity made such transfer,
and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the source, and their tax consequences.
Your disclosure should make clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign
exchange and your ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations
on your ability to distribute earnings from the company, including your subsidiaries, to the parent company and U.S. investors.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosures on the cover page of the proxy statement/prospectus and page 37 of
Amendment No. 1 to clarify that, to date, no transfers, dividends or distributions have been in response to the Staff’s comment.
The Company respectfully notes that it has not included a condensed consolidating schedule. In addition, the Company has revised the disclosure
on page 37 of Amendment No. 1 to clarify that cash is transferred through the organization in the form of capital contributions
or working capital loans. The Company has also added disclosure on page 37 of Amendment No. 1 to describe the restrictions on
foreign exchange and distribution of earnings.

Questions and Answers for Stockholders of ExcelFin,
page 17

 5. Comment: Please highlight the material risks to public warrant holders, including those arising
from differences between private and public warrants. Clarify whether recent common stock trading prices exceed the threshold that would
allow the company to redeem public warrants. Clearly explain the steps, if any, the company will take to notify all shareholders, including
beneficial owners, regarding when the warrants become eligible for redemption.

Response: The Company acknowledges
the Staff’s comment and has added the disclosure on pages 30 and 31 of Amendment No. 1 in response to the Staff’s
comment.

Q: Did Board obtain a fairness opinion in determining
whether or not to proceed with the Business Combination?, page 20

 6. Comment: We note your disclosure that you did not obtain a fairness opinion. Here and as appropriate
throughout your filing, please provide additional detail describing the qualifications and “substantial experience” of your
board that allowed them to determine that the business combination agreement and the transactions thereby are advisable and in the best
interests of shareholders, and recommend that stockholders approve the business combination.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 20, 48, 49, 190, and 191 of Amendment No. 1 in response to the Staff’s
comment.

Q: What equity stake will current stockholders
of ExcelFin and Baird Medical hold in PubCo after the Closing?, page 21

 7. Comment: We note your disclosure on page 24 relating to the potential impact of redemptions
on the per share value of the shares owned by non-redeeming shareholders. Please revise to include a sensitivity analysis showing a range
of redemption scenarios, including at least one interim redemption level.

Response: The Company has revised
the disclosure on page 24 to include one interim redemption level between no redemptions and maximum redemptions. The sensitivity
analysis shows, in the Base Scenario, values between $0.48 per share with no redemptions and $0.15 per share for maximum redemptions,
compared to a current trading price of above $10.00 per share. The Company believes that further iterations of these calculations will
not provide any material new information to investors.

Q: If I am a warrants holder, can I exercise
redemption rights with respect to my warrants?, page 30

 8. Comment: Quantify the value of warrants, based on recent trading prices, that may be retained
by redeeming stockholders assuming maximum redemptions and identify any material resulting risks.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on page 30 of Amendment No. 1 in response to the Staff’s comment.

Summary of the Proxy Statement/Prospectus,
page 35

 9. Comment: Please revise your description of Baird Medical to address the following issues:

 · You disclose on page 73 that Baird Medical has obtained one registration certificate for microwave
ablation therapeutic apparatus under Class III, one registration certificate for microwave ablation needles under Class III
and one registration certificate for microwave ablation needles under Class II. Revise to disclose the specific products for which
and when Baird Medical obtained Class II and III registration certificates here and elsewhere in the prospectus.

 · We note your disclosure on page 73 that in addition to the registration certificates, companies
engaging in manufacturing of Class II and Class III medical devices are required to obtain and maintain a Manufacture License
for medical devices. You also disclose on page 246 that Baird Medical has obtained the Manufacture License for Class II and
III medical devices for its existing microwave ablation products in China. Please revise to clarify when Baird Medical obtained such Manufacture
Licenses and the expiration dates of such licenses.

Response: The
Company acknowledges the Staff’s comment and has revised the disclosure related to its registration certificates on pages 37
and 79 of Amendment No. 1 to clarify the specific products to which such registration certificates relate and the dates on which
such registration certificates were obtained in response to the Staff’s comment. In addition, the Company has revised the disclosure
related to its manufacturing license on page 296 of Amendment No. 1 to clarify that such manufacturing license was obtained
on May 25, 2021 and expires on May 24, 2026 in response to the Staff’s comment.

The Combined Company and Baird Medical’s
Structure before and after the Business Combination, page 36

 10. Comment: Your diagram at the top of page 37 indicates that Auto King International Limited
will own 59.94% of Betters Medical Investment Holdings Limited, which will own 75% of PubCo. Please revise your disclosure in this section
to discuss, as you do on page 312, that Auto King is controlled by Wu Haimei, and discuss any related conflicts of interest.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on page 39 of Amendment No. 1 in response to the Staff’s comment
to disclose that Auto King is controlled by Haimei Wu. The Company has also included a cross-reference to the relevant risk factor disclosure
related to related party transactions.

 11. Comment: We understand that UBS Securities and KeyBanc Capital Markets Inc., two of the underwriters
in your SPAC IPO, intend to waive the deferred underwriting commissions that would otherwise be due to them upon the closing of the business
combination. Please disclose how these waivers were obtained and why the parties agreed to these waivers. Make conforming changes to your
disclosure in the Background of the Business Combination.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 48, 136 & 190 of Amendment No. 1 in response to the
Staff’s comment to disclose that ExcelFin’s management reached out to UBS Securities and KeyBanc Capital Markets Inc. in August of
2023 and requested that they waive their right to receive deferred underwriting fees. ExcelFin entered into fee waiver agreements with
KeyBanc and UBS Securities on August 7, 2023 and August 11, 2023, respectively. Neither UBS nor KeyBanc Capital Markets Inc.
communicated the reason for providing such waivers. Such waivers were provided without any consideration from ExcelFin and without any
conditions. Neither UBS nor KeyBanc communicated to ExcelFin, nor is ExcelFin aware, that their waiver was
the result of any dispute or disagreement with ExcelFin, including any disagreement relating to the disclosure in the proxy statement/prospectus.

UNAUDITED PRO FORMA CONDENSED COMBINED FINANCIAL
INFORMATION, page 62

 12. Comment: Please update the pro forma financial information provided to include a pro forma balance
sheet as of June 30, 2023 as well as a pro forma statement of operations for the six months ended June 30, 2023.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 64 through 75 of Amendment No. 1 to include a pro forma balance
sheet as of June 30, 2023 in response to the Staff’s comment. The Company has also revised the disclosure on pages 64
through 75 of Amendment No. 1 to include a pro forma statement of operations for the six months ended June 30, 2023 in response
to the Staff’s comment.

 13. Comment: We note your disclosures in notes F and J on page 68 indicating that the Earnout
shares did not qualify for equity treatment as the provisions contained a change of control feature, which is not an assumption in the
fixed-to-fixed model. Please further expand your disclosures to clarify the specific terms that resulted in your determination that they
should treated as a liability classified instrument pursuant to your consideration of ASC 815-40. Please also disclose and discuss the
potential impact of the shares on future results and provide a sensitivity analysis that quantifies the potential impact that changes
in the per share market price of the post combination common stock could have on the pro forma financial statements. Refer to Article 11-02(b)(10) of
Regulation S-X.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 72 and 73 of Amendment No. 1 in response to the Staff’s
comment.

 14. Comment: We note your discussion of agreements that will terminate upon the business combination
as discussed on page 282. Please address what consideration was given to reflecting these agreements in your pro forma financial
information.

Response: The Company acknowledges
the Staff’s comment and has revised the pro forma financial information on pages 64 through 75 of Amendment No. 1 to make
adjustments to reflect that these costs are not continuing. Specifically, on the Unaudited Pro Forma Condensed Combined Statement of Operations
for the year ended December 31, 2022 and on the Unaudited Pro Forma Condensed Combined Statement of Operations for the six months
ending June 30, 2023, adjustment DD reverses these charges.

 15. Comment: Your disclosures on page 172 indicate that two of the underwriters in the ExcelFin
IPO, informally notified ExcelFin that, in connection with the Business Combination, they were waiving their right to receive any deferred
underwriting fees arising out of the ExcelFin IPO. Given your characterization of this as an informal notification, please disclose your
basis for reflecting this waiver in the pro forma financial information. Refer to Rule 11-02 of Regulation S-X.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 48, 136 and 190 of Amendment No. 1 to spec