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January 19, 2024

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

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

Filed November 28, 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 December 20, 2023 (the “Comment Letter”), regarding Amendment No. 1 to 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 November 28,
2023.

The Company has filed today
Amendment No. 2 to the Registration Statement (“Amendment No. 2”) 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. 2. Capitalized terms
used herein but not defined shall have the meanings ascribed to them in Amendment No. 2.

Amendment No. 1 to Registration Statement on Form F-4
Filed November 28, 2023 Cover Page

 1. Comment: We note your disclosure
                                            that “PubCo, with Tycoon being its wholly-owned subsidiary after the Business Combination,
                                            is a holding company incorporated in the Cayman Islands with its registered office in the
                                            Cayman Islands. PubCo conducts its operations through Tycoon and its subsidiaries, and PubCo’
                                            s global headquarters are based in Guangzhou in the People’s Republic of China, or
                                            Mainland China.” Please revise your disclosure to clearly state that you are not a
                                            Chinese operating company, but a Cayman Islands holding company with operations conducted
                                            by your subsidiary. As a related matter, we note your disclosure that “investments
                                            in PubCo’s Ordinary Shares are not purchases of equity securities of these operating
                                            subsidiaries in Mainland China but instead are purchases of equity securities of a Cayman
                                            Islands holding company with no material operations of its own.” Please revise your
                                            disclosure to clearly state that investors may never hold equity interests in the Chinese
                                            operating company. Please also revise the disclosure on your cover page to clearly disclose
                                            how you will refer to the holding company and its subsidiary when providing the disclosure
                                            throughout the document so that it is clear to investors which entity the disclosure is referencing
                                            and which subsidiaries or entities are conducting the business operations.

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 38
of Amendment No. 2 in response to the Staff’s comment.

 2. Comment: We note your response to
                                            comment 3 and your revised disclosure that “because our business is subject to the
                                            laws and regulations of the PRC, there are additional legal and operational risks associated
                                            with being based in China,” with a cross reference to your risk factor disclosure.
                                            Please further revise your disclosure as follows:

 · Please
                                            revise your disclosure to clearly state that the legal and operational risks associated with
                                            being based in China could result in a material change in your operations.

 · Where
                                            you disclose that there may be an impact on the value of your securities, disclose that the
                                            value of your securities could significantly decline and that the value of such securities
                                            could become worthless.

 · We
                                            note your disclosure that “expanding the categories of industries and companies whose
                                            foreign securities offerings are subject to government review could significantly limit or
                                            hinder PubCo’s ability to offer or continue to offer securities to investors.”
                                            Please revise the disclosure on your cover page to more broadly state that the legal
                                            and operational risks associated with being based in or having the majority of the company’s
                                            operations in China could result in a material change in your operations and/or the value
                                            of the securities you are registering for sale or could significantly limit or completely
                                            hinder your ability to offer or continue to offer securities to investors and cause the value
                                            of such securities to significantly decline or be worthless.

For additional guidance, please
see the Division of Corporation Finance’s Sample Letter to China-Based Companies issued by the Staff in December 2021.

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 14
of Amendment No. 2 in response to the Staff’s comment.

 3. Comment: As a related matter, we
                                            note your revised disclosure that “the approval of the China Securities Regulatory
                                            Commission (the “CSRC”), the Cyberspace Administration of China (the “CAC”),
                                            or other PRC regulatory agencies will be required in connection with the Business Combination.”
                                            However, we also note your disclosure that “[e]xcept for the Trial Measures, no other
                                            relevant laws or regulations in the PRC explicitly require Baird Medical to seek approval
                                            from the Cyberspace Administration of China (“CAC”) or any other PRC governmental
                                            authorities for its overseas listing plan.” Please revise your disclosure for consistency,
                                            and to clearly disclose each permission or approval that you or your subsidiaries are required
                                            to obtain from Chinese authorities to operate your business and to offer the securities being
                                            registered to foreign investors.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on the cover page of the proxy statement/prospectus and on pages 14,
16, 39 – 40, 112 and 115 – 117 of Amendment No. 2 in response to the Staff’s comment to clarify that (i) except
for the filing procedures based on the Trial Measures, which procedures are required by the CSRC, the Company does not believe it is
required to obtain any other license, permission or approval from the PRC authorities in connection with the business combination and
(ii) the Company believes it has received all required licenses, permissions and approvals from the PRC authorities required to
conduct its business operations, including the Registration Certificates for Medical Device, Permit for Medical Device Production, Medical
Device Quality Management System Certificate, Certification of High-Tech Enterprise, Pollutant Discharge Registration for Fixed Sources
of Pollution, the Business Operation License for Class III Medical Devices and the Record Filing Certificate for Operation of Class II
Medical Devices.

Risk Factor Summary, page 14

 4. Comment: For each risk factor in
                                            your summary, please provide a cross reference to the more detailed discussion of each of
                                            these risks elsewhere in the prospectus. Revise your risk factor summary to describe the
                                            significant regulatory, liquidity, and enforcement risks. For example, in your risk factor
                                            summary, specifically discuss risks arising from the legal system in China, including risks
                                            and uncertainties regarding the enforcement of laws and that rules and regulations in
                                            China can change quickly with little advance notice; and the risk that the Chinese government
                                            may intervene or influence your operations at any time, or may exert more control over offerings
                                            conducted overseas and/or foreign investment in China-based issuers, which could result in
                                            a material change in your operations and/or the value of the securities you are registering
                                            for sale. Acknowledge any risks that any actions by the Chinese government to exert more
                                            oversight and control over offerings that are conducted overseas and/or foreign investment
                                            in China-based issuers could significantly limit or completely hinder your ability to offer
                                            or continue to offer securities to investors and cause the value of such securities to significantly
                                            decline or be worthless.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 14 – 17 of Amendment No. 2 to provide cross references
to each of the major categories of risks included in the summary. The Company respectfully notes that Item 105 of Regulation S-K provides
that the summary risk factors should be no longer than two pages. The Company believes that a cross reference to each risk would be unduly
repetitive and would more than double the length of the summary as currently drafted. The Company believes that in order to comply with
this comment, the Company would be required to omit half of the risk factors from the risk factor summary, resulting in less fulsome
disclosure.

Questions and Answers for Stockholders of
ExcelFin, page 17

 5. Comment: We acknowledge your response
                                            to prior comment 5, including that The ExcelFin private placement warrants will be terminated
                                            upon the closing of the Business Combination. Given that the private placement warrants will
                                            not be cancelled until closing of the business combination, please expand your disclosure
                                            to address the material risks, if any, to public warrant holders arising from the differences
                                            between private and public warrants. As a related matter, we note your disclosure on page 134
                                            that the Sponsor paid an aggregate of $11,700,000 for the private placement warrants, has
                                            agreed to surrender the private placement warrants for no additional consideration, will
                                            be issued PubCo ordinary shares in exchange for its Class A common stock, and “[i]f
                                            the Business Combination does not close, the private placement warrants will expire worthless
                                            and the Sponsor will have no means to recover its $11,700,000 investment in ExcelFin.”
                                            Please clarify how the Sponsor will recover its $11,700,000 investment in the private placement
                                            warrants if it has agreed to surrender the warrants for no consideration, including if the
                                            Sponsor will receive shares in PubCo in exchange for shares underlying the private placement
                                            warrants.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosures on pages 27, 47, 60, 138, 140 – 141, 164, 206 and 250 of Amendment
No. 2 in response to the Staff’s comment to make it clear that the private placement warrants will either be cancelled or
will expire in accordance with their terms. In no event will the private placement warrants be exercisable, since they are not exercisable
prior to the closing of an initial business combination, and they are being cancelled in connection with the Business Combination. If
the Business Combination is not consummated, ExcelFin does not expect to attempt to close another business combination. The Company has
also revised the disclosures on pages 27, 31, 60, 138, 140, 164, 206 and 345 of Amendment No. 2 to explain that the Sponsor
will attempt to recover its investment in the private placement warrants through the PubCo Ordinary Shares that will be issued to the
Sponsor in connection with the Business Combination in exchange for the Sponsor’s founder shares. The Sponsor currently owns two
types of securities in ExcelFin, namely ExcelFin Class A Common Stock and private placement warrants. The Sponsor will be issued
up to 4,500,000 PubCo Ordinary Shares (including 1,350,000 Earnout Shares) in exchange for its founder shares from which the Sponsor
may recover its investment in the private placement warrants.

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

 6. Comment: We note your revised disclosure
                                            in response to comment 7, including an interim scenario of 17.7% redemptions. Please clarify
                                            what percentage of public shareholders redeem their shares in your maximum redemption scenario.
                                            Please also revise to clarify whether it is possible that more public shareholders may redeem
                                            than assumed for the purposes of your maximum redemption scenario.

Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on pages 23 – 25, 48 – 49, 79 – 80 and 208 – 209
of Amendment No. 2 in response to the Staff’s comment to clarify that maximum redemptions equal 35.4% of ExcelFin Class A
Common Stock. In addition, the Company has revised such disclosure to reflect that maximum redemptions assume PIPE proceeds of $0