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 June 18, 2025

J. Douglas Ramsey, Ph.D
Chief Executive Officer
YD Bio Limited
955 West John Carpenter Freeway
Suite 100-929
Irving, TX, 75039

Ethan Shen, Ph.D
Chief Executive Officer
YD Biopharma Limited
12F., No. 3, Xingnan St.
Nangang Dist.
Taipei City 115001, Taiwan

 Re: YD Bio Limited
 Amendment No. 6 to Registration Statement on Form F-4
 Filed June 5, 2025
 File No. 333-283428
Dear J. Douglas Ramsey Ph.D and Ethan Shen Ph.D:

 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 May 15, 2025
letter.
 June 18, 2025
Page 2
Amendment No. 6 to Form F-4 filed June 5, 2025
The Business Combination
CIAA Breast Cancer License Valuation, page 113

1. With respect to the Breast Cancer License Valuation, under the
"Conclusion" heading
 on page 113 you state: "As of June 30, 2024, the investment value of the
Subject
 Asset was between $747.8 million to $769.6 million," which considers
both the
 Market Approach and Income Approach valuations. We also note your
statement on
 page 125, which appears to cite a different valuation range as CIAA's
conclusion:
 "The income method . . . conclude[s] that the value range of Biopharma
s exclusive
 breast cancer license is between US$620,082,000 and US$777,266,000; the
Market
 Approach estimates that the value range of Biopharma s exclusive
breast cancer
 license is between US$747,847,000 and US$884,952,000 . . . The two
overlapping
 value ranges are between US$747,847,000 and US$769,609,000. The value
range
 determined is not an overlapping value range. Instead, it is recommended
that the
 value range is between US$620,082,000 and US$747,847,000. This
evaluation uses
 this value range as the conclusion of YD Biopharma s exclusive breast
cancer
 license." Please reconcile these statements or advise.

2. We note your revised disclosure in response to prior comment 5, which we
reissue in
 part. With respect to the Breast Cancer License Valuation, when only
considering
 Grail's valuation under the Market Approach the Company's global market
valuation
 range was $747 million to $884 million, as stated on page 113 and shown
in the table
 on page 114. On page 116, in connection with your discussion of the
Market
 Approach, you state: "CIAA selected GRAIL Inc. as a comparable company
and,
 utilizing the share prices as well as the financial and operational data
of relevant
 publicly traded peer companies, calculated the appropriate valuation
multiples . . .
 these multiples were then used in conjunction with YD Biopharma s
financial and
 operational figures as of December 31, 2024, to derive an estimate of
the company s
 enterprise value as of that date." Please revise to provide the
Company's "enterprise
 valuation" calculated by CIAA as part of the Breast Cancer License
Valuation as of
 December 31, 2024, which appears to be based on Grail's data as well as
the data of
 the companies in the table on page 116. Please also reconcile this with
the following
 statement on page 125, which appears to indicate that CIAA only
considered Grail's
 valuation in determining the Market Approach valuation, and did not
consider any
 other companies: "the Market Approach estimates that the value range of
Biopharma s
 exclusive breast cancer license is between US$747,847,000 and
US$884,952,000."
Breeze Board of Directors Reasons for Reaffirmation of the Merger Agreement;
CIAA
Enterprise Valuation, page 125

3. We note your analysis in response to prior comment 9. Please revise your
disclosure
 relating to Grail in this section to briefly describe your consideration
of Grail's current
 stock market valuation and capitalization and why more recent data was
considered
 not suitable for this analysis.
4. We note your statement: "[t]hese newly licensed technologies represent
cutting-edge
 innovations in their respective fields, with intrinsic value likely
materially exceeding
 June 18, 2025
Page 3

 the estimates generated by the Guideline Public Company Method." Please
revise to
 state this as management's belief or note that these tests have not been
commercialized
 and therefore their ultimate value may differ from expectations.
Advancing Noninvasive Cancer Detection with Circulating Cell-Free DNA ("cfDNA")
Methylation Technology, page 223

5. We note your response to prior comment 11. Please revise to clarify
throughout your
 registration statement whether you intend to market your cancer
diagnostic tests that
 are LDTs directly to consumers or just to healthcare providers.
Additionally, revise to
 further clarify the basis for this regulatory distinction between LDTs
sold directly to
 consumers and those performed at the request of a healthcare provider.
 Please contact Christie Wong at 202-551-3684 or Michael Fay at
202-551-3812 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jane Park at 202-551-7439 or Margaret Sawicki at 202-551-7153 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Mathew J. Saur, Esq.
 Marc Rivera, Esq.
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