SecProbe.io

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 Infobird Co., Ltd

 Room 706, 7/F, Low Block,
Grand Millennium Plaza,

 181 Queen's Road
Central,

 Central, Hong Kong

 Via EDGAR

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 December 31, 2025

 Re:
 Infobird Co., Ltd

 Registration Statement on Form F-3 (File No. 333-292415)

 Initially Filed December 23, 2025

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933,
as amended, Infobird Co., Ltd hereby requests acceleration of effectiveness of the above referenced Registration Statement on F-3 (the
"Registration Statement"), so that it will become effective at 4:00 p.m. ET on January 5, 2026, or as soon as thereafter practicable.

 Very truly yours,

 /s/ Xiangyang Wen

 Name:
 Xiangyang Wen

 Title:
 Chief Executive Officer
(Principal Executive
Officer)

 cc:
 Lawrence Venick, Esq.

 Loeb & Loeb LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 December 30, 2025

Xiangyang Wen
Chief Executive Officer
Infobird Co., Ltd
Room 706, 7/F, Low Block, Grand Millennium Plaza
181 Queen s Road Central,
Central, Hong Kong

 Re: Infobird Co., Ltd
 Registration Statement on Form F-3
 Filed December 23, 2025
 File No. 333-292415
Dear Xiangyang Wen:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Matthew Derby at 202-551-3334 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
</TEXT>
</DOCUMENT>

CORRESP
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Infobird Co., Ltd

Room 12A06, Block A, Boya International Center,

Building 2, No. 1 Courtyard, Lize Zhongyi Road

Chaoyang District, Beijing, China 100102

February 15, 2023

VIA EDGAR

U.S. Securities
and Exchange Commission

Division of
Corporate Finance

Washington,
DC 20549

    Re:
    Infobird Co., Ltd

    Registration Statement on Form F-3

    File No. 333-268993

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, NextPlat Corp, a Nevada corporation (the “Company”), hereby respectfully
requests that the effective date for the Registration Statement referenced above be accelerated so that it will be declared effective
at 4:30 P.M. (Eastern Time) on February 17, 2023, or as soon thereafter as possible on such date.

    Very truly yours,

    Infobird Co., Ltd

    By:
    /s/ Cheuk Yee Li

    Name:
    Cheuk Yee Li

    Title:
    Chief Executive Officer

CORRESP
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Infobird
Co., Ltd

Room 12A06, Block A, Boya International Center

Building 2, No. 1 Courtyard, Lize Zhongyi Road

Chaoyang District, Beijing, China 100102

February 1, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, NE

Washington, DC 20549

Attention: Alexandra Barone and Joshua Shainess

Re:	         Infobird Co., Ltd

Registration Statement on Form F-3

Filed December 23, 2022

File No. 333-268993

Dear Ms. Barone and Mr. Shainess:

On behalf of Infobird Co.,
Ltd (the “Company”), set forth below are our responses to the comments provided by the Staff of the Division of Corporate
Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC” or the “Commission”)
in a letter dated January 6, 2023. For your convenience, we have set forth each of the Staff’s comments in bold, italic typeface
followed by our responses. References to “we,” “us,” “our” and “Registrant” refer
to the Company. All responses are those of the Trust and the Company only.

Registration Statement on Form F-3
filed December 23, 2022

Cover Page

1.	            Provide a description of how cash
is transferred through your organization and disclose your intentions to distribute earnings or settle amounts owed under the VIE
agreements. State whether any transfers, dividends, or distributions have been made to date between the holding company, its subsidiaries,
and consolidated VIEs, or to investors, and quantify the amounts where applicable. Provide cross-references to the condensed consolidating
schedule and the consolidated financial statements.

 RESPONSE: The Company has revised the disclosure on the cover page of the prospectus to include summary disclosure
regarding the cash transfers within the Company’s organization as well as to quantify the such transfers during the fiscal
year ended December 31, 2022. The Company has also revised the disclosure to include (a) a cross reference directing investors
to the section titled “Cash Transfers Within Our Organization” for further information, and (b) a cross reference to
the principles of consolidation set forth in the notes to the Company’s Consolidated Financial Statements for the years ended
December 31, 2021, 2020 and 2019 located in Amendment 1 to the Company’s Annual Report on Form 20-F filed with the SEC on
October 21, 2022. Similar disclosure was also added to the section entitled “Cash and Asset Flows Through Our Organization.”

United
States Securities and Exchange Commission

Attention:
Alexandra Barone and Joshua Shainess

February 1, 2023

Page 2

Summary, page 1

2.	            We note the diagram of the company’s
corporate structure on page 36; however, please provide early in the summary a diagram of the company’s corporate structure,
identifying the person or entity that owns the equity in each depicted entity. Additionally, revise to ensure the diagram is fully
legible.

 RESPONSE: The Company has updated disclosure in the prospectus summary and has revised the diagram of the
Company’s corporate structure to ensure that it is fully legible.

3.	            We note your discussion
of how cash is transferred through your organization on page 82. In your prospectus summary, please provide a clear description
of how cash is transferred through your organization. Disclose your intentions to distribute earnings or settle amounts owed under
the VIE agreements. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company,
its subsidiaries, and the consolidated VIEs, and direction of transfer. Quantify any dividends or distributions that a subsidiary
or consolidated VIE have 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 and/or the consolidated VIEs, to the parent company
and U.S. investors as well as the ability to settle amounts owed under the VIE agreements.

 RESPONSE: The
                                                                                                                                   Company
                                                                                                                                   has
                                                                                                                                   revised
                                                                                                                                   the
                                                                                                                                   prospectus
                                                                                                                                   summary
                                                                                                                                   to
                                                                                                                                   include
                                                                                                                                   a
                                                                                                                                   discussion
                                                                                                                                   of
                                                                                                                                   how
                                                                                                                                   cash
                                                                                                                                   is
                                                                                                                                   transferred
                                                                                                                                   through
                                                                                                                                   our
                                                                                                                                   organization
                                                                                                                                   and
                                                                                                                                   the
                                                                                                                                   potential
                                                                                                                                   limitations
                                                                                                                                   and
                                                                                                                                   restrictions
                                                                                                                                   on
                                                                                                                                   the
                                                                                                                                   Company’s
                                                                                                                                   ability
                                                                                                                                   to
                                                                                                                                   transfer
                                                                                                                                   cash
                                                                                                                                   across
                                                                                                                                   borders.
                                                                                                                                   The
                                                                                                                                   company
                                                                                                                                   has
                                                                                                                                   also
                                                                                                                                   quantified
                                                                                                                                   the
                                                                                                                                   amounts
                                                                                                                                   transferred
                                                                                                                                   in
                                                                                                                                   the
                                                                                                                                   last
                                                                                                                                   year:
                                                                                                                                   (a) between
                                                                                                                                   Infobird
                                                                                                                                   Cayman
                                                                                                                                   (the
                                                                                                                                   public
                                                                                                                                   parent)
                                                                                                                                   and
                                                                                                                                   its
                                                                                                                                   subsidiary,
                                                                                                                                   Infobird
                                                                                                                                   HK;
                                                                                                                                   (b)
                                                                                                                                   between
                                                                                                                                   Infobird
                                                                                                                                   HK
                                                                                                                                   and
                                                                                                                                   its
                                                                                                                                   subsidiary,
                                                                                                                                   Infobird
                                                                                                                                   WFOE;
                                                                                                                                   (c) from
                                                                                                                                   Inborid
                                                                                                                                   WFOE
                                                                                                                                   to
                                                                                                                                   the
                                                                                                                                   consolidated
                                                                                                                                   VIE;
                                                                                                                                   and
                                                                                                                                   (d) from
                                                                                                                                   the
                                                                                                                                   consolidated
                                                                                                                                   VIE
                                                                                                                                   to
                                                                                                                                   Infobird
                                                                                                                                   WFOE.
                                                                                                                                   In
                                                                                                                                   addition,
                                                                                                                                   the

United States securities and exchange commission logo
January 6, 2023
Cheuk Yee Li
Chief Executive Officer
Infobird Co., Ltd
Room 12A06, Block A, Boya International Center
Building 2, No. 1 Courtyard, Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Registration Statement on Form F-3
Filed December 23, 2022
File No. 333-268993
Dear Cheuk Yee Li:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-3 filed December 23, 2022
Cover Page
1.Provide a description of how cash is transferred through your organization and disclose
your intentions to distribute earnings or settle amounts owed under the VIE agreements.
State whether any transfers, dividends, or distributions have been made to date between
the holding company, its subsidiaries, and consolidated VIEs, or to investors, and quantify
the amounts where applicable. Provide cross-references to the condensed consolidating
schedule and the consolidated financial statements.

 FirstName LastNameCheuk Yee Li
 Comapany NameInfobird Co., Ltd
 January 6, 2023 Page 2
 FirstName LastName
Cheuk Yee Li
Infobird Co., Ltd
January 6, 2023
Page 2
Summary, page 1
2.We note the diagram of the company's corporate structure on page 36; however,
please provide early in the summary a diagram of the company’s corporate structure,
identifying the person or entity that owns the equity in each depicted entity.  Additionally,
revise to ensure the diagram is fully legible.
3.We note your discussion of how cash is transferred through your organization on page 82.
In your prospectus summary, please provide a clear description of how cash is transferred
through your organization. Disclose your intentions to distribute earnings or settle
amounts owed under the VIE agreements. Quantify any cash flows and transfers of other
assets by type that have occurred between the holding company, its subsidiaries, and the
consolidated VIEs, and direction of transfer. Quantify any dividends or distributions that a
subsidiary or consolidated VIE have 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 and/or the
consolidated VIEs, to the parent company and U.S. investors as well as the ability to settle
amounts owed under the VIE agreements.
4.We note your disclosure on page 38 with respect to the permissions or approvals you need
to operate your business in China. In both the prospectus summary and in your summary
of risk factors, please revise to also discuss any permissions and approvals required to be
obtained from Chinese authorities to offer securities to foreign investors. In the case of
each of the permissions required to operate your business in China and to offer securities
to foreign investors, if you determine no permissions are required, provide an explanation
as to whether you consulted counsel and, if not, why you did not consult counsel and why
you believe you do not need any permissions or approvals.
Summary of Risk Factors, page 39
5.For each risk related to doing business in China, provide a specific cross-reference to the
more detailed risk factor.

 FirstName LastNameCheuk Yee Li
 Comapany NameInfobird Co., Ltd
 January 6, 2023 Page 3
 FirstName LastName
Cheuk Yee Li
Infobird Co., Ltd
January 6, 2023
Page 3
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rule 461 regarding requests for acceleration.  Please allow adequate time for us
to review any amendment prior to the requested effective date of the registration statement.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Joshua Shainess,
Legal Branch Chief, at (202) 551-7951 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Marc Rivera

United States securities and exchange commission logo
November 10, 2022
Yimin Wu
Chief Executive Officer
Infobird Co., Ltd
Room 12A05, Block A, Boya International Center
Building 2, No. 1 Courtyard, Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Form 20-F for the fiscal year ended December 31, 2021
Response dated September 15, 2022
File No. 001-40301
Dear Yimin Wu:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Technology

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October 21, 2022

VIA EDGAR

U.S. Securities and
Exchange Commission

Division of Corporation
Finance

100 F. Street, N.E.

Washington, D.C. 20549

    Attn:
    Morgan Youngwood

    Stephen Krikorian

    Re:
    Infobird Co., Ltd

    Form 20-F for the fiscal year ended December 31, 2021

Ladies and Gentlemen:

Infobird Co., Ltd (the “Company”
or “we”), hereby provides the following information in response to the comment received from the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in its letter to the Company dated October 14, 2022
(the “Comment Letter”). The Company’s response is preceded by a reproduction of the corresponding Staff comment
in bold as set forth in the Comment Letter.

If the Staff would like hard copies
of Amendment No. 1 to the Annual Report on Form 20-F (the “Form 20-F/A”) as filed with the Commission on the date hereof,
marked against the Annual Report on Form 20-F as filed with the Commission on May 16, 2022, please so advise and we would be happy to
provide such copies. All page number references contained in the Company’s response below correspond to the page numbers in the
Form 20-F/A.

Form 20-F for the fiscal year ended December
31, 2021

Cash and Asset Flows Through Our Organization,
page viii

    1.
    We note your proposed disclosures in response to prior comment 8. Please revise to disclose whether you have written cash management policies and procedures that dictate how funds are transferred, and if so, describe these policies and procedures (e.g., a policy that addresses how a company handles any limitations on cash transfers due to PRC law).

Company Response: The Company acknowledges
the Staff’s comment and has revised the disclosure on page viii of the Form 20-F/A accordingly.

***

If you have any questions or comments
concerning these responses, please do not hesitate to contact me by telephone at 86-010-52411819 or by e-mail at wuym@infobird.com or
the Company’s counsel by telephone at 305-539-3306 or by e-mail at clayton.parker@klgates.com.

    Sincerely,

    /s/ Yimin Wu

    Yimin Wu, Chief Executive Officer and Chairman of the Board of Directors

cc:

Clayton E. Parker, Esq., K&L Gates LLP

United States securities and exchange commission logo
October 14, 2022
Yimin Wu
Chief Executive Officer
Infobird Co., Ltd
Room 12A05, Block A, Boya International Center
Building 2, No. 1 Courtyard, Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Form 20-F for the fiscal year ended December 31, 2021
Response dated September 15, 2022
File No. 001-40301
Dear Yimin Wu:
            We have reviewed your September 15, 2022 response to our comment letter and have the
following comment.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
August 8, 2022 letter.
Form 20-F for the fiscal year ended December 31, 2021
Cash and Asset Flows Through Our Organization, page viii
1.We note your proposed disclosures in response to prior comment 8.  Please revise
to disclose whether you have written cash management policies and procedures that
dictate how funds are transferred, and if so, describe these policies and procedures (e.g., a
policy that addresses how a company handles any limitations on cash transfers due to PRC
law).
            You may contact Morgan Youngwood, Senior Staff Accountant at 202-551-3479 or
Stephen Krikorian, Accounting Branch Chief at 202-551-3488 if you have questions regarding
comments on the financial statements and related matters.

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 October 14, 2022 Page 2
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
October 14, 2022
Page 2
Sincerely,
Division of Corporation Finance
Office of Technology

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September 15, 2022

VIA EDGAR

U.S. Securities
and Exchange Commission

Division
of Corporation Finance

100 F.
Street, N.E.

Washington,
D.C. 20549

Attn:
Morgan Youngwood

Stephen Krikorian

Re:
Infobird
Co., Ltd

Form 20-F for the fiscal
year ended December 31, 2021

Ladies and Gentlemen:

Infobird Co., Ltd
(the “Company” or “we”), hereby provides the following information in response to the comments
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
in its letter to the Company dated August 8, 2022 (the “Comment Letter”). The Company’s responses are
preceded by a reproduction of the corresponding Staff comments in bold as set forth in the Comment Letter.

To assist the Staff’s review,
the Company has attached as a courtesy copy .pdf a redline copy of the proposed Amendment No. 1 to the Annual Report on Form 20-F (the
“Draft Form 20-F/A”), marked against the Annual Report on Form 20-F as filed with the Commission on May 16, 2022 to
show the Company’s proposed revisions in response to the Staff’s comments. All page number references contained in the Company’s
responses below correspond to the page numbers in the Draft Form 20-F/A. Any capitalized terms used herein but not defined herein shall
have the meanings given to them in the Draft Form 20-F/A.

In addition, the Company effected
a one-for-five share consolidation effective on September 9, 2022 (the “Share Consolidation”). The Company is of the
understanding that the information in the Draft Form 20-F/A, including the consolidated financial statements, is not required to be retroactively
revised to reflect the Share Consolidation, as the information in the Draft Form 20-F/A, including the consolidated financial statements,
shall speak as of the filing date of the Annual Report on Form 20-F as filed with the Commission on May 16, 2022, as indicated in the
Explanatory Note on page ii of the Draft Form 20-F/A. If the Staff disagrees with such position, the Company would greatly appreciate
the Staff’s indication of this. The Company acknowledges that it and its management are responsible for the accuracy and adequacy
of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.

Form 20-F for the fiscal year
ended December 31, 2021

Introduction, page 1

    1.
    Please disclose
    prominently in this section that you are not a Chinese operating company but a Cayman Islands holding company with operations
    conducted by your subsidiaries and through contractual arrangements with a variable interest entity (VIE) based in China and
    that this structure involves unique risks to investors. If true, disclose that these contracts have not been tested in court.
    Explain whether the VIE structure is used to provide investors with exposure to foreign investment in China-based companies
    where Chinese law prohibits direct foreign investment in the operating companies, and disclose that investors may never hold
    equity interests in the Chinese operating company. Your disclosure should acknowledge that Chinese regulatory authorities
    could disallow this structure, which would likely result in a material change in your operations and/or a material change
    in the value of the securities, including that it could cause the value of such securities to significantly decline or become
    worthless. Provide a cross-reference to your detailed discussion of risks facing the company and the offering as a result
    of this structure.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages iii, iv, xx, xxi, 11 and 12 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

2.
Provide prominent disclosure in this section about the legal and operational risks associated with being based in or having the majority of the company’s operations in China. Your disclosure should make clear whether these risks could result in a material change in your operations and/or the value of the securities 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. Your disclosure should address how recent statements and regulatory actions by China’s government, such as those related to the use of variable interest entities and data security or anti-monopoly concerns, have or may impact the company’s ability to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange. Please disclose whether your auditor is subject to the determinations announced by the PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies Accountable Act and related regulations will affect your company.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages iv, v, vii and 23 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

    3.
    Clearly disclose
    how you will refer to the holding company, subsidiaries, and VIEs 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. Refrain from using terms such as “we” or “our” when describing activities
    or functions of a VIE. For example, disclose, if true, that your subsidiaries and/or the VIE conduct operations in China,
    that the VIE is consolidated for accounting purposes but is not an entity in which you own equity, and that the holding company
    does not conduct operations. Disclose clearly the entity (including the domicile) in which investors are purchasing an interest.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages iii, 12, 13, 15, 30, 35, 51, 66, 78 and 85 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

    4.
    Disclose clearly
    that the company uses a structure that involves a VIE based in China and what that entails, and provide early in the introduction
    section a diagram of the company’s corporate structure, identifying the person or entity that owns the equity in each
    depicted entity. Describe all contracts and arrangements through which you claim to have economic rights and exercise control
    that results in consolidation of the VIE’s operations and financial results into your financial statements. Identify
    clearly the entity in which investors are purchasing their interest and the entity(ies) in which the company’s operations
    are conducted. Describe the relevant contractual agreements between the entities and how this type of corporate structure
    may affect investors and the value of their investment, including how and why the contractual arrangements may be less effective
    than direct ownership, and that the company may incur substantial costs to enforce the terms of the arrangements. Disclose
    the uncertainties regarding the status of the rights of the Cayman Islands holding company with respect to its contractual
    arrangements with the VIE, its founders and owners, and the challenges the company may face enforcing these contractual agreements
    due to legal uncertainties and jurisdictional limits.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages iii, vi, xx, xxi, 11, 12, 31 and 51 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

    5.
    We note your
    disclosure that the Cayman Islands holding company controls and receives the economic benefits of the VIE’s business
    operations through contractual agreements between the VIE and your Wholly Foreign-Owned Enterprise (WFOE) and that those agreements
    are designed to provide your WFOE with the power, rights, and obligations equivalent in all material respects to those it
    would possess as the principal equity holder of the VIE. We also note your disclosure that the Cayman Islands holding company
    is the primary beneficiary of the VIE. However, neither the investors in the holding company nor the holding company itself
    have an equity ownership in, direct foreign investment in, or control of, through such ownership or investment, the VIE. Accordingly,
    please refrain from implying that the contractual agreements are equivalent to equity ownership in the business of the VIE.
    Any references to control or benefits that accrue to you because of the VIE should be limited to a clear description of the
    conditions you have satisfied for consolidation of the VIE under U.S. GAAP. Additionally, your disclosure should clarify that
    you are the primary beneficiary of the VIE for accounting purposes. Please also disclose, if true, that the VIE agreements
    have not been tested in a court of law.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages iv, vi, vii, x, xx, 11, 12, 30, 31, F-7, F-10 and F-23 of the Draft Form 20-F/A accordingly as shown in the attached
redline copy.

    6.
    In your summary
    of risk factors, disclose the risks that your corporate structure and being based in or having the majority of the company’s
    operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks
    with cross-references to the more detailed discussion of these risks in the filing. For example, 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 your securities. 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.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages v, xx, xxi, 15 and 16 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

    7.
    Disclose each
    permission or approval that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to operate
    your business and to offer the registered securities to foreign investors. State whether you, your subsidiaries, or VIEs are
    covered by permissions requirements from the China Securities Regulatory Commission (CSRC), Cyberspace Administration of China
    (CAC) or any other governmental agency that is required to approve the VIE’s operations, and state affirmatively whether
    you have received all requisite permissions or approvals and whether any permissions or approvals have been denied. Please
    also describe the consequences to you and your investors if you, your subsidiaries, or the VIEs: (i) do not receive or maintain
    such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable
    laws, regulations, or interpretations change and you are required to obtain such permissions or approvals in the future.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages viii, 17 and 19 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

8.
In this section, provide a clear description of how cash is transferred through your organization. Disclose your intentions to distribute earnings or settle amounts owed under the VIE agreements. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company, its subsidiaries, and the consolidated VIEs, and direction of transfer. Quantify any dividends or distributions that a subsidiary or consolidated VIE have 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 and/or the consolidated VIEs, to the parent company and U.S. investors as well as the ability to settle amounts owed under the VIE agreements.

Company Response: The
Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages viii, ix and x of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

    9.
    We note that
    the consolidated VIEs constitute a material part of your consolidated financial statements. Please provide in tabular form
    a condensed consolidating schedule that disaggregates the operations and depicts the financial position, cash flows, and results
    of operations as of the same dates and for the same periods for which audited consolidated financial statements are required.
    The schedule should present major line items, such as revenue and cost of goods/services, and subtotals and disaggregated
    intercompany amounts, such as separate line items for intercompany receivables and investment in subsidiary. The schedule
    should also disaggregate the parent company, the VIEs and its consolidated subsidiaries, the WFOEs that are the primary beneficiary
    of the VIEs, and an aggregation of other entities that are consolidated. The objective of this disclosure is to allow an investor
    to evaluate the nature of assets held by, and the operations of, entities apart from the VIE, as well as the nature and amounts
    associated with intercompany transactions. Any intercompany amounts should be presented on a gross basis and when necessary,
    additional disclosure about such amounts should be included in order to make the information presented not misleading.

Company Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on pages x - xix of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

Risk
Factors

Our
business generates and processes a large amount of data and we are required to comply with PRC and other applicable laws…,
page 18

    10.
    In light of recent
    events indicating greater oversight by the Cyberspace Administration of China (CAC) over data security, particularly for companies
    seeking to list on a foreign exchange, please revise your disclosure to explain how this oversight impacts your business and
    your registered securities and to what extent you believe that you are compliant with the regulations or policies that have
    been issued by the CAC to date.

Company
Response: The Company acknowledges the Staff’s comment and proposes to revise the
disclosure on page 17 of the Draft Form 20-F/A accordingly as shown in the attached redline copy.

***

If
you have any questions or comments concerning these responses, please do not hesitate to contact me by telephone at 86-010-52411819
or by e-mail at wuym@infobird.com or the Company’s counsel by telephone at 305-539

CORRESP
1
filename1.htm

September 2, 2022

VIA EDGAR

U.S. Securities and
Exchange Commission

Division of Corporation
Finance

100 F. Street, N.E.

Washington, D.C. 20549

    Attn:
    Morgan Youngwood

    Stephen Krikorian

    Re:
    Infobird Co., Ltd

    Form 20-F for the fiscal year ended December 31, 2021

Dear Mr. Youngwood and Mr. Krikorian:

Reference is made to the comment
letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
dated August 8, 2022 (the “Comment Letter”) received by Infobird Co., Ltd (the “Company” or “we”)
regarding the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2021 as filed with the Commission on May
16, 2022 (the “Form 20-F”), and the Company’s letter to the SEC dated August 18, 2022 requesting an extension
of ten business days to respond to the Comment Letter.

We have been diligently working
on responding to the Comment Letter and preparing an Amendment to the Form 20-F; however, we will need additional time to respond and
file the Amendment to the Form 20-F, particularly as our auditor (Friedman LLP, which merged with Marcum LLP effective September 1, 2022)
requires additional time to complete its internal procedures. We hereby request an extension of an additional ten business days to provide
a response to the Comment Letter and file the Amendment to the Form 20-F.

Thank you for your consideration
of this request for extension. If you have any questions or require any additional information with respect to the above, please do not
hesitate to contact me by telephone at 86-010-52411819 or by e-mail at wuym@infobird.com or the Company’s counsel by telephone at
305-539-3306 or by e-mail at clayton.parker@klgates.com.

    Sincerely,

    /s/ Yimin Wu

    Yimin Wu, Chief Executive Officer and Chairman of the Board of Directors

cc:

Clayton E. Parker, Esq., K&L Gates LLP

CORRESP
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August 18, 2022

VIA EDGAR

U.S. Securities and
Exchange Commission

Division of Corporation
Finance

100 F. Street, N.E.

Washington, D.C. 20549

    Attn:
    Morgan Youngwood

    Stephen Krikorian

    Re:
    Infobird Co., Ltd

    Form 20-F for the fiscal year ended December 31, 2021

Dear Mr. Youngwood and Mr. Krikorian:

Reference is made to the comment
letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
dated August 8, 2022 (the “Comment Letter”) received by Infobird Co., Ltd (the “Company” or “we”)
regarding the Company’s Annual Report on Form 20-F for the fiscal year ended December 31, 2021 as filed with the Commission on May
16, 2022.

The Staff has requested that the
Company respond to the Comment Letter within ten business days or advise the Staff of when the Company will provide a response. We have
been diligently working on responding to the Comment Letter; however, we will need additional time to respond. We hereby request an extension
of an additional ten business days to provide a response to the Comment Letter.

Thank you for your consideration
of this request for extension. If you have any questions or require any additional information with respect to the above, please do not
hesitate to contact me by telephone at 86-010-52411819 or by e-mail at wuym@infobird.com or the Company’s counsel by telephone at
305-539-3306 or by e-mail at clayton.parker@klgates.com.

    Sincerely,

    /s/ Yimin Wu

    Yimin Wu, Chief Executive Officer and Chairman of the Board of Directors

cc:

Clayton E. Parker, Esq., K&L Gates LLP

United States securities and exchange commission logo
August 8, 2022
Yimin Wu
Chief Executive Officer
Infobird Co., Ltd
Room 12A05, Block A, Boya International Center
Building 2, No. 1 Courtyard, Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Form 20-F for the fiscal year ended December 31, 2021
Dear Mr. Wu:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the fiscal year ended December 31 , 2021
Introduction, page 1
1.Please disclose prominently in this section that you are not a Chinese operating company
but a Cayman Islands holding company with operations conducted by your subsidiaries
and through contractual arrangements with a variable interest entity (VIE) based in China
and that this structure involves unique risks to investors. If true, disclose that these
contracts have not been tested in court. Explain whether the VIE structure is used to
provide investors with exposure to foreign investment in China-based companies where
Chinese law prohibits direct foreign investment in the operating companies, and disclose
that investors may never hold equity interests in the Chinese operating company. Your
disclosure should acknowledge that Chinese regulatory authorities could disallow this
structure, which would likely result in a material change in your operations and/or a
material change in the value of the securities, including that it could cause the value of
such securities to significantly decline or become worthless. Provide a cross-reference to
your detailed discussion of risks facing the company and the offering as a result of this

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 8, 2022 Page 2
 FirstName LastNameYimin Wu
Infobird Co., Ltd
August 8, 2022
Page 2
structure.
2.Provide prominent disclosure in this section about the legal and operational risks
associated with being based in or having the majority of the company’s operations in
China. Your disclosure should make clear whether these risks could result in a material
change in your operations and/or the value of the securities 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. Your disclosure
should address how recent statements and regulatory actions by China’s government, such
as those related to the use of variable interest entities and data security or anti-monopoly
concerns, have or may impact the company’s ability to conduct its business, accept
foreign investments, or list on a U.S. or other foreign exchange. Please disclose whether
your auditor is subject to the determinations announced by the PCAOB on December 16,
2021 and whether and how the Holding Foreign Companies Accountable Act and related
regulations will affect your company.
3.Clearly disclose how you will refer to the holding company, subsidiaries, and VIEs 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. Refrain from using terms such as “we” or “our” when describing
activities or functions of a VIE. For example, disclose, if true, that your subsidiaries
and/or the VIE conduct operations in China, that the VIE is consolidated for accounting
purposes but is not an entity in which you own equity, and that the holding company does
not conduct operations. Disclose clearly the entity (including the domicile) in which
investors are purchasing an interest.
4.Disclose clearly that the company uses a structure that involves a VIE based in China and
what that entails, and provide early in the introduction section a diagram of the company’s
corporate structure, identifying the person or entity that owns the equity in each depicted
entity. Describe all contracts and arrangements through which you claim to have
economic rights and exercise control that results in consolidation of the VIE’s operations
and financial results into your financial statements. Identify clearly the entity in which
investors are purchasing their interest and the entity(ies) in which the company’s
operations are conducted. Describe the relevant contractual agreements between the
entities and how this type of corporate structure may affect investors and the value of their
investment, including how and why the contractual arrangements may be less effective
than direct ownership and that the company may incur substantial costs to enforce the
terms of the arrangements. Disclose the uncertainties regarding the status of the rights of
the Cayman Islands holding company with respect to its contractual arrangements with the
VIE, its founders and owners, and the challenges the company may face enforcing these
contractual agreements due to legal uncertainties and jurisdictional limits.
5.We note your disclosure that the Cayman Islands holding company controls and receives
the economic benefits of the VIE’s business operations through contractual agreements
between the VIE and your Wholly Foreign-Owned Enterprise (WFOE) and that those

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 8, 2022 Page 3
 FirstName LastNameYimin Wu
Infobird Co., Ltd
August 8, 2022
Page 3
agreements are designed to provide your WFOE with the power, rights, and obligations
equivalent in all material respects to those it would possess as the principal equity holder
of the VIE. We also note your disclosure that the Cayman Islands holding company is the
primary beneficiary of the VIE. However, neither the investors in the holding company
nor the holding company itself have an equity ownership in, direct foreign investment in,
or control of, through such ownership or investment, the VIE. Accordingly, please refrain
from implying that the contractual agreements are equivalent to equity ownership in the
business of the VIE. Any references to control or benefits that accrue to you because of
the VIE should be limited to a clear description of the conditions you have satisfied for
consolidation of the VIE under U.S. GAAP. Additionally, your disclosure should clarify
that you are the primary beneficiary of the VIE for accounting purposes. Please also
disclose, if true, that the VIE agreements have not been tested in a court of law.
6.In your summary of risk factors, disclose the risks that your corporate structure and being
based in or having the majority of the company’s operations in China poses to investors.
In particular, describe the significant regulatory, liquidity, and enforcement risks with
cross-references to the more detailed discussion of these risks in the filing. For example,
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 your securities.
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.
7.Disclose each permission or approval that you, your subsidiaries, or the VIEs are required
to obtain from Chinese authorities to operate your business and to offer the registered
securities to foreign investors. State whether you, your subsidiaries, or VIEs are covered
by permissions requirements from the China Securities Regulatory Commission (CSRC),
Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve the VIE’s operations, and state affirmatively whether you have
received all requisite permissions or approvals and whether any permissions or approvals
have been denied. Please also describe the consequences to you and your investors if you,
your subsidiaries, or the VIEs: (i) do not receive or maintain such permissions or
approvals, (ii) inadvertently conclude that such permissions or approvals are not required,
or (iii) applicable laws, regulations, or interpretations change and you are required to
obtain such permissions or approvals in the future.
8.In this section, provide a clear description of how cash is transferred through your
organization. Disclose your intentions to distribute earnings or settle amounts owed under

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 8, 2022 Page 4
 FirstName LastNameYimin Wu
Infobird Co., Ltd
August 8, 2022
Page 4
the VIE agreements. Quantify any cash flows and transfers of other assets by type that
have occurred between the holding company, its subsidiaries, and the consolidated VIEs,
and direction of transfer. Quantify any dividends or distributions that a subsidiary or
consolidated VIE have 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 and/or the consolidated VIEs, to
the parent company and U.S. investors as well as the ability to settle amounts owed under
the VIE agreements.
9.We note that the consolidated VIEs constitute a material part of your consolidated
financial statements. Please provide in tabular form a condensed consolidating schedule
that disaggregates the operations and depicts the financial position, cash flows, and results
of operations as of the same dates and for the same periods for which audited consolidated
financial statements are required. The schedule should present major line items, such as
revenue and cost of goods/services, and subtotals and disaggregated intercompany
amounts, such as separate line items for intercompany receivables and investment in
subsidiary. The schedule should also disaggregate the parent company, the VIEs and its
consolidated subsidiaries, the WFOEs that are the primary beneficiary of the VIEs, and an
aggregation of other entities that are consolidated. The objective of this disclosure is to
allow an investor to evaluate the nature of assets held by, and the operations of, entities
apart from the VIE, as well as the nature and amounts associated with intercompany
transactions. Any intercompany amounts should be presented on a gross basis and when
necessary, additional disclosure about such amounts should be included in order to make
the information presented not misleading.
Risk Factors
Our business generates and processes a large amount of data, and we are required to comply with
PRC and other applicable laws..., page 18
10.In light of recent events indicating greater oversight by the Cyberspace Administration of
China (CAC) over data security, particularly for companies seeking to list on a foreign
exchange, please revise your disclosure to explain how this oversight impacts your
business and your registered securities and to what extent you believe that you are
compliant with the regulations or policies that have been issued by the CAC to date.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Morgan Youngwood, Senior Staff Accountant at 202-551-3479 or

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 8, 2022 Page 5
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
August 8, 2022
Page 5
Stephen Krikorian, Accounting Branch Chief at 202-551-3488 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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Infobird
Co., Ltd

Room
12A05, Block A, Boya International Center

Building
2, No. 1 Courtyard, Lize Zhongyi Road

Chaoyang
District, Beijing, China 100102

March
29, 2021

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attn:  Edwin
                                            Kim

    Jan
                                            Woo

Re:  Infobird
                                            Co., Ltd

    Request
                                            for Acceleration of Registration Statement on Form F-1, as amended

    File
                                            No. 333-251234

Ladies
and Gentlemen:

In
connection with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities
and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), Infobird Co., Ltd hereby requests
acceleration of effectiveness of the above-referenced Registration Statement so that it will be declared effective at 4:00 p.m., Eastern
Time, on Wednesday, March 31, 2021, or as soon as practicable thereafter.

Very
truly yours,

INFOBIRD
CO., LTD

By:
	/s/ Yimin Wu

Name:	Yimin
Wu

Title:	Chief
Executive Officer and Chairman of the Board of Directors

CORRESP
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filename1.htm

WestPark
Capital, Inc.

Suite
310, 1900 Avenue of the Stars

Los
Angeles, CA 90067

United
States of America

As
representatives of the several underwriters

VIA
EDGAR

March
29, 2021

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Attn:  Edwin
                                            Kim

    Jan
                                            Woo

Re:  Infobird
                                            Co., Ltd

    Request
                                            for Acceleration of Registration Statement on Form F-1, as amended

    File
                                            No. 333-251234

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as
representatives of the several underwriters of the Company’s proposed initial public offering, hereby join the Company’s
request that the effective date of the above-referenced Registration Statement be accelerated so that the above-referenced Registration
Statement will be declared effective at 4:00 p.m., Eastern Time, on March 31, 2021, or as soon thereafter as is practicable.

Pursuant
to Rule 460 of the Securities Act, we wish to advise you that we have effected the following distribution of the Company’s Preliminary
Prospectus, dated March 15, 2021, through the date hereof:

Preliminary
Prospectus dated March 15, 2021:

500 copies to prospective underwriters,
institutional investors, dealers and others

The
undersigned advise that they have complied and will continue to comply, and that they have been informed by the participating underwriters
and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

[Remainder
of Page Intentionally Left Blank]

    1

Very
truly yours,

By
Westpark Capital, Inc.

By:	/s/
Craig Kaufman	                                       

	Authorized Representative

Acting
on behalf of themselves and as the Representatives of the several Underwriters

    2

CORRESP
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January 12, 2021

VIA EDGAR

U.S. Securities
and Exchange Commission

Division
of Corporation Finance

100 F. Street,
N.E.

Washington,
D.C. 20549

    Attn:
    Edwin Kim

    Jan Woo

    Re:
    Infobird Co., Ltd

        Registration Statement on Form F-1

        Filed December 9, 2020

    File No. 333-251234

Ladies and Gentlemen:

Infobird Co., Ltd (the
“Company” or “we”), hereby provides the following information in response to the comments
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
in its letter to the Company dated December 23, 2020 (the “Comment Letter”). The Company’s responses are
preceded by a reproduction of the corresponding Staff comments in bold as set forth in the Comment Letter.

If the Staff would
like hard copies of the Amendment to the Registration Statement on Form F-1 (the “Registration Statement”) as
filed with the Commission on the date hereof, marked against the Registration Statement on Form F-1 as filed with the Commission
on December 9, 2020, please so advise and we would be happy to provide such copies. All page number references contained in the
Company’s responses below correspond to the page numbers in the Registration Statement. Any capitalized terms used herein
but not defined herein shall have the meanings given to them in the Registration Statement.

Registration Statement on Form F-1

Prospectus Summary, page 1

    1.
    Please revise to describe the changes with your relationship with your largest customer, China Guangfa Bank. Please clarify in your summary that your services agreement for customized cloud-based services expired on June 30, 2020 and you have been operating under an “oral arrangement” since then. Further, your telecommunication services agreement with China Guangfa Bank will expire on December 31, 2020. Please describe how the oral arrangement differs from your written contractual relationship prior to June 30, 2020 and whether you derive material amounts of revenue from the soon-to-be expiring telecommunications services agreement with China Guangfa Bank. Please also explain how China Guangfa Bank is changing its internal telemarking strategy and how that affects the services you provide to this customer.

Company Response: The
Company acknowledges the Staff’s comment and has revised the disclosure on pages 6, 10, 48, 49, 51, 58, 63, and 68 of the
Registration Statement accordingly.

China Guangfa Bank has not renewed
the services agreement for customized cloud-based services that expired on June 30, 2020. The Company was operating under oral
arrangements to complete ongoing projects under such agreement. The Company and China Guangfa Bank are currently not operating
under such agreement. China Guangfa Bank also has not renewed the telecommunications services agreement that expired on December
31, 2020, and the Company and China Guangfa Bank are currently not operating under such agreement. The Company does not derive
material amounts of revenue from the expired telecommunications services agreement with China Guangfa Bank.

The Company is negotiating with
China Guangfa Bank to provide new products and services to China Guangfa Bank. Currently, China Guangfa Bank’s internal telemarketing
strategy is to increase its internal IT capabilities. Therefore, China Guangfa Bank no longer procures such services from a third-party
provider, including the Company, which affects the services the Company provides to China Guangfa Bank. Due to the Company’s
long-lasting relationship with China Guangfa Bank, it has been actively communicating with China Guangfa Bank to explore cooperative
opportunities involving its standard cloud-based services in other business lines.

It is currently preliminarily
anticipated that China Guangfa Bank will account for less than 5%, approximately 30% and approximately 5% of the Company’s
total revenues for the second half of the 2020 fiscal year, the full 2020 fiscal year and the full 2021 fiscal year, respectively.
As previously disclosed on pages 48 and 51 of the Registration Statement on Form F-1 as filed with the Commission on December 9,
2020, and in the Registration Statement, in 2021 and beyond, the Company expects its revenues will not be largely solely driven
from a single major customer and that its standard cloud-based services will constitute the major portion of its 2021 revenue as
compared to customized cloud-based services.

In the second half of the 2020
fiscal year, the Company retained its client base and actively enhanced its sales and marketing by increasing its team size and
marketing efforts in China. The Company has also been expanding its client base with its cloud-based call center and its intelligent
AI-powered products and has obtained some new large contracts. The new clients are primarily in the internet, BPO and telecommunications
industries. The Company has also been engaging with clients in the finance, healthcare, retail, and consumer products industries
and has entered into contracts with several of these clients. The Company believes these new contracts will increase its revenue
for the 2021 fiscal year while diversifying its client base.

    1

Corporate History and Structure,
page 43

    2.
    We note that you have filed your VIE agreements as exhibits related to your VIE entity, Infobird Beijing. Please revise to describe the management structure and officers and directors of Infobird Beijing.

Company Response: The
Company acknowledges the Staff’s comment and has revised the disclosure on pages 3 and 43 of the Registration Statement accordingly.

***

If you have any questions
or comments concerning these responses, please do not hesitate to contact me by telephone at 86-010-52411819 or by e-mail at wuym@infobird.com
or the Company’s counsel by telephone at 305-539-3306 or by e-mail at clayton.parker@klgates.com.

    Sincerely,

    /s/ Yimin Wu

    Yimin Wu, Chief Executive Officer and Chairman of the Board of Directors

cc:

Clayton E. Parker, Esq., K&L Gates
LLP

    2

United States securities and exchange commission logo
December 23, 2020
Yimin Wu
Chief Executive Officer
Infobird Co., Ltd
Room 12A05, Block A
Boya International Center, Building 2, No. 1 Courtyard
Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Registration Statement on Form F-1
Filed December 9, 2020
File No. 333-251234
Dear Mr. Wu:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1
Prospectus Summary, page 1
1.Please revise to describe the changes with your relationship with your largest customer,
China Guangfa Bank.  Please clarify in your summary that your services agreement for
customized cloud-based services expired on June 30, 2020 and you have been operating
under an "oral arrangement" since then.  Further, your telecommunication services
agreement with China Guangfa Bank will expire on December 31, 2020.  Please describe
how the oral arrangement differs from your written contractual relationship prior to June
30, 2020 and whether you derive material amounts of revenue from the soon-to-be
expiring telecommunications services agreement with China Guangfa Bank.  Please also

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 December 23, 2020 Page 2
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
December 23, 2020
Page 2
explain how China Guangfa Bank is changing its internal telemarking strategy and how
that affects the services you provide to this customer.
Corporate History and Structure, page 43
2.We note that you have filed your VIE agreements as exhibits related to your VIE entity,
Infobird Beijing.  Please revise to describe the management structure and officers and
directors of Infobird Beijing.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Becky Chow, Staff Accountant, at (202) 551-6524 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-348 if you have questions regarding
comments on the financial statements and related matters. Please contact Edwin Kim, Staff
Attorney, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Clayton E. Parker, Esq.

CORRESP
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October 29, 2020

VIA EDGAR

U.S. Securities
and Exchange Commission

Division
of Corporation Finance

100 F. Street,
N.E.

Washington,
D.C. 20549

    Attn:
    Edwin Kim

    Jan Woo

    Re:
    Infobird Co., Ltd

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

        Submitted September 24, 2020

    CIK No. 0001815566

Ladies and Gentlemen:

Infobird Co., Ltd (the
“Company” or “we”), hereby provides the following information in response to the comments
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
in its letter to the Company dated October 15, 2020 (the “Comment Letter”). The Company’s responses are
preceded by a reproduction of the corresponding Staff comments in bold as set forth in the Comment Letter.

If the Staff would
like hard copies of the Draft Registration Statement on Form F-1 (the “Registration Statement”) as confidentially
submitted to the Commission on the date hereof, marked against the Draft Registration Statement on Form F-1 as confidentially submitted
to the Commission on September 24, 2020, please so advise and we would be happy to provide such copies. All page number references
contained in the Company’s responses below correspond to the page numbers in the Registration Statement. Any capitalized
terms used herein but not defined herein shall have the meanings given to them in the Registration Statement.

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

Prospectus Summary, page 1

    1.
    We note your response to prior comment 1 regarding the basis for your belief that you are a leading SaaS provider in serving large enterprises in the finance industry in customer engagement. To the extent material, please include this information in the filing.

Company Response: The
Company acknowledges the Staff’s comment and has revised the disclosure on page 62 of the Registration Statement accordingly.

Corporate History and Structure,
page 3

    2.
    Please revise your registration statement to include your responses to prior comments 4 and 5 regarding the corporate restructuring and the ownership before and after of each for the 19 shareholders of Infobird Beijing.

Company Response: The
Company acknowledges the Staff’s comment and has revised the disclosure on pages 3 and 42 of the Registration Statement accordingly
to reflect that the sale of securities in March 2020 was in the same proportion as the ownership of Infobird Beijing prior to the
reorganization, and that, to the Company’s knowledge, such investors still currently own their same interests in Infobird
Beijing. In regards to the response to prior comment 5, the VIE agreements will be filed as exhibits to the Registration Statement.

Business, page 57

    3.
    Your response to prior comment 11 indicates that you have 358 customers, consisting of over 10,000 paid users accounts. Please provide more detail regarding your customer base outside of your largest customer China Guangfa Bank. Please clarify the number of paid user accounts outside of China Guangfa Bank and whether your other customers are concentrated in any particular industry, geographic location or size of customer.

Company Response: The
Company acknowledges the Staff’s comment and has revised the disclosure on pages 47, 50, 52, 53, 61 and 67 of the Registration
Statement accordingly to reflect the below information.

The number of average monthly
paid user accounts outside of the Company’s largest customer, China Guangfa Bank, is as follows:

    Number of Average

Monthly Paid User Accounts

    June 30,

 2020

    December 31,

2019
    December 31,

2018

    Standard cloud-based services
      5,121
      4,027
      5,222

    BPO services
      155
      181
      186

    Total
      5,276
      4,208
      5,408

The customer base outside of
China Guangfa Bank is not concentrated in any particular industry, geographic location or size of customer. The breakdown of customers
by business line is as follows as of June 30, 2020:

    Business Line
    Number of Customers

    Customized cloud-based services
    1

    Standard cloud-based services
    330

    BPO services
    15

    Other services
    12

    Total
    358

    4.

        Please refer to prior comment 12 and
        advise us whether you substantially dependent on any of your agreements with China Guangfa Bank, and if so, whether you plan on
        filing such agreements as exhibits pursuant to Item 601(b)(10) of Regulation S-K.

        Company Response: The Company acknowledges
        the Staff’s comment and respectfully submits that it is not currently substantially dependent on written agreements with
        China Guangfa Bank. As disclosed on page 67 of the Registration Statement, the Company is currently operating under oral arrangements
        with China Guangfa Bank regarding customized cloud-based services.

***

If you have any questions
or comments concerning these responses, please do not hesitate to contact me by telephone at 86-010-52411819 or by e-mail at wuym@infobird.com
or the Company’s counsel by telephone at 305-539-3306 or by e-mail at clayton.parker@klgates.com.

    Sincerely,

    /s/ Yimin Wu

    Yimin Wu, Chief Executive Officer and Chairman of the Board of Directors

cc:

Clayton E. Parker, Esq., K&L Gates
LLP

United States securities and exchange commission logo
October 15, 2020
Yimin Wu
Chief Executive Officer
Infobird Co., Ltd
Room 12A05, Block A
Boya International Center, Building 2, No. 1 Courtyard
Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted September 24, 2020
CIK No. 0001815566
Dear Mr. Wu:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.  References to our prior comments refer to our letter dated August 31, 2020.
Amendment No. 1 to Draft Registration on Form F-1
Prospectus Summary, page 1
1.We note your response to prior comment 1 regarding the basis for your belief that you are
a leading SaaS provider in serving large enterprises in the finance industry in customer
engagement.  To the extent material, please include this information in the filing.

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 October 15, 2020 Page 2
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
October 15, 2020
Page 2
Corporate History and Structure, page 3
2.Please revise your registration statement to include your responses to prior comments 4
and 5 regarding the corporate restructuring and the ownership before and after of each for
the 19 shareholders of Infobird Beijing.
Business, page 57
3.Your response to prior comment 11 indicates that you have 358 customers, consisting of
over 10,000 paid users accounts.  Please provide more detail regarding your customer base
outside of your largest customer China Guangfa Bank.  Please clarify the number of paid
user accounts outside of China Guagfa Bank and whether your other customers are
concentrated in any particular industry, geographic location or size of customer.
4.Please refer to prior comment 12 and advise us whether you substantially dependent on
any of your agreements with China Guangfa Bank, and if so, whether you plan on filing
such agreements as exhibits pursuant to Item 601(b)(10) of Regulation S-K.
            You may contact Becky Chow, Staff Accountant, at (202) 551-6524 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-348 if you have questions regarding
comments on the financial statements and related matters.  Please contact Edwin Kim, Staff
Attorney, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Clayton E. Parker, Esq.

CORRESP
1
filename1.htm

September
24, 2020

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

    Attn:
    Edwin
    Kim

    Jan
        Woo

    Re:
    Infobird
    Co., Ltd

    Draft
        Registration Statement on Form F-1

        Submitted
        August 4, 2020

    CIK
    No. 0001815566

Ladies
and Gentlemen:

Infobird
Co., Ltd (the “Company” or “we”), hereby provides the following information in response
to the comments received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
in its letter to the Company dated August 31, 2020 (the “Comment Letter”). The Company’s responses are
preceded by a reproduction of the corresponding Staff comments in bold as set forth in the Comment Letter.

If
the Staff would like hard copies of the Draft Registration Statement on Form F-1 (the “Registration Statement”)
as confidentially submitted to the Commission on the date hereof, marked against the Draft Registration Statement on Form F-1
as confidentially submitted to the Commission on August 4, 2020, please so advise and we would be happy to provide such copies.
All page number references contained in the Company’s responses below correspond to the page numbers in the Registration
Statement. Any capitalized terms used herein but not defined herein shall have the meanings given to them in the Registration
Statement.

Draft
Registration Statement filed August 4, 2020

Prospectus
Summary, page 1

 1. You
                                         describe yourself as one of the leading domestic SaaS providers in serving large enterprises
                                         in the finance industry in customer engagement. Please provide the basis for your belief
                                         that you are a leader and describe the criteria used, such as market share based on revenues.
                                         Further, clarify whether you have significant market share in other industries, such
                                         as education, public services, healthcare and consumer products industries in which you
                                         compete.

Company
Response: It is respectfully submitted that we believe we are one of the leading domestic SaaS providers in serving large
enterprises in the finance industry in customer engagement primarily due to the following reasons:

 ● The
                                         AI SaaS customer engagement industry is newly emerging: There are few specific reports
                                         analyzing this market. To our knowledge, the domestic companies in this industry are
                                         all small- to medium-scaled private enterprises with an estimated average annual revenue
                                         of less than $15 million in 2019, and there is no enterprise that currently dominates
                                         the market. Meanwhile, our revenue in 2019 exceeded $18 million.

    1

 ● Infobird
                                         Beijing is one of the first enterprises to enter the AI SaaS customer engagement industry,
                                         particularly in the finance industry: Our services to China Guangfa Bank date back
                                         to 2011, and we believe this was one of the first cases of a large banking enterprise
                                         adopting SaaS solutions in customer engagement in China. Even though we began small as
                                         a trial service for China Guangfa Bank, we have successfully expanded the average monthly
                                         paid user accounts for China Guangfa Bank over seven thousand for the year ended December
                                         31, 2019. We believe this is a result of the excellent performance of our solutions and
                                         lack of replacement solutions that are capable of supporting high concurrence of accounts
                                         on the cloud. Our experience with China Guangfa Bank is very rewarding because we believe
                                         that we, together with our client, pioneered the market without realizing it at the time.

 ● We
                                         have proven our technological and service capabilities to serve demanding large financial
                                         enterprises in the long-term: Due to our self-developed cloud computing structure,
                                         our products have flexible scale-out capabilities, high tolerance of failures and default,
                                         and support ultra-large-scale concurrence capabilities. We believe this technological
                                         capability exceeds most of the current domestic customer engagement SaaS providers since
                                         most of them use open source to provide services. With open source, they have lower tolerance
                                         of failure, and support a concurrence of approximately 2,000 agents with one set of physical
                                         equipment. Under the same conditions and with the same resources, we could provide high
                                         tolerance of failures and default and can support a large volume of services of concurrence
                                         of over 10,000 agents with a cloud computing structure. Even if such providers added
                                         additional sets of physical equipment to support a concurrence of more agents, we believe
                                         there would still be problems with timely response as well as uneven agent distribution.
                                         In addition, based on feedback from our large financial enterprise clients, we have successfully
                                         met the high stability and service requirements of large financial enterprises.

We
do not have significant market share in other industries, such as education, public services, healthcare and consumer products
industries.

 2. On
                                         page 2 you provide industry market information for the SaaS industry in China as a whole,
                                         the AI industry in China as a whole, and the IT services market for the finance industry.
                                         We note that you describe yourself as a leader in a small subset of these industries,
                                         providing AI, SaaS, and customer service engagement services primarily in the financial
                                         services industry. Please clarify that you only compete in a smaller subset of these
                                         broader categories. Please consider revising to present specific market information for
                                         the subset of industries for which you compete.

Company
Response: It is respectfully submitted that we compete in the sector providing AI, SaaS, and customer engagement solutions,
which is not restrained solely to the financial services industry, but also includes broader industries including the education,
public services, healthcare and consumer products industries. Currently, most of our customers are in the finance industry. As
AI, SaaS, and customer engagement solutions is relatively new to this sector, there exist few industry reports describing the
market information of this specific sector. Therefore, we described the broad industries, including the AI industry, SaaS industry,
and the IT services industry, in the Registration Statement.

    2

 3. In
                                         your summary, please disclose the risk that you are dependent on a major customer, China
                                         Guangfa Bank, which accounted for 77.3% of your 2019 revenues.

Company
Response: The Company acknowledges the Staff’s comment and has revised the disclosure on pages 5 and 10 of the Registration
Statement accordingly.

Corporate
History and Structure, page 3

 4. Please
                                         describe your reorganization with more details as to how the shareholders of Infobird
                                         Beijing, your VIE, received their respective shares in Infobird Cayman, your public holding
                                         company. We note that 19 million ordinary shares of Infobird Cayman were issued to 19
                                         investors in March 2020. Please clarify whether this sale of securities was in the same
                                         proportion as the ownership of Infobird Beijing prior to the reorganization. It is not
                                         clear if these 19 investors still own their same interests in Infobird Beijing or if
                                         they sold them to members of management or your sponsors.

Company
Response: The sale of securities in March 2020 was in the same proportion as the ownership of Infobird Beijing prior to the
reorganization. These investors still own their same interests in Infobird Beijing.

 5. Please
                                         identify the shareholders of Infobird Beijing that are the signatories of the VIE agreements
                                         and current nominal owners of Infobird Beijing. Identify the parties to the spousal consents,
                                         including their respective spouses that are the shareholders of Infobird Beijing. In
                                         addition, describe the management structure of Infobird Beijing and identify its board
                                         members beyond Shengmin Wu.

Company
Response: The shareholders of Infobird Beijing that are the signatories of the VIE agreements and current nominal owners of
Infobird Beijing, as well as their spouses, are as follows (last name, first name):

 1. Shareholder
                                         Name: Wu Yimin

Spouse
Name: Tang Qing

 2. Shareholder
                                         Name: Jiang Dongliang

Spouse
Name: Yan Peng

 3. Shareholder
                                         Name: Weng Bing

Spouse
Name: Wang Xue Meng

 4. Shareholder
                                         Name: Wu Weimin

Spouse
Name: Lyu Ling

 5. Shareholder
                                         Name: Yu Zhuoke

Spouse
Name: Wang Hao

 6. Shareholder
                                         Name: Meng Ji

Spouse
Name: Bin Yu

 7. Shareholder
                                         Name: Li Zhiguo

Spouse
Name: Liu Lei

 8. Shareholder
                                         Name: Li Yujiang

Spouse
Name: Yang Yue Yuan

 9. Shareholder
                                         Name: Lin Nai Zhen

Spouse
Name: Shi Li Zhen

 10. Shareholder
                                         Name: Lin Jun

Spouse
Name: Liu Yin

    3

 11. Shareholder
                                         Name: Hong Hao

Spouse
Name: Guo Xin Xin

 12. Shareholder
                                         Name: Wang Jiang

Spouse
Name: He Su Ru

 13. Shareholder
                                         Name: Wang Rui

Spouse
Name: Guo Ying Ying

 14. Shareholder
                                         Name: Xiao Le Jian

Spouse
Name: Cui He Ying

 15. Shareholder
                                         Name: Miao Man Lin

Spouse
Name: Hai Feng Bin

 16. Shareholder
                                         Name: Guo Jian Feng

Spouse
Name: Qu Lingfan

 17. Shareholder
                                         Name: Yan Lin De

Spouse
Name: Li Yue Yun

 18. Shareholder
                                         Name: Chen Yong Liang

Spouse
Name: Yang Ming Jun

 19. Shareholder
                                         Name: Ju Jing

Spouse
Name: Liang Yang Chun

 20. Shareholder
                                         Name: Qiu Ping Rong

Spouse
Name: N/A

The
senior management structure of Infobird Beijing is as follows (last name, first name):

 1. Wu
                                         Yimin, Chief Executive Officer

 2. Tseng
                                         Hsiaochien, Executive Vice President

 3. Chen
                                         Chunhsiang, Vice President

 4. Zhou
                                         Lianfang, Finance Director

The
board members of Infobird Beijing are as follows (last name, first name):

 1. Wu
                                         Yimin, Chairman of the Board of Directors

 2. Weng
                                         Bing

 3. Jiang
                                         Dongliang

Risk
Factors

Failure
to adhere to regulations that govern our customers’ business…, page 12

 6. You
                                         indicate that you only have a VATS License to offer call center services in Guizhou Province.
                                         Please describe how these restrictions have impacted your operations. It is unclear whether
                                         your physical call center operations are restricted to Guizhou or you are able to service
                                         calls from outside Guizhou. Further, please clarify whether you are currently compliant
                                         with such restrictions, as it appears that you have operations and customers in locations
                                         outside of Guizhou according to your Business section.

Company
Response: As disclosed on page 12 of the Registration Statement, we are currently not compliant with such restrictions. The
VATS License relates to our BPO services delivered mainly through Infobird Guiyang, a subsidiary of Infobird Beijing. Infobird
Guiyang holds a VATS License to offer call center services in the Guizhou Province, while Infobird Beijing holds a VATS License
to offer such services nationwide in China. The reason why we offer BPO services through Infobird Guiyang is that our first and
largest client for BPO services was located in the Guizhou Province. As we grew the BPO services business outside of the Guizhou
Province, we continued to enter into agreements with customers using Infobird Guiyang as a counterparty. We are currently in the
process of switching the counterparty on our relevant existing agreements with customers from Infobird Guiyang to Infobird Beijing
in order to be compliant with such restrictions. We do not believe there will be any material adverse impact on our business.

    4

Key
Factors that Affect Operating Results, page 42

 7. You
                                         disclose that your ability to increase your revenues and your profitability will depend
                                         on your ability to continue to increase your paid user accounts and number of customers.
                                         In addition, you disclosed that you had over 10,000 paid user accounts for SaaS services
                                         and BPO services as of May 30, 2020. Please expand your disclosures to address the following:

 ● Please
                                         clarify whether the number of paid user accounts, average monthly paid user, and customers
                                         are used as your key performance metrics to measure your operating performance.

 ● Please
                                         include a discussion of the trends, expectations and purpose of these metrics as they
                                         relate to your b

United States securities and exchange commission logo
August 31, 2020
Yimin Wu
Chief Executive Officer
Infobird Co., Ltd
Room 12A05, Block A
Boya International Center, Building 2, No. 1 Courtyard
Lize Zhongyi Road
Chaoyang District, Beijing, China 100102
Re:Infobird Co., Ltd
Draft Registration Statement on Form F-1
Submitted August 4, 2020
CIK No. 0001815566
Dear Mr. Wu:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement filed August 4, 2020
Prospectus Summary, page 1
1.You describe yourself as one of the leading domestic SaaS providers in serving large
enterprises in the finance industry in customer engagement.  Please provide the basis for
your belief that you are a leader and describe the criteria used, such as market share based
on revenues.  Further, clarify whether you have significant market share in other
industries, such as education, public services, healthcare and consumer products industries
in which you compete.

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 31, 2020 Page 2
 FirstName LastNameYimin Wu
Infobird Co., Ltd
August 31, 2020
Page 2
2.On page 2 you provide industry market information for the SaaS industry in China as a
whole, the AI industry in China as a whole, and the IT services market for the finance
industry.  We note that you describe yourself as a leader in a small subset of these
industries, providing AI, SaaS, and customer service engagement services primarily in the
financial services industry.  Please clarify that you only compete in a smaller subset of
these broader categories.  Please consider revising to present specific market information
for the subset of industries for which you compete.
3.In your summary, please disclose the risk that you are dependent on a major customer,
China Guangfa Bank, which accounted for 77.3% of your 2019 revenues.
Corporate History and Structure, page 3
4.Please describe your reorganization with more details as to how the shareholders of
Infobird Beijing, your VIE, received their respective shares in Infobird Cayman, your
public holding company.  We note that 19 million ordinary shares of Infobird Cayman
were issued to 19 investors in March 2020.  Please clarify whether this sale of securities
was in the same proportion as the ownership of Infobird Beijing prior to the
reorganization.  It is not clear if these 19 investors still own their same interests in Infobird
Beijing or if they sold them to members of management or your sponsors.
5.Please identify the shareholders of Infobird Beijing that are the signatories of the VIE
agreements and current nominal owners of Infobird Beijing.  Identify the parties to the
spousal consents, including their respective spouses that are the shareholders of Infobird
Beijing.  In addition, describe the management structure of Infobird Beijing and identify
its board members beyond Shengmin Wu.
Risk Factors
Failure to adhere to regulations that govern our customers’ business…, page 12
6.You indicate that you only have a VATS License to offer call center services in Guizhou
Province.  Please describe how these restrictions have impacted your operations.  It is
unclear whether your physical call center operations are restricted to Guizhou or you are
able to service calls from outside Guizhou.  Further, please clarify whether you are
currently compliant with such restrictions, as it appears that you have operations and
customers in locations outside of Guizhou according to your Business section.
Key Factors that Affect Operating Results, page 42
7.You disclose that your ability to increase your revenues and your profitability will depend
on your ability to continue to increase your paid user accounts and number of customers.
 In addition, you disclosed that you had over 10,000 paid user accounts for SaaS services
and BPO services as of May 30, 2020.  Please expand your disclosures to address the
following:
•Please clarify whether the number of paid user accounts, average monthly paid user,
and customers are used as your key performance metrics to measure your operating

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 31, 2020 Page 3
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
August 31, 2020
Page 3
performance.
•Please include a discussion of the trends, expectations and purpose of these metrics as
they relate to your business operations and performance.
In addition, please revise to disclose number of paid user accounts and average monthly
paid user that are attributable to your significant customer, China Guangfa Bank, for each
period presented.  Your disclosure should highlight the significance and dependence on
this customer.
Management’s discussion and analysis of financial condition and results of operations
Overview, page 42
8.We note you state: “[w]e have grown rapidly since our inception.  We generate revenues
primarily from providing standard and customized cloud-based SaaS and BPO services.
For the years ended December 31, 2019 and 2018, total revenues were approximately
$18.2 and $18.8 million, respectively.  Our gross profit and net income were $10.3 million
and $5.1 million, respectively, for the year ended December 31, 2019 as compared to our
gross profit and net income of $9.5 million and $2.4 million, respectively, for the year
ended December 31, 2018.”  It appears your 2019 revenue decreased about 3% compared
to 2018 revenue.  Please revise your disclosures to support your statement that you have
grown rapidly since your inception.  Further, explain why the increase in average monthly
paid users of 15.7% did not have a corresponding impact on your revenue even after
factoring in the impact of changes in your currency.  Indicate whether the average paid
users number should be stratified by revenue or fee type to explain this disparity.
Liquidity and Capital Resources, page 46
9.Please disclose the minimum funding required remaining in business for at least the next
12 months.  Please refer to Item 303(a) (1) and (2) of Regulation S-K as well as FRC
501.03.a and Section IV of Interpretive Release No. 33-8350 for additional guidance.  In
addition, please describe the importance of your significant customer, China Guangfa
Bank, on your liquidity and the potential impact of the loss of this customer.
Business, page 51
10.We note that three vendors accounted for over 40% of your total purchases for 2019.
Please describe the purchases and how these entities relate to the infrastructure of your
platform. Identify the vendors, to the extent material, and disclose the material terms of
your agreements with these vendors.

11.You disclose that you had 10,000 paid user accounts for SaaS services and BPO services
as of May 31, 2020.  To the extent material, please also disclose the total number of
customers and the nature of those customers to provide additional context.

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 31, 2020 Page 4
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
August 31, 2020
Page 4
12.Please disclose the material terms of your agreement with your largest customer, China
Guangfa Bank, including the term and termination provisions.  File the agreement as an
exhibit.  See Item 601(b)(10) of Regulation S-K.
Management, page 73
13.We note that your management and principal shareholders may have a controlling interest
in Infobird Cayman after the IPO.  Please clarify you may be eligible for the close
company exemptions under Nasdaq rules.
14.Under Cayman Islands law, it appears that you are not required to have an annual
meeting.  Please clarify whether you will have annual director elections.
Capitalized development costs, page F-10
15.Please expand your disclosures to clarify whether amortization of internal-use software
should begin when the software is ready for its intended use.  Please refer to ASC 350-40-
35-6.
Revenue recognition, page F-11
16.We note your disclosure of your revenue recognition policies for each type of revenue
streams.  Please expand your disclosure to provide the contract terms of these contracts
with customers, including the duration of these contracts with customers.
Variable interest entity (“VIE”), page F-15
17.We note from your disclosure in Note 3 of your consolidated financial statements that you
have determined Infobird Beijing to be variable interests entities (“VIEs”) through the
Contractual Arrangements with Infobird Beijing, which you consolidate as a result of
being the primary beneficiary.  Please tell us your consideration for presenting the assets
and liabilities of the consolidated VIEs separately on the face of the consolidated balance
sheets in accordance with ASC 810-10-45-25.
Recent Sales of Unregistered Securities, page II-1
18.Please provide a description of the sales of shares of Infobird Beijing for the past three
fiscal years, pursuant to Item 701 of Regulation S-K.  We note that your disclosure is
limited to the shares issued at the creation of your public holding company Infobird
Cayman that was newly created as part of your reorganization.  Please include the sales of
your predecessor entity.

 FirstName LastNameYimin Wu
 Comapany NameInfobird Co., Ltd
 August 31, 2020 Page 5
 FirstName LastName
Yimin Wu
Infobird Co., Ltd
August 31, 2020
Page 5
General
19.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            You may contact  Becky Chow, Staff Accountant, at (202) 551-6524 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-348 if you have questions regarding
comments on the financial statements and related matters.  Please contact Edwin Kim, Staff
Attorney, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Clayton E. Parker, Esq.