SecProbe.io

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 Jin Medical International Ltd.

 No. 33 Lingxiang Road, Wujin District

 Changzhou City, Jiangsu Province

 People's Republic of China

 September 5, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporate Finance

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Ms. Jane Park

 Re:

 Jin Medical International Ltd.
 Registration Statement on Form F-3
 File No. 333-288314

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the
General Rules and Regulations promulgated under the Securities Act of 1933, as amended, Jin Medical International Ltd. hereby requests
the United States Securities and Exchange Commission take appropriate action to cause the above-referenced Registration Statement on Form
F-3 to become effective on September 9, 2025, at 9:00 a.m. Eastern Time, or as soon thereafter as practicable.

 Please feel free to direct
any questions or comments concerning this request to our U.S. legal counsel, Ms. Huan Lou of McCarter & English, LLP by telephone
at +1 (212)-609-6921 or via e-mail at hlou@mccarter.com .

 Very truly yours,

 For and on behalf of
 Jin Medical International Ltd.

 /s/ Erqi Wang

 Name:
 Erqi Wang

 Title:
 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 1, 2025

Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People s Republic of China

 Re: Jin Medical International Ltd.
 Registration Statement on Form F-3
 Filed June 25, 2025
 File No. 333-288314
Dear Erqi Wang:

 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 Jane Park at 202-551-7439 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Evelyn Li, Esq.
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 25, 2025

Ziqiang Wang
Chief Financial Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People s Republic of China

 Re: Jin Medical International Ltd.
 Form 20-F for Fiscal Year Ended September 30, 2024
 Filed January 24, 2025
 File No. 001-41661
Dear Ziqiang Wang:

 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 Industrial
Applications and
 Services
</TEXT>
</DOCUMENT>

CORRESP
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 Jin Medical International Ltd.

 No. 33 Lingxiang Road, Wujin District

 Changzhou City, Jiangsu Province

 People's Republic of China

 March 20, 2025

 Securities and Exchange Commission

 Division of Corporate Finance

 Office of Industrial Applications and Services

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Julie Sherman and Kristin Lochhead

 Re:
 Jin Medical International Ltd.

 Form 20-F for Fiscal Year Ended September 30, 2024

 Filed January 24, 2025

 File No. 001-41661

 Dear Ms. Julie Sherman and Ms. Kristin Lochhead

 Please find below our responses
to the questions raised by the staff (the "Staff") of the Securities and Exchange Commission (the "Commission")
in its letter of comments dated March 6, 2025 (the "Comment Letter") relating to the annual report on Form 20-F for Fiscal
Year Ended September 30, 2024, which was filed with the Commission by Jin Medical International Ltd. (the "Company" or "we")
on January 24, 2025 (the " Annual Report"). The Company is concurrently filing an amendment to the Annual Report herewith
(the "Amendment").

 For the Staff's convenience,
the Staff's comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company.
Except for any page references appearing in the headings or the Staff's comments (which are references to Annual Report), all page
references herein correspond to the pages of the Amendment. Capitalized terms used but not defined in this letter have the meanings ascribed
to such terms in the Amendment and the Annual Report.

 Form 20-F for Fiscal Year Ended September 30,
2024

 Item 5. Operating and Financial Review and
Prospects

 A. Operating Results, Comparison of Results
of Operations for the Fiscal Years Ended

 September 30, 2024 and 2023, page 87

 1.
 We see that revenue from wheelchair products decreased 9% from FY24 to FY23 while revenue from wheelchair components increased 149%. We also note from page 55 and 61 that the percentage of revenue derived from Nissin, the sole distributor in Japan, decreased from 70% of revenue in FY23 to 48% in FY24. Revise future filings to provide greater clarity about the underlying reasons for the fluctuations in revenue from period to period, including how changes in the geographic distribution of revenue and sales to major customers impacted revenue and whether that trend is expected to continue in the future. In addition, when you include multiple reasons for fluctuations, such as for wheelchair product revenue, future filings should quantify the impact of each item.

 Response: We have noted the Commission's
comments and will revise future filings to provide the specified information.

 B. Liquidity and Capital Resources, page 96

 2.

 We note significant changes in your liquidity
 and capital resources such as increases in cash, short-term investments and accounts receivable along with increases in bank loans. However,
 we do not see any discussion about the underlying reasons for these trends. Revise future filings to include more robust discussion about
 any known trends or any known demands, commitments, events or uncertainties that will result in or that are reasonably likely to result
 in the registrant's liquidity increasing or decreasing in any material way. In addition, future filing should more fully describe any
 known material trends, favorable or unfavorable, in the registrant's capital resources. Reference Item 303(b)(1) of Regulation S-K.

 Response: We have noted the Commission's
comments and will revise future filings to provide the specified information.

 Item 15. Controls and Procedures

 Managements Annual Report on Internal Control
over Financial Reporting, page 137

 3.

 You disclose that you have identified a significant
 weakness in your internal control over financial reporting; however it does not appear that you have included management's report of internal
 control over financial reporting that complies with Item 308 of Regulation S-K. Please amend your filing to disclose management's
 report on the effectiveness of your internal controls over financial reporting, including an explicit statement as to whether or not internal
 control over financial reporting is effective. Refer to the requirements of Item 308(a) of Regulation S-K. You may provide an abbreviated
 amendment that includes a cover page, explanatory note, the complete text of Item 15, a signature page and the certification required
 by Item 601(b)(31) of Regulation S-K, including paragraphs 1,2,4 and 5. Please ensure the revised certifications refer to the appropriate
 amendment and are currently dated.

 Please also revise to remove the disclosure
 that the Annual Report does not include a report of management's assessment regarding internal control over financial reporting
 due to a transition period established by rules of the SEC for newly listed public companies. Since this is your second Form 20-F, the
 transition period is no longer applicable to you.

 Response: Please refer to the revised disclosures
at Item 15 of the Amendment.

 Consolidated Statement of Comprehensive Income, page F-5

 4.
 Please tell us why you do not disclose the cost of related party revenue on the face of your consolidated statement of comprehensive income in compliance with Rule 4-08(k) of Regulation S-X.

 Response: The Company respectfully submits that
it will disclose the cost of related party revenue on the face of our consolidated statements of comprehensive income in compliance with
Rule 4-08(k) of Regulation S-X in future filings.

 Should you have any questions
regarding the foregoing, please do not hesitate to contact the Company's counsel, Huan Lou, Esq. of Sichenzia Ross Ference Carmel
LLP at (646) 810-2187.

 Very truly yours,
 For and on behalf of
 Jin Medical International Ltd.

 By:
 /s/ Erqi Wang

 Name:
 Erqi Wang

 Title:
 Chief Executive Officer

March 6, 2025
Ziqiang Wang
Chief Financial Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
20-F for Fiscal Year Ended September 30, 2024
Filed January 24, 2025
File No. 001-41661
Dear Ziqiang Wang:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended September 30, 2024
Item 5. Operating and Financial Review and Prospects
A. Operating Results, Comparison of Results of Operations for the Fiscal Years Ended
September 30, 2024 and 2023, page 87
1.We see that revenue from wheelchair products decreased 9% from FY24 to FY23
while revenue from wheelchair components increased 149%. We also note from page
55 and 61 that the percentage of revenue derived from Nissin, the sole distributor in
Japan, decreased from 70% of revenue in FY23 to 48% in FY24. Revise future filings
to provide greater clarity about the underlying reasons for the fluctuations in revenue
from period to period, including how changes in the geographic distribution of
revenue and sales to major customers impacted revenue and whether that trend is
expected to continue in the future. In addition, when you include multiple reasons for
fluctuations, such as for wheelchair product revenue, future filings should quantify the
impact of each item.

March 6, 2025
Page 2
B. Liquidity and Capital Resources, page 96
2.We note significant changes in your liquidity and capital resources such as
increases in cash, short-term investments and accounts receivable along with increases
in bank loans. However, we do not see any discussion about the underlying reasons
for these trends. Revise future filings to include more robust discussion about any
known trends or any known demands, commitments, events or uncertainties that will
result in or that are reasonably likely to result in the registrant's liquidity increasing or
decreasing in any material way. In addition, future filing should more fully describe
any known material trends, favorable or unfavorable, in the registrant's capital
resources. Reference Item 303(b)(1) of Regulation S-K.

Item 15. Controls and Procedures
Managements Annual Report on Internal Control over Financial Reporting, page 137
3.You disclose that you have identified a significant weakness in your internal control
over financial reporting; however it does not appear that you have included
management's report of internal control over financial reporting that complies with
Item 308 of Regulation S-K. Please amend your filing to disclose management’s
report on the effectiveness of your internal controls over financial reporting, including
an explicit statement as to whether or not internal control over financial reporting is
effective. Refer to the requirements of Item 308(a) of Regulation S-K. You may
provide an abbreviated amendment that includes a cover page, explanatory note, the
complete text of Item 15, a signature page and the certification required by Item
601(b)(31) of Regulation S-K, including paragraphs 1,2,4 and 5. Please ensure the
revised certifications refer to the appropriate amendment and are currently dated.

Please also revise to remove the disclosure that the Annual Report does not include a
report of management’s assessment regarding internal control over financial reporting
due to a transition period established by rules of the SEC for newly listed public
companies. Since this is your second Form 20-F, the transition period is no longer
applicable to you.

Consolidated Statement of Comprehensive Income, page F-5
4.Please tell us why you do not disclose the cost of related party revenue on the face of
your consolidated statement of comprehensive income in compliance with Rule 4-
08(k) of Regulation S-X.

March 6, 2025
Page 3
            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.
            Please contact Julie Sherman at 202-551-3640 or Kristin Lochhead at 202-551-3664
with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

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JIN MEDICAL INTERNATIONAL LTD.

No. 33 Lingxiang Road, Wujin District

Changzhou City, Jiangsu Province

People’s Republic of China

VIA EDGAR

March 23, 2023

Ms. Jane Park

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F. Street, N.E.

Washington, D.C. 20549

    Re:
    JIN MEDICAL INTERNATIONAL LTD.

    Registration Statement on Form F-1, as amended

    File No. 333-259767

Dear Ms. Park:

In accordance with Rule 461
of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended,
JIN MEDICAL INTERNATIONAL LTD. hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it
will become effective at 5:00 pm, Eastern Time, on March 27, 2023, or as soon thereafter as practicable.

    Very truly yours,

    JIN MEDICAL INTERNATIONAL LTD.

    By:
    /s/ Erqi Wang

    Name:
    Erqi Wang

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

cc. Ying Li, Esq., Hunter Taubman Fischer &
Li LLC

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March 23, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

    RE:
    Jin Medical International Ltd. (CIK: 0001837821)

    Registration Statement No. 333-259767 on Form F-1 (the “Registration Statement”)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”),
Prime Number Capital, LLC hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective at 5:00 p.m. Eastern Time, March 27, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act,
please be advised that we will distribute as many electronic copies of the proposed form of preliminary prospectus as appears to be reasonable
to secure adequate distribution.

    By:
    Prime Number Capital, LLC

    By:
    /s/ Xiaoyan Jiang

    Name:
    Xiaoyan Jiang

    Title:
    Chairwoman

CORRESP
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March 7, 2023

Via Edgar

Ms. Jane Park

Division of Corporation Finance

Office of Industrial Applications and Services

U.S. Securities and Exchange Commission

    Re:
    Jin Medical International Ltd.

    Amendment No. 11 to Registration Statement on Form F-1

    Filed February 24, 2023

    File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter dated
March 2, 2023, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference,
we have recited the Commission’s comment in this response. An amendment to the registration statement on Form F-1 (the “Amendment”)
is being filed to accompany this letter.

Amendment No. 11 to Form F-1 filed February
24, 2023

Exhibits

 1. We
refer to your filing fee table filed as Exhibit 107 to your registration statement. Please revise your filing fee table to include separate
entries for the Underwriters' Warrants and the ordinary shares underlying such warrants.

Response: The Company acknowledges the
Staff’s comment and revised the filing fee table, which is being refiled as exhibit 107 to the Amendment.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
March 2, 2023
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 11 to Registration Statement on Form F-1
Filed February 24, 2023
File No. 333-259767
Dear Erqi Wang:
            We have reviewed your amended 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.
Amendment No. 11 to Form F-1 filed February 24, 2023
Exhibits
1.We refer to your filing tee table filed as Exhibit 107 to your registration statement.  Please
revise your filing fee table to include separate entries for the Underwriters' Warrants and
the ordinary shares underlying such warrants.
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 March 2, 2023 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
March 2, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Ying Li, Esq.

CORRESP
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December 1, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

    Re:
    Jin Medical International Ltd.

    Amendment No. 8 to Registration Statement on Form F-1

    Filed November 17, 2022

    File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter dated
November 21, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference, we have
recited the Commission’s comments in this response. An amendment to the registration statement on Form F-1 (the “Amendment”)
is being filed to accompany this letter.

Amendment No. 8 to Form F-1 filed November
17, 2022

Exhibits

    1.
    We note your disclosure on the cover page that your offering is contingent upon final approval of your Nasdaq listing.  Please ensure the disclosure is consistent with your underwriting agreement.

Response: The Company acknowledges the
Staff’s comment and revised the underwriting agreement, which is being refiled as exhibit 1.1 to the Amendment, to ensure that the
disclosure is consistent with the underwriting agreement.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
November 21, 2022
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 8 to Registration Statement on Form F-1
Filed November 17, 2022
File No. 333-259767
Dear Erqi Wang:
            We have reviewed your amended 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.
Amendment No. 8 to Form F-1 filed November 17, 2022
Exhibits
1.We note your disclosure on the cover page that your offering is contingent upon final
approval of your Nasdaq listing.  Please ensure the disclosure is consistent with your
underwriting agreement.
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 November 21, 2022 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
November 21, 2022
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Ying Li, Esq.

CORRESP
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September 13, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

    Re:
    Jin Medical International Ltd.

    Amendment No. 6 to Registration Statement on Form F-1

    Filed August 31, 2022

    File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter dated
September 8, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference, we have
recited the Commission’s comments in this response. An amendment to the registration statement on Form F-1 (the “Amendment”)
is being filed to accompany this letter.

Amendment No. 6 to Form F-1 filed August 31,
2022

Agreements with Named Executive Officers, page
121

 1. We
note your disclosure on page 121 that you have entered into employment agreements with your executive officers. We also note your deletion
of certain disclosure relating to the employment agreements with your CEO and CFO. Please revise to include a summary of the material
terms of the employment agreements between the company and both Erqui Wang and Ziqiang Wang and please file the actual agreements rather
than the form of agreements. Refer to Item 601(b)(10) of Regulation S-K.

Response: The Company acknowledges the
Staff’s comment and revised the disclosure on page 121 to include a summary of the material terms of the employment agreements between
the company and both Erqui Wang and Ziqiang Wang, and filed the actual agreements as exhibits to the registration agreement.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
September 8, 2022
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 6 to Registration Statement on Form F-1
Filed August 31, 2022
File No. 333-259767
Dear Mr. Wang:
            We have reviewed your amended 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.
Amendment No. 6 to Form F-1 filed August 31, 2022
Agreements with Named Executive Officers, page 121
1.We note your disclosure on page 121 that you have entered into employment agreements
with your executive officers.  We also note your deletion of certain disclosure relating to
the employment agreements with your CEO and CFO.  Please revise to include a
summary of the material terms of the employment agreements between the company and
both Erqui Wang and Ziqiang Wang and please file the actual agreements rather than the
form of agreements.  Refer to Item 601(b)(10) of Regulation S-K.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 September 8, 2022 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
September 8, 2022
Page 2
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li, Esq.

CORRESP
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August 31, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

    Re:
    Jin Medical International Ltd.

    Amendment No. 5 to Registration Statement on Form F-1

    Filed August 10, 2022

    File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter dated
August 19, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference, we have
recited the Commission’s comments in this response. An amendment to the registration statement on Form F-1 (the “Amendment”)
is being filed to accompany this letter.

Amendment No. 5 to Form F-1 filed August 10, 2022

General

 1. We
note your response to prior comment 1 and reissue in part. Any references to control or economic benefits that accrued to you because
of the VIE should be limited to and clearly describe the conditions you met for consolidation of the VIE under U.S. GAAP and your disclosure
should clarify that, for accounting purposes, you were the primary beneficiary. For example only, we note that your disclosure on pages
F-8 and F-39 do not clarify that the control or economic benefits you receive from the VIE are “for accounting purposes” only.

Response: The Company acknowledges the
Staff’s comment and revised its disclosures to ensure that all references to control or benefits that accrue because of the VIE
are limited to a clear description of the conditions that have been satisfied for consolidation of the VIE under U.S. GAAP, and that the
Company was the primary beneficiary for accounting purpose.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
August 19, 2022
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 5 to Registration Statement on Form F-1
Filed August 10, 2022
File No. 333-259767
Dear Mr. Wang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our July 26, 2022 letter.
Amendment No. 5 to Form S-1 filed August 10, 2022
General
1.We note your response to prior comment 1 and reissue in part.  Any references to control
or economic benefits that accrued to you because of the VIE should be limited to and
clearly describe the conditions you met for consolidation of the VIE under U.S. GAAP
and your disclosure should clarify that, for accounting purposes, you were the primary
beneficiary.  For example only, we note that your disclosure on pages F-8 and F-39 do not
clarify that the control or economic benefits you receive from the VIE are "for accounting
purposes" only.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 August 19, 2022 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
August 19, 2022
Page 2
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li, Esq.

CORRESP
1
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August 10, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

    Re:
    Jin Medical International Ltd.

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

    Filed July 15, 2022

     File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter
dated July 26, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amendment to the registration statement
on Form F-1 (the “Amendment”) is being filed to accompany this letter.

Amendment No. 4 to Form F-1 filed July 15, 2022

Cover Page

1. We acknowledge your revised disclosure in response to prior comment 2, which we reissue. Please revise
to ensure that all references to control or benefits that accrue to you because of the VIE are limited to a clear description of the conditions
you have satisfied for consolidation of the VIE under U.S. GAAP. We note that your disclosure continues to refer to the control or benefits
that accrue to you as a result of the VIE, including but not limited to the cover page, pages ii, 1, 2, 86, 87 and 124.

Response:
The Company acknowledges the Staff’s comment and revised its disclosures to ensure that all references to control or benefits that
accrue because of the VIE are limited to a clear description of the conditions have been satisfied for consolidation of the VIE under
U.S. GAAP.

Summary of
Risk Factors, page 10

2. We note your revised disclosure in response to prior comment 6, which we reissue in part. Please revise
to include specific cross-references for each summary risk to the more detailed discussion of such risks in the prospectus rather than
including page references.

Response:
The Company acknowledges the Staff’s comment and revised “Summary of Risk Factors” to include specific cross-references
for each summary risk to the more detailed discussion of such risks in the prospectus rather than including page references.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
July 26, 2022
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 4 to Registration Statement on Form F-1
Filed July 15, 2022
File No. 333-259767
Dear Mr. Wang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our April 28, 2022 letter.
Amendment No. 4 to Registration Statement on Form F-1 filed July 15, 2022
Cover Page
1.We acknowledge your revised disclosure in response to prior comment 2, which we
reissue.  Please revise to ensure that all references to control or benefits that accrue to you
because of the VIE are limited to a clear description of the conditions you have satisfied
for consolidation of the VIE under U.S. GAAP.  We note that your disclosure continues to
refer to the control or benefits that accrue to you as a result of the VIE, including but not
limited to the cover page, pages ii, 1, 2, 86, 87 and 124.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 July 26, 2022 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
July 26, 2022
Page 2
Summary of Risk Factors, page 10
2.We note your revised disclosure in response to prior comment 6, which we reissue in
part.  Please revise to include specific cross-references for each summary risk to the more
detailed discussion of such risks in the prospectus rather than including page references.
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li, Esq.

CORRESP
1
filename1.htm

July 15, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

 Re: Jin Medical International Ltd.

Amendment No. 3 to Registration
Statement on Form F-1

Filed April 1, 2022

File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter
dated April 28, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amendment to the registration statement
on Form F-1 (the “Amendment”) is being filed to accompany this letter.

Amendment No. 3 to Form F-1 filed April 1, 2022

Cover Page

1. We note the references on the cover page and on page 31 that the PRC State Internet Information
                                        Office issued the Measures of Cybersecurity Review on July 10, 2021. In light of the final version of the Cyberspace Administration
                                        of China’s (CAC) Measures of Cyber Security Review that became effective on February 15, 2022, please revise your disclosure
                                        to explain how this oversight impacts your business and your offering and to what extent you believe that you are compliant with the
                                        regulations or policies that have been issued by the CAC to date.

Response:
The Company acknowledges the Staff’s comment and revised its disclosure on the cover page to explain how this oversight impacts
the Company’s business and offering and that the Company believes that it is compliant with the regulations and policies that have
been issued by the CAC as of the date of the prospectus.

2. 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. We refer to your
disclosure that you control and receive economic benefits of the VIE’s business operations throughout the prospectus, including
on pages ii, 2, 85 and 124. Please revise accordingly.

Response:
The Company acknowledges the Staff’s comment and updated references to control or benefits that accrue to the Company because of
the VIE to be limited to a clear description of the conditions the Company satisfies for consolidation of the VIE under U.S. GAAP, including
on pages ii, 2, 86 and 124 of this Amendment.

Prospectus Summary

Dividends and Distributions, page 3

3. Please revise your disclosure in the Summary to quantify any cash flows and transfers
of other assets by type that have occurred between the holding company, its subsidiaries and the consolidated VIE, and direction of transfer.
Your disclosure should make clear if no transfers have been made to date. Please expand your disclosure to discuss your cash management
policies, if any. In your summary of risk factors, please also disclose the risks that restrictions on foreign exchange, your ability
to transfer cash between entities, across borders, and to U.S. investors and your ability to distribute earnings from the company pose
to investors and the operation of your business.

Response:
The Company acknowledges the Staff’s comment and revise its disclosure in the Summary to indicate that no cash flows or transfers
of other assets have occurred between the holding company, its subsidiaries and the consolidated VIE, and that the Company does not have
any cash management policies. The Company also added a risk factor in the summary of risk factors and risk factors section on page 35
of the Amendment to disclose the risks that restrictions on foreign exchange, the Company’s ability to transfer cash between entities,
across borders, and to U.S. investors and its ability to distribute earnings pose to investors and the operation of the Company’s
business.

Prospectus
Summary

Permissions
from the PRC Authorities to Issue Our Ordinary Shares to Foreign Investors, page 3

4. We note your disclosure on pages 3 and 31 that as advised by your PRC counsel,
you, your PRC subsidiaries and the VIE are not subject to permission requirements from the Chinese Securities Regulatory Commission (the
“CSRC”) and the Cyberspace Administration of China (the “CAC”) to approve of the VIE’s operations. Please
identify outside PRC counsel and file a consent. Alternatively, remove the references and explain the basis for your belief that you are
not subject to the review or required to obtain prior approval of the CSRC and CAC. Please also describe all consequences to you and your
investors if you, your subsidiaries, or the VIE inadvertently conclude that such permissions or approvals are not required.

Response: The Company
acknowledges the Staff’s comment and revised the disclosure on the cover page and pages 3 and 4 of the Amendment to identify
its outside PRC counsel, Beijing Dacheng Law Office, LLP (Shanghai), which has already filed a consent as exhibit 23.3 to the
Company’s registration statement. The Company also revised the disclosure on page 4 of the Amendment to describe all
consequences to itself and its investors if the Company, its subsidiaries, or the VIE inadvertently conclude that such permissions
or approvals are not required.

    2

Selected Condensed Consolidated Financial
Schedule of Jin Med and Its Subsidiaries and VIE, page 6

5. We note from your responses to prior comments 2 and 3 that you updated the selected
condensed consolidated statements of operations on page 6 of the Amendment to separately present the WFOE from your other subsidiaries.
We further note that you have (i) updated the WFOE column to include service fee income from consulting services pursuant to the Exclusive
Business Cooperation and Service Agreement, (ii) updated the selected condensed consolidated balance sheet on page 7 of the Amendment
to provide a more comprehensive presentation of the consolidating assets and liabilities on a gross basis, and (iii) updated the selected
condensed consolidated cash flows on page 8 of the Amendment to present the cash flows of the WFOE and the other subsidiaries separately.
Please further revise these statements to remove the “Benefits from VIE and VIE’s subsidiaries”, “Accumulated
benefits through VIE and VIE’s subsidiaries”, and corresponding eliminations, as well as the ensuing effects on the condensed
financial statements of Jin Medical International Ltd. for periods that pre-date the November 26, 2020 VIE Agreements. In this regard,
amounts included in the Jin Med (Cayman Islands), Subsidiary (Hong Kong), and WFOE (PRC) columns prior to November 26, 2020 should be
zero or N/A. Also, revise the introductory paragraph to clarify when the VIE Agreements were entered into and why the historical amounts
prior to the November 26, 2020 are reflected in the VIE only column. Please address this comment as it relates to your condensed financial
information of the parent company as presented in Note 16 beginning on page F-33.

Response:
The Company acknowledges the Staff’s comment and revised the “PROSPECTUS SUMMARY - Selected Condensed Consolidated Financial
Schedule of Jin Med and Its Subsidiaries and VIE” on page 7 of the Amendment to remove the “Benefits from VIE and VIE’s
subsidiaries”, “Accumulated benefits through VIE and VIE’s subsidiaries”, and corresponding elimination for periods
that occurred prior to November 26, 2020, the date of the VIE Agreements. We have also revised the introductory paragraph to clarify when
the VIE Agreements were entered into and why the historical amounts prior to November 26, 2020 are reflected in the VIE only column. We
have further revised the condensed financial information of the parent company as presented in Note 16 beginning on page F-63 to be in
conformity with the presentation of the “PROSPECTUS SUMMARY - Selected Condensed Consolidated Financial Schedule of Jin Med and
Its Subsidiaries and VIE” and to reflect the fact that the VIE Agreements were effective since November 26, 2020.

    3

Summary of Risk Factors, page 9

6. We refer to your disclosure of 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, please revise to include specific
cross-references for each summary risk to the more detailed discussion of such risks in the prospectus. Please also specifically discuss
the 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. Revise your summary risk factor relating to the risk that the Chinese
government may intervene or influence your operations at any time to clarify that the Chinese government may also exert more control over
offerings conducted overseas and/or foreign investment in China-based issuers. Acknowledge any risks that any actions by the Chinese government
to exert more oversight and control over offerings that are conducted overseas and/or foreign investment in China-based issuers could
significantly limit or completely hinder your ability to offer or continue to offer securities to investors and cause the value of such
securities to significantly decline or be worthless.

Response:
The Company acknowledges the Staff’s comment and revised the disclosure to include specific cross-references for each summary risk
to the more detailed discussion of the risks relating to its corporate structure and being based in or having the majority of the company's
operations in China poses to investors in the prospectus. The Company also revised the disclosures in the Risk Factors section to specifically
discuss the 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 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.

    4

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

5

United States securities and exchange commission logo
April 28, 2022
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 3 to
Registration Statement on Form F-1
Filed April 1, 2022
File No. 333-259767
Dear Mr. Wang:
            We have reviewed your amended 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.
Amendment No. 3 to Form F-1 filed April 1, 2022
Cover Page
1.We note the references on the cover page and on page 31 that the PRC State Internet
Information Office issued the Measures of Cybersecurity Review on July 10, 2021.  In
light of the final version of the Cyberspace Administration of China’s (CAC) Measures of
Cyber Security Review that became effective on February 15, 2022, please revise your
disclosure to explain how this oversight impacts your business and your offering and to
what extent you believe that you are compliant with the regulations or policies that have
been issued by the CAC to date.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 April 28, 2022 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
April 28, 2022
Page 2
2.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.  We refer to your disclosure that you control and receive
economic benefits of the VIE’s business operations throughout the prospectus, including
on pages ii, 2, 85 and 124.  Please revise accordingly.
Prospectus Summary
Dividends and Distributions, page 3
3.Please revise your disclosure in the Summary to quantify any cash flows and transfers of
other assets by type that have occurred between the holding company, its subsidiaries and
the consolidated VIE, and direction of transfer.  Your disclosure should make clear if no
transfers have been made to date.  Please expand your disclosure to discuss your cash
management policies, if any.  In your summary of risk factors, please also disclose the
risks that restrictions on foreign exchange, your ability to transfer cash between entities,
across borders, and to U.S. investors and your ability to distribute earnings from the
company pose to investors and the operation of your business.
Prospectus Summary
Permissions from the PRC Authorities to Issue Our Ordinary Shares to Foreign Investors, page 3
4.We note your disclosure on pages 3 and 31 that as advised by your PRC counsel, you,
your PRC subsidiaries and the VIE are not subject to permission requirements from the
Chinese Securities Regulatory Commission (the “CSRC”) and the Cyberspace
Administration of China (the “CAC”) to approve of the VIE’s operations.  Please identify
outside PRC counsel and file a consent.  Alternatively, remove the references and explain
the basis for your belief that you are not subject to the review or required to obtain prior
approval of the CSRC and CAC.  Please also describe all consequences to you and your
investors if you, your subsidiaries, or the VIE inadvertently conclude that such
permissions or approvals are not required.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 April 28, 2022 Page 3
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
April 28, 2022
Page 3
Selected Condensed Consolidated Financial Schedule of Jin Med and Its Subsidiaries and VIE,
page 6
5.We note from your responses to prior comments 2 and 3 that you updated the selected
condensed consolidated statements of operations on page 6 of the Amendment to
separately present the WFOE from your other subsidiaries. We further note that you have
(i) updated the WFOE column to include service fee income from consulting services
pursuant to the Exclusive Business Cooperation and Service Agreement, (ii) updated the
selected condensed consolidated balance sheet on page 7 of the Amendment to provide a
more comprehensive presentation of the consolidating assets and liabilities on a gross
basis, and (iii) updated the selected condensed consolidated cash flows on page 8 of the
Amendment to present the cash flows of the WFOE and the other subsidiaries separately.
Please further revise these statements to remove the “Benefits from VIE and VIE’s
subsidiaries”, “Accumulated benefits through VIE and VIE’s subsidiaries”, and
corresponding eliminations, as well as the ensuing effects on the condensed financial
statements of Jin Medical International Ltd. for periods that pre-date the November 26,
2020 VIE Agreements. In this regard, amounts included in the Jin Med (Cayman Islands),
Subsidiary (Hong Kong), and WFOE (PRC) columns prior to November 26, 2020 should
be zero or N/A. Also, revise the introductory paragraph to clarify when the VIE
Agreements were entered into and why the historical amounts prior to the November 26,
2020 are reflected in the VIE only column.  Please address this comment as it relates to
your condensed financial information of the parent company as presented in Note 16
beginning on page F-33.
Summary of Risk Factors, page 9
6.We refer to your disclosure of 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,
please revise to include specific cross-references for each summary risk to the more
detailed discussion of such risks in the prospectus.  Please also specifically discuss the
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.  Revise your summary risk factor relating to the risk that the Chinese
government may intervene or influence your operations at any time to clarify that the
Chinese government may also exert more control over offerings conducted overseas
and/or foreign investment in China-based issuers.  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.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 April 28, 2022 Page 4
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
April 28, 2022
Page 4
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li, Esq.

CORRESP
1
filename1.htm

April 1, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

 Re: Jin Medical International Ltd.

    Amendment No. 2 to Registration Statement on Form F-1

    Filed February 4, 2022

    File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter
dated March 1, 2022, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amendment to the registration statement
on Form F-1 (the “Amendment”) is being filed to accompany this letter.

Amendment No. 2 to Form F-1 filed February
4, 2022

Cover Page

1. We note your response to our prior comment 1. Please revise to provide cross-references to the condensed
consolidating schedule and the consolidated financial statements.

Response:
The Company acknowledges the Staff’s comment and provided cross-references to the condensed consolidating schedule and the consolidated
financial statements on the cover page.

Selected Condensed
Consolidated Statements of Operations, page 6

2. We have the following comments on your consolidating statements of operations presentation:

 ● Please
separately present the WFOE from your other subsidiaries;

 ● Please
explain why the current Subsidiaries column reflects no activity. Specifically address why, in accordance with the Exclusive Business
Cooperation and Service Agreement described on page 87, the WFOE does not reflect the service fees that the VIE is obligated to pay WFOE;
and

 ● Your
disclosures indicate the fee owed to the WFOE by the Zhongjin Operating Companies is “...determined to be pretax income after deducting
relevant costs and reasonable expenses in accordance with United States Financial Reporting Standards.” Please explain to us in
more detail the “relevant costs and reasonable expenses” deducted from pretax income and how the resulting fee provides the
WFOE with the right to receive benefits that could be potentially significant to the Zhongjin Operating Companies. In addition, please
explain to us how the fee creates an obligation for the WFOE to absorb losses of the Zhongjin Operating Companies when the WFOE receives
the fee.

 Response:
The Company acknowledges the Staff’s comment and updated the “selected condensed consolidated statements of operations”
schedule on page 6 of the Amendment to separately present the WFOE from our other subsidiaries.

Additionally,
we have updated the WFOE column to include service fee income from consulting services pursuant to the Exclusive Business Cooperation
and Service Agreement. The “relevant costs and reasonable expenses” include operation expenses and income taxes incurred by
the VIE in its day-to-day operations. The resulting fee amounted to approximately 100% of the Zhongjin Operating Companies’ net
profit. Even though U.S. GAAP does not provide clear guidance on whether WFOE’s right to receive such benefits is “potentially
significant”, we believe that 100% of the Zhongjin Operating Companies’ net profit is significant to the Zhongjin Operating
Companies.

In addition, we
have further determined that the fee does not create an obligation for the WFOE to absorb losses of the Zhongjin Operating Companies.
Accordingly, we have deleted disclosure that we are obligated to absorb losses of the Zhongjin Operating Companies throughout the Amendments.

Selected Condensed
Consolidated Balance Sheets, page 7

3. Please expand your selected condensed consolidated balance sheets to provide a more comprehensive presentation
of the consolidating assets and liabilities by ensuring the Subsidiaries column, WFOE column and VIE column include all intercompany activities
and balances. Ensure such amounts are presented on a gross basis to enhance transparency. To the extent necessary, please provide footnote
disclosures to indicate the nature of such activities and balances. To the extent necessary, please address this comment as it relates
to your Selected Condensed Consolidated Cash Flows.

Response:
The Company acknowledges the Staff’s comment and updated the “selected condensed consolidated balance sheet” on page
7 of the Amendment to provide a more comprehensive presentation of the consolidating assets and liabilities on a gross basis. Additionally,
the Company has revised the footnote disclosures to include the nature of activities conducted by the WFOE, other subsidiaries of the
Company and the balances outstanding. The Company has also amended the Selected Condensed Consolidated Cash Flows to present the cash
flows of the WFOE and the other subsidiaries separately.

Financial
Statements

Note 1 - Organization
and Business Description

Reorganization,
page F-7

4. You disclose that the November 26, 2020 reorganization involved the incorporation of Jin Med, Zhongjin
HK and Erhua Med, and signing of certain contractual arrangements between Zhongjin Technology, the shareholders of Changzhou Zhongjin
and Changzhou Zhongjin. Consequently, the Company became the ultimate holding company of Zhongjin HK, Erhua Med, Changzhou Zhongjin and
its subsidiaries. Please revise your disclosures such that it does not imply that the Company holds the equity interest in Changzhou Zhongjin
and its subsidiaries.

Response:
The Company acknowledges the Staff’s comments and revised Note 1 of the consolidated financial statements as of and for the years
ended September 30, 2021 and 2020.

    2

5. Please replace all references to "its" VIE with "the" VIE throughout the footnotes.

Response:
The Company acknowledges the Staff’s comments and revised all references to “its” VIE with “the” VIE throughout
the footnotes.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

3

United States securities and exchange commission logo
March 1, 2022
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 2 to
Registration Statement on Form F-1
Filed February 4, 2022
File No. 333-259767
Dear Mr. Wang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our December 20, 2021 letter.
Amendment No. 2 to Form F-1 filed February 4, 2022
Cover Page
1.We note your response to our prior comment 1.  Please revise to provide cross-references
to the condensed consolidating schedule and the consolidated financial statements.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 March 1, 2022 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
March 1, 2022
Page 2
Selected Condensed Consolidated Statements of Operations, page 6
2.We have the following comments on your consolidating statements of operations
presentation:
•Please seperately present the WFOE from your other subsidiaries;
•Please explain why the current Subsidiaries column reflects no activity.  Specifically
address why, in accordance with the Exclusive Business Cooperation and Service
Agreement described on page 87, the WFOE does not reflect the service fees that the
VIE is obligated to pay WFOE; and
•Your disclosures indicate the fee owed to the WFOE by the Zhongjin Operating
Companies is “...determined to be pretax income after deducting relevant costs and
reasonable expenses in accordance with United States Financial Reporting
Standards.”  Please explain to us in more detail the “relevant costs and reasonable
expenses” deducted from pretax income and how the resulting fee provides the
WFOE with the right to receive benefits that could be potentially significant to the
Zhongjin Operating Companies.  In addition, please explain to us how the fee creates
an obligation for the WFOE to absorb losses of the Zhongjin Operating Companies
when the WFOE receives the fee.
Selected Condensed Consolidated Balance Sheets, page 7
3.Please expand your selected condensed consolidated balance sheets to provide a more
comprehensive presentation of the consolidating assets and liabilities by ensuring the
Subsidiaries column, WFOE column and VIE column include all intercompany activities
and balances.  Ensure such amounts are presented on a gross basis to
enhance transparency.  To the extent necessary, please provide footnote disclosures to
indicate the nature of such activities and balances.  To the extent necessary, please address
this comment as it relates to your Selected Condensed Consolidated Cash Flows.
Financial Statements
Note 1 - Organization and Business Description
Reorganization, page F-7
4.You disclose that the November 26, 2020 reorganization involved the incorporation of Jin
Med, Zhongjin HK and Erhua Med, and signing of certain contractual arrangements
between Zhongjin Technology, the shareholders of Changzhou Zhongjin and Changzhou
Zhongjin. Consequently, the Company became the ultimate holding company of Zhongjin
HK, Erhua Med, Changzhou Zhongjin and its subsidiaries.   Please revise your disclosures
such that it does not imply that the Company holds the equity interest in Changzhou
Zhongjin and its subsidiaries.
5.Please replace all references to "its" VIE with "the" VIE throughout the footnotes.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 March 1, 2022 Page 3
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
March 1, 2022
Page 3
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li, Esq.

CORRESP
1
filename1.htm

February 4, 2022

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

Re: Jin Medical International
Ltd.

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

Filed December 10, 2021

File No. 333-259767

Dear Ms. Park:

This letter is in response to the letter
dated December 20, 2021, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amendment to the registration statement
on Form F-1 (the “Amendment”) is being filed to accompany this letter.

Form F-1A filed December 10, 2021

Cover Page

1. We note your response to our prior comment 1. Please provide a description on the cover page of how
cash is transferred through your organization and disclosure regarding your intentions to distribute earnings or settle amounts owed under
the VIE agreements.

Response:
The Company acknowledges the Staff’s comment and provided a description on the cover page of how cash is transferred through the
organization and disclosure regarding our intentions to distribute earnings or settle amounts owed under the VIE agreements.

Prospectus Summary, page 1

2. We note your response to our prior comment 2. Please revise further to replace all references to “your”
VIE business operations with “the” VIE in the Summary. For example, we refer to two references on page 2.

Response:
The Company acknowledges the Staff’s comment and replaced all references to “our” VIE business operations with “the”
VIE throughout the Amendment.

3. We note your response to our prior comment 6. Please provide a clearer description of how cash is transferred
through your organization as depicted in the organizational chart on page 1.

Response:
The Company acknowledges the Staff’s comment and revised the disclosure on page 3 of the Amendment to provide a clearer description
of how cash is transferred through our organization.

4. We note your revised disclosure in response to our prior comment 10. Please also provide a roll-forward
of the investment in subsidiaries and VIE line item for the fiscal year 2019.

Response:
The Company acknowledges the Staff’s comment and provided a roll-forward of the investment in subsidiaries and VIE line item for
the fiscal year 2019.

Financial Statements, page F-1

5. We note your audited financial statements are older than 12 months. Please explain your consideration
of Item 8.A.4 of Form 20-F and the corresponding instructions which indicates that, in the case of an initial public offering, audited
financial statements should generally not be older than 12 months at the time of filing. Please note that audited financial statements
not older than 15 months may be permitted if you are able to represent the following:

 ● The company is not required to comply with the 12 month
requirement for the age of financial statements in any other jurisdiction outside the United States; and

 ● Complying with the 12 month requirement is impracticable
or involves undue hardship.

If you meet the above criteria,
please provide a representation from management which indicates you meet the criteria and file that representation as an exhibit to your
registration statement. If you do not meet the criteria, please provide updated audited financial statements and related disclosures.

Response: The Company
acknowledges the Staff’s comment and is filing audited financial statements for the fiscal year ended September 30, 2021 as part
of the Amendment, therefore our audited financial statements are no longer older than 12 months.

    2

Note 12 Shareholders’ Equity, page
F-33

6. We note that during the years ended September 30, 2020 and 2019, the Company advanced cash to related
parties that are controlled by the Company’s major shareholder, Mr. Wang. Please further explain the business purposes for these
advances and, with reference to the appropriate authoritative literature, explain why you accounted for the forgiveness of these advances
as a return of capital rather than as an expense. Specifically address why, given the fact that Mr. Wang is the Company’s CEO, the forgiveness
of the advances should not be recognized as compensation.

Response: In September
2019, as part of the Company’s reorganization, Changzhou Zhongjin Medical Equipment Co. Ltd. (“Changzhou Zhongjin”)
spun off two entities, Jiangsu Zhongjin Kanglu Information Technology Co., Ltd. (“Jiangsu Zhongjin”) and Jiangsu Weiqier Health
Technology Co., Ltd. (“Jiangsu Weiqier”), and transferred the ownership of these two entities to Changzhou Zhongjian Kanglu
Technology Co., Ltd. (“Changzhou Kanglu”), a related party majority-owned by the Company’s major shareholder and CEO,
Mr. Erqi Wang. In connection with this spin-off transaction, the Company initially recorded approximately $1.5 million of receivables
due from Changzhou Kanglu as a related party loan. On September 30, 2019, the board of directors of Changzhou Zhongjin held a special
meeting and approved that those related party receivables should be considered as a return of capital to shareholders instead of a related
party loan, since Changzhou Zhongjin, Jiangsu Zhongjin, Jiangsu Weiqier and Changzhou Kanglu were effectively all controlled by the same
majority shareholder before and after the reorganization. Therefore, the reorganization, including the spin-off transaction, was considered
as a recapitalization of entities under common control, and the cancelation of the $1.5 million related party receivable as of September
30, 2019, which represented an offset of equity, was accounted for as a return of capital as part of the reorganization rather than
as compensation.

In May 2020, two minority owners
of Changzhou Zhongjin withdrew their investment in Changzhou Zhongjin and requested the Company return their capital contributions
in the amount of approximately $2 million. Changzhou Zhongjin returned the capital contribution to those minority shareholders
through Zhongjin Jingao Rehabilitation Equipment Co., Ltd. (“Jingao Rehab”), a related party controlled by the
Company’s major shareholder, Mr. Erqi Wang. Changzhou Zhongjin previously advanced approximately the same amount of funds to
Jingao Rehab as a related party loan. The $2 million advance to this related party was therefore used to refund the capital
contribution of these minority owners investment withdrawal. Therefore, the forgiveness of this advance was determined to be an
offset of equity contribution. Accordingly, the Company accounted for the forgiveness of this advance as a return of capital rather
than as an expense.

In assessing the accounting treatment
of these two transactions, the Company considered Staff Accounting Bulletin No. 107 (“SAB 107”), according to which, receivables
due from officers or other employees that resulting from sale of stock should be presented in the balance sheet as a deduction from stockholder’s
equity. Since the offset of receivables due from Changzhou Kanglu related to the Company’s restructuring and the offset of an advance
made to Jingao Rehab related to the return of capital to two minority owners of the Company, the Company therefore offset these receivables
against its equity and presented these transactions as return of capital rather than compensation expenses.

We further expanded our disclosure in
the financial statement under “Footnote 12 – Return of capital” as follows:

Return of capital

During the years ended September 30,
2020 and 2019, the Company had advances due from related parties that were controlled by the Company’s major shareholder, Mr. Erqi
Wang, for business purposes. The advances were interest free and due upon demand. The board of directors of the Company subsequently approved
that those related party advances should be considered a return of capital to its shareholders instead of related party loans, since these
advances were used to offset the spin-off or withdrawal of various equity interests of the Company. As a result, $2,059,532 and $1,525,266
of these advances were recorded as a return of capital to offset additional paid-in capital of the Company in the fiscal years ended September
30, 2020 and 2019, respectively, and the cash outflows to its related parties were recorded as part of investing activities as advances
made to (collections on advances to) related parties.

    3

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

4

United States securities and exchange commission logo
December 20, 2021
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 1 to
Registration Statement on Form F-1
Filed December 10, 2021
File No. 333-259767
Dear Mr. Wang:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our November 16, 2021 letter.
Form F-1A filed December 10, 2021
Cover Page
1.We note your response to our prior comment 1.  Please provide a description on the cover
page of how cash is transferred through your organization and disclosure regarding your
intentions to distribute earnings or settle amounts owed under the VIE agreements.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 December 20, 2021 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
December 20, 2021
Page 2
Prospectus Summary, page 1
2.We note your response to our prior comment 2.  Please revise further to replace all
references to "your" VIE business operations with "the" VIE in the Summary.  For
example, we refer to two references on page 2.
3.We note your response to our prior comment 6.  Please provide a clearer description of
how cash is transferred through your organization as depicted in the organizational chart
on page 1.
4.We note your revised disclosure in response to our prior comment 10.  Please also provide
a roll-forward of the investment in subsidiaries and VIE line item for the fiscal year 2019.
Financial Statements, page F-1
5.We note your audited financial statements are older than 12 months. Please explain your
consideration of Item 8.A.4 of Form 20-F and the corresponding instructions which
indicates that, in the case of an initial public offering, audited financial statements should
generally not be older than 12 months at the time of filing.  Please note that audited
financial statements not older than 15 months may be permitted if you are able to
represent the following:
    • The company is not required to comply with the 12 month requirement for the age of
financial statements in any other jurisdiction outside the United States; and
    • Complying with the 12 month requirement is impracticable or involves undue
hardship.
If you meet the above criteria, please provide a representation from management which
indicates you meet the criteria and file that representation as an exhibit to your registration
statement. If you do not meet the criteria, please provide updated audited financial
statements and related disclosures.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 December 20, 2021 Page 3
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
December 20, 2021
Page 3
Note 12 Shareholders' Equity, page F-33
6.We note that during the years ended September 30, 2020 and 2019, the Company
advanced cash to related parties that are controlled by the Company’s major shareholder,
Mr. Wang.  Please further explain the business purposes for these advances and, with
reference to the appropriate authoritative literature, explain why you accounted for the
forgiveness of these advances as a return of capital rather than as an expense.  Specifically
address why, given the fact that Mr. Wang is the Company's CEO, the forgiveness of the
advances should not be recognized as compensation.

            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li, Esq.

CORRESP
1
filename1.htm

December 10, 2021

Via Edgar

Ms. Jane Park

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange
Commission

Re: Jin Medical International Ltd.

Registration Statement
on Form F-1

Filed September 24, 2021

CIK No. 0001837821

Dear Ms. Park:

This letter is in response to the letter
dated November 16, 2021, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. An amendment to the registration statement
on Form F-1 (the “Amendment”) is being filed to accompany this letter.

Form F-1 filed September 24, 2021

Cover Page

1. Provide a description of how cash is transferred through your organization and disclosure regarding
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.

Response: The
Company respectfully acknowledges the Staff’s comment and in response we have revised the cover page of the Amendment and have added
disclosure under the heading “Prospectus Summary - Dividends and Distributions” to provide a description of how cash
is transferred through our organization and have included disclosure regarding our intentions to distribute earnings or settle amounts
owed under the VIE agreements. In addition, we revised the disclosure to indicate that no transfers of cash, dividends, or distributions
have been made to date.

2. We note references here and throughout the registration statement to “your” VIE business operations. Please replace all
such references in the registration statement with “the” VIE, where applicable.

Response: The
Company respectfully acknowledges the Staff’s comment and in response has replaced all references throughout the registration statement
to “our” VIE business with “the” VIE, where applicable.

3. We note your disclosure on page 1 and throughout your filing that you control and receive economic
benefits of Changzhou Zhongjin Medical Equipment Co. Ltd.’s business operations through VIE agreements and that those agreements
are designed to provide your 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 the disclosure that your WFOE is deemed to be the primary beneficiary of the VIE.
However, you or your investors do not have an equity ownership in, direct foreign investment in, or control through such ownership/investment
of the VIE. Any references to control or benefits that accrue to you because of the VIE should be limited to and clearly describe the
conditions you met for consolidation of the VIE under U.S. GAAP and your disclosure should clarify that, for accounting purposes, you
will be the primary beneficiary. In addition, your disclosure should note, if true, that the agreements have not been tested in a court
of law.

Response: The
Company respectfully acknowledges the Staff’s comment and in response we revised the disclosure on page 1 and throughout the Amendment,
so that any references to control or benefits that accrue to the Company because of the VIE are limited and due to the conditions the
Company met for consolidation of the VIE under the U.S. GAAP, which are described in the disclosure, and have clarified that the Company
will be the primary beneficiary for accounting purposes. In addition, we revised the disclosure to note that the VIE agreements have not
been tested in a court of law.

Prospectus Summary, page 1

4. 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 uncertainties under Chinese
law and jurisdictional limits.

Response: The
Company respectfully acknowledges the Staff’s comment and in response has revised the Prospectus Summary on page 2 of the Amendment
to (1) describe how the Company’s 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, and (2) 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 uncertainties under Chinese law and jurisdictional limits.

5. Disclose each permission that you, your subsidiaries or your VIEs are required to obtain from Chinese
authorities to operate and issue these securities to foreign investors. State whether you, your subsidiaries, or VIEs are covered by permissions
requirements from the CSRC, CAC or any other entity that is required to approve of the VIE’s operations, and state affirmatively
whether you have received all requisite permissions and whether any permissions have been denied.

Response: The
Company respectfully acknowledges the Staff’s comment and in response has revised the Prospectus Summary on page 3 of the Amendment
to disclose that neither we, our subsidiaries nor the VIE (1) are required to obtain any permission from Chinese authorities to operate
and issue securities to foreign investors, and (2) are covered by permission requirements from the CSRC, CAC or any other entity that
is required to approve of the VIE’s operations. We have also included disclosure in the Amendment to affirmatively state that we
have received all requisite permissions and that we have not been denied any permission to operate our business.

6. Please revise to provide a clearer description of how cash is transferred through your organization.
Describe any restrictions and limitations on your ability to distribute earnings from your businesses, including subsidiaries and/or 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 respectfully acknowledges the Staff’s comment and in response has revised the Prospectus Summary on page 3 of the Amendment
to provide a clearer description of how cash is transferred through our organization and describe any restrictions and limitations on
our ability to distribute earnings from our businesses, including subsidiaries and/or consolidated VIE, to the parent company and U.S.
investors, as well as the ability to settle amounts owed under the VIE agreements.

    2

7. We note your disclosure on page 23 and throughout your filing that you control and receive economic
benefits of Changzhou Zhongjin Medical Equipment Co. Ltd.’s business operations through VIE agreements and that those agreements
are designed to provide you 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 the disclosure that your WFOE is deemed to be the primary beneficiary of the VIE. However,
you or your investors do not have an equity ownership in, direct foreign investment in, or control through such ownership/investment of
the VIE. Any references to control or benefits that accrue to you because of the VIE should be limited to and clearly describe the conditions
you met for consolidation of the VIE under U.S. GAAP and your disclosure should clarify that, for accounting purposes, you will be the
primary beneficiary. In addition, your disclosure should note, if true, that the agreements have not been tested in a court of law.

Response: The
Company respectfully acknowledges the Staff’s comment and in response we have revised the disclosure on page 24 and throughout the
Amendment, so that any references to control or benefits that accrue to the Company because of the VIE are (1) limited and due to the
conditions the Company met for consolidation of the VIE under the U.S. GAAP, which are described in the disclosure, and (2) the Company
will be the primary beneficiary for accounting purposes. In addition, we revised the disclosure to note that the VIE agreements have not
been tested in a court of law.

8. We note your disclosure that the VIE structure is used to replicate foreign investment in China-based
companies. We note, however, that the structure provides contractual exposure to foreign investment in such companies rather than replicating
an investment. Please revise accordingly.

Response:
The Company respectfully acknowledges the Staff’s comment and in response has revised the disclosure throughout the Amendment to
state that the VIE structure is used to provide contractual exposure to foreign investment in the Company rather than replicating an investment.

9. Please disclose whether you are required to obtain any approvals to offer securities to foreign investors,
whether you have received such approvals and the consequences to you and your investors if you do not receive or maintain the approvals,
inadvertently conclude that such approvals are not required, or applicable laws, regulations, or interpretations change and you are required
to obtain approval in the future.

Response: We
respectfully advise the Staff that we have revised the Prospectus Summary on page 3 of the Amendment to disclose that we, our subsidiaries
or VIE, are not required to obtain any permission from Chinese authorities to offer securities to foreign investors, and the consequences
to the Company and investors if applicable laws, regulations, or interpretations change and the Company is required to obtain approval
in the future.

10. We note that the activity of the VIE is reflected in the line items titled “investments in subsidiaries
and VIEs” and “income from equity method investment” in the parent’s financial statements. Please provide a roll-forward
of the investment in subsidiaries and VIEs line item.

Response: We
respectfully acknowledge the Staff’s comment and in response have revised the disclosure on page 7 of the Amendment to provide a
roll-forward of the investment in subsidiaries and VIE line item.

Risk Factors, page 13

11. We note from the audit opinion and your risk factor on page 37 that you have a U.S. based auditor that
is registered with the PCAOB and subject to PCAOB inspection. Please disclose any material risks to the company and investors if it is
later determined that the PCAOB is unable to inspect or investigate completely your auditor because of a position taken by an authority
in a foreign jurisdiction. For example, disclose the risk that lack of inspection could cause trading in your securities to be prohibited
under the Holding Foreign Companies Accountable Act and as a result an exchange may determine to delist your securities.

Response: We
respectfully acknowledge the Staff’s comment and in response have revised the disclosure on pages 9 and 38 of the Amendment to
disclose material risks to the Company and investors if it is later determined that the PCAOB is unable to inspect or investigate completely
our auditor because of a position taken by an authority in a foreign jurisdiction.

    3

12. Please expand your risk factor disclosure to discuss that the United States Senate passed the Accelerating
Holding Foreign Companies Accountable Act, which, if enacted, would decrease the number of non-inspection years from three years to two,
thus reducing the time period before your securities may be prohibited from trading or delisted.

Response: The
Company respectfully acknowledges the Staff’s comment and in response has revised the disclosure on pages 9 and 38 of the Amendment
to expand our risk factor disclosure to discuss that the United States Senate passed the Accelerating Holding Foreign Companies Accountable
Act, which, if enacted, would decrease the number of non-inspection years from three years to two, thus reducing the time period before
our securities may be prohibited from trading or delisted.

13. Revise your risk factors to acknowledge that if the PRC government determines that the contractual
arrangements constituting part of your VIE structure do not comply with PRC regulations, or if these regulations change or are interpreted
differently in the future, your shares may decline in value or become worthless if you are unable to assert your contractual control rights
over the assets of your PRC subsidiaries that conduct all or substantially all of your operations.

Response: We
respectfully acknowledge the Staff’s comment and in response have revised the disclosure on pages 9 and 22 of the Amendment to acknowledge
that if the PRC government determines that the contractual arrangements constituting part of our VIE structure do not comply with PRC
regulations, or if these regulations change or are interpreted differently in the future, our shares may decline in value or become worthless
if we are unable to assert contractual control rights over the assets of our PRC operating entities that conduct all of our operations.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

4

United States securities and exchange commission logo
November 16, 2021
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Registration Statement on Form F-1
Filed September 24, 2021
File No. 333-259767
Dear Mr. Wang:
            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.
Form F-1 filed September 24, 2021
Cover Page
1.Provide a description of how cash is transferred through your organization and disclosure
regarding 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.
2.We note references here and throughout the registration statement to "your" VIE business
operations.  Please replace all such references in the registration statement with "the" VIE,
where applicable.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 November 16, 2021 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
November 16, 2021
Page 2
3.We note your disclosure on page 1 and throughout your filing that you control and receive
economic benefits of Changzhou Zhongjin Medical Equipment Co. Ltd.’s business
operations through VIE agreements and that those agreements are designed to provide
your 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 the disclosure that
your WFOE is deemed to be the primary beneficiary of the VIE. However, you or your
investors do not have an equity ownership in, direct foreign investment in, or control
through such ownership/investment of the VIE. Any references to control or benefits that
accrue to you because of the VIE should be limited to and clearly describe the conditions
you met for consolidation of the VIE under U.S. GAAP and your disclosure should clarify
that, for accounting purposes, you will be the primary beneficiary. In addition, your
disclosure should note, if true, that the agreements have not been tested in a court of law.
Prospectus Summary, page 1
4.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 uncertainties under Chinese law and jurisdictional limits.
5.Disclose each permission that you, your subsidiaries or your VIEs are required to obtain
from Chinese authorities to operate and issue these securities to foreign investors.  State
whether you, your subsidiaries, or VIEs are covered by permissions requirements from the
CSRC, CAC or any other entity that is required to approve of the VIE’s operations, and
state affirmatively whether you have received all requisite permissions and whether any
permissions have been denied.
6.Please revise to provide a clearer description of how cash is transferred through your
organization.  Describe any restrictions and limitations on your ability to distribute
earnings from your businesses, including subsidiaries and/or consolidated VIEs, to the
parent company and U.S. investors as well as the ability to settle amounts owed under the
VIE agreements.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 November 16, 2021 Page 3
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
November 16, 2021
Page 3
7.We note your disclosure on page 23 and throughout your filing that you control and
receive economic benefits of Changzhou Zhongjin Medical Equipment Co. Ltd.’s
business operations through VIE agreements and that those agreements are designed to
provide your 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 the
disclosure that your WFOE is deemed to be the primary beneficiary of the VIE.  However,
you or your investors do not have an equity ownership in, direct foreign investment in, or
control through such ownership/investment of the VIE.  Any references to control or
benefits that accrue to you because of the VIE should be limited to and clearly describe
the conditions you met for consolidation of the VIE under U.S. GAAP and your disclosure
should clarify that, for accounting purposes, you will be the primary beneficiary.  In
addition, your disclosure should note, if true, that the agreements have not been tested in a
court of law.
8.We note your disclosure that the VIE structure is used to replicate foreign investment in
China-based companies.  We note, however, that the structure provides contractual
exposure to foreign investment in such companies rather than replicating an investment.
Please revise accordingly.
9.Please disclose whether you are required to obtain any approvals to offer securities to
foreign investors, whether you have received such approvals and the consequences to you
and your investors if you do not receive or maintain the approvals, inadvertently conclude
that such approvals are not required, or applicable laws, regulations, or interpretations
change and you are required to obtain approval in the future.
10.We note that the activity of the VIE is reflected in the line items titled “investments in
subsidiaries and VIEs” and “income from equity method investment” in the parent’s
financial statements.  Please provide a roll-forward of the investment in subsidiaries and
VIEs line item.
Risk Factors, page 13
11.We note from the audit opinion and your risk factor on page 37 that you have a U.S. based
auditor that is registered with the PCAOB and subject to PCAOB inspection.  Please
disclose any material risks to the company and investors if it is later determined that the
PCAOB is unable to inspect or investigate completely your auditor because of a position
taken by an authority in a foreign jurisdiction.  For example, disclose the risk that lack of
inspection could cause trading in your securities to be prohibited under the Holding
Foreign Companies Accountable Act and as a result an exchange may determine to delist
your securities.
12.Please expand your risk factor disclosure to discuss that the United States Senate passed
the Accelerating Holding Foreign Companies Accountable Act, which, if enacted, would
decrease the number of non-inspection years from three years to two, thus reducing the
time period before your securities may be prohibited from trading or delisted.

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 November 16, 2021 Page 4
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
November 16, 2021
Page 4
13.Revise your risk factors to acknowledge that if the PRC government determines that the
contractual arrangements constituting part of your VIE structure do not comply with PRC
regulations, or if these regulations change or are interpreted differently in the future, your
shares may decline in value or become worthless if you are unable to assert your
contractual control rights over the assets of your PRC subsidiaries that conduct all or
substantially all of your operations.
            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 Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li

CORRESP
1
filename1.htm

September 24, 2021

Via Edgar

Mr. Jason Drory

Division of Corporation

Office of Life Sciences

U.S. Securities and Exchange Commission

Re: Jin Medical International
Ltd.

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

Submitted June 30, 2021

CIK No. 0001837821

Dear Mr. Drory:

This letter is in response to the letter dated
July 16, 2021, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Jin Medical International Ltd. (the “Company”, “we”, or “our”). For ease of reference, we have
recited the Commission’s comments in this response and numbered them accordingly. A registration statement on Form F-1 (the “F-1”)
is being filed to accompany this letter.

Amendment No. 1 to Registration Statement on
Form F-1 submitted on June 30, 2021

Prospectus Summary

Overview, page 1

    1.
    We note your updated disclosure at the top of page 3 and it appears that your statement of financial results for the last two fiscal years is inconsistent with your disclosure elsewhere in your draft registration statement. Please revise your statement that your “revenue was $16,193,763 and $20,366,846 for the fiscal years 2019 and 2020, respectively; [y]our net income was $2,205,998 and $3,647,510 for the fiscal years 2019 and 2020, respectively.”

Response: We acknowledge the
Staff’s comment and revised the statement of financial results for the last two fiscal years on page 5 of the F-1.

Material Income Tax Considerations, page 148

    2.
    We note your response to prior comment 33 and revised disclosure on page 148. Please update your exhibit index accordingly to reflect that Maples and Calder (Hong Kong) LLP, your Cayman Islands counsel, is providing a tax opinion.

Response: We acknowledge the
Staff’s comment and updated the exhibit index accordingly to reflect that Maples and Calder (Hong Kong) LLP, our Cayman Islands
counsel, is providing a tax opinion.

Consolidated Financial Statements

Employee Benefits, page F-19

    3.
    You indicate in your responses to prior comments 35 and 36 that you have not received any notice or announcement from relevant government authorities indicating that your practice relating to employees’ social security premiums payments or housing funds are in violation of existing applicable laws and regulations. Notwithstanding this lack of notice or announcement, please clarify if your practices are in accordance with existing applicable laws and regulations. If not, address the need to revise your financial statements to fully recognize your obligations under these laws. In this regard, please note that even though Mr. Wang promised to unconditionally, irrevocably and personally bear any and all of the economic losses and expense you would incur if your practices were determined to be in violation of applicable laws and regulations, such expenses must be reflected as an expense in your financial statements in accordance with SAB Topic 5T.

Response: The applicable PRC
laws and regulations on employee benefits stipulate that employers shall be responsible for paying employers’ portion of social
insurance welfares, including pension insurance, medical insurance, work-related injury insurance, unemployment insurance, maternity insurance
and housing provident funds based on the actual wage paid to employees. However, given the different economic development levels in different
regions, these regulations have not been implemented consistently by local governments in China, and each provincial or municipal governing
Social Security Bureau (“SSB”) has its own discretion to enforce the compliance of these regulations by employers. The Company’s
PRC operating entities have contributed employment benefits for all of the eligible employees at least at the minimum wage level and have
received official letters from the local governing SSBs in Jiangsu Province, where the Company’s PRC operating entities are located,
confirming that none of the Company’s PRC operating entities is in violation of any employment or social benefit regulations for
the period from January 2017 to August 2021. The Company has evaluated all relevant facts and believes the probability that the local
governing SSBs may find any of its PRC operating entities to be in violation of the relevant regulations in the future is very low. Accordingly,
the Company has concluded that no additional accrual for social security premium or housing provident fund contribution is necessary in
accordance with SAB Topic 5T.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Erqi Wang

    Name:
    Erqi Wang

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
July 16, 2021
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted June 30, 2021
CIK No. 0001837821
Dear Mr. Wang:
            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.
Amendment No. 1 to Registration Statement on Form F-1 submitted on June 30, 2021
Prospectus Summary
Overview, page 1
1.We note your updated disclosure at the top of page 3 and it appears that your statement of
financial results for the last two fiscal years is inconsistent with your disclosure elsewhere
in your draft registration statement. Please revise your statement that your "revenue was
$16,193,763 and $20,366,846 for the fiscal years 2019 and 2020, respectively; [y]our net
income was $2,205,998 and $3,647,510 for the fiscal years 2019 and 2020, respectively."

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 July 16, 2021 Page 2
 FirstName LastName
Erqi Wang
Jin Medical International Ltd.
July 16, 2021
Page 2
Material Income Tax Considerations, page 148
2.We note your response to prior comment 33 and revised disclosure on page 148. Please
update your exhibit index accordingly to reflect that Maples and Calder (Hong Kong)
LLP, your Cayman Islands counsel, is providing a tax opinion.
Consolidated Financial Statements
Employee Benefits, page F-19
3.You indicate in your responses to prior comments 35 and 36 that you have not received
any notice or announcement from relevant government authorities indicating that your
practice relating to employees’ social security premiums payments or housing funds are in
violation of existing applicable laws and regulations. Notwithstanding this lack of notice
or announcement, please clarify if your practices are in accordance with existing
applicable laws and regulations. If not, address the need to revise your financial
statements to fully recognize your obligations under these laws. In this regard, please note
that even though Mr. Wang promised to unconditionally, irrevocably and personally bear
any and all of the economic losses and expense you would incur if your practices were
determined to be in violation of applicable laws and regulations, such expenses must be
reflected as an expense in your financial statements in accordance with SAB Topic 5T.
            You may contact Tracey McKoy at 202-551-3772 or Jeanne Baker at 202-551-3691 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jason Drory at 202-551-8342 or Celeste Murphy at 202-551-3257 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ying Li

United States securities and exchange commission logo
January 22, 2021
Erqi Wang
Chief Executive Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
Draft Registration Statement on Form F-1
Submitted December 28, 2020
CIK No. 0001837821
Dear Mr. Wang:
            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 on Form F-1 submitted December 28, 2021
Prospectus Summary
Overview, page 1
1.Please balance your disclosure where you state that you have relationships with over forty
dealers to highlight the fact that approximately 79% of your sales for the six months ended
March 31, 2021 were attributable to your top two customers and approximately 82% of
your sales for the fiscal year ended September 30, 2019 were attributable to your top
three customers.
2.We note your disclosure on page 2 that you "own two manufacturing facilities in China."

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 January 22, 2021 Page 2
 FirstName LastNameErqi Wang
Jin Medical International Ltd.
January 22, 2021
Page 2
However, we note your disclosure on page 105 where it appears that you lease one of your
two manufacturing facilities. Please correct this inconsistency or otherwise advise.
3.We note your disclosure on page 117 that, "[t]he Company manufactures wheelchairs and
wheelchair components as subcontracted by Nissin Medical Industries Co., Ltd.
(“Nissin”), which imports and distributes the Company’s products in Japan under Nissin’s
brands." We also note your disclosure here that Nissin is your "largest dealer and sole
distributor in Japan." Please expand your disclosure here and elsewhere in your Business
section as appropriate to further clarify your relationship with Nissin, including the fact
that your products sold in Japan are sold under Nissin's brand, or otherwise advise.
Corporate Structure, page 5
4.Identify the natural persons who are the shareholders of the VIE and each subsidary of the
VIE, including but not limited to the Changzhou Zhongin Shareholders.
5.Revise your Corporate Structure to identify Zhongjin Jinao, the entity that obtained the
2015 value-added telecommunications business operating license and is in the process of
renewing it.  Further define Zhongjin Jinao in your definitions section, summary and
throughout the disclosure.
6.Please explain the status of the current business use of the value-added
telecommunications business operation license obtained in 2015 by Zhongjin
Jinao.   Disclose the timing of the company's plans to "open its own internet platform for
selling and promoting products directly to its end-users."  We note that the license expired
in June 2020 and the Company is in the process of renewing it.
7.Please disclose the commercial name of your company as required by Item 4.A.1 of Form
20-F. For example, we note that your logo contains the name Jin Med, your website is
www.zhjmedical.com and the legal name of your operating companies contain Zhongjin.
Please clarify in your disclosure the name(s) by which your customers recognize you.
8.Disclose the business purpose for using the VIE structure for the business entities that do
not hold the telecommunications business license, given that your current production and
operation do not fall within any items on the Negative List.
Implications of Being an Emerging Growth Company and a Foreign Private Issuer, page 6
9.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.
Risk Factors, page 10
10.Please update your risk factor disclosure by relocating risks that could apply generally to
any company or offering of securities to the end of the risk factor section under the

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 January 22, 2021 Page 3
 FirstName LastNameErqi Wang
Jin Medical International Ltd.
January 22, 2021
Page 3
caption “General Risk Factors.” In addition, your risk factor disclosure exceeds 15 pages.
Please include summary risk factor disclosure of no more than two pages in the forepart of
your registration statement. Refer to Item 105 of Regulation S-K and SEC Release No.
33-10825.
Risks Related to Our Business, page 10
11.Based on your disclosures on page 122, it is not clear that your CEO or CFO has US
GAAP accounting experience.   Please tell us the background and experience of the
people who are primarily responsible for preparing and supervising the preparation of
your financial statements and their knowledge of U.S. GAAP and SEC rules and
regulations, including education, professional designations such as Certified Public
Accountant (U.S.) and professional experience in preparing and/or auditing financial
statements prepared in accordance with U.S. GAAP.  If your staff does not have
sufficient knowledge of US GAAP and SEC rules and regulations, please provide a risk
fact that appropriately addresses the potential implications of this limited knowledge.
A significant portion of our revenue is concentrated on a few large customers..., page 10
12.We note that as of March 31, 2020 you only had two large customers that account for
most of your revenue whereas in the prior year you had three large customers. Please
update your disclosure to include the reason for the loss of customer or otherwise
advise. In addition, to the extent that your business is substantially dependent on a
contractual agreement with these customers, in your business section please identify the
customer, disclose the material terms, and file the agreement as an exhibit to your
registration statement. Please refer to Item 4(b) of Form F-1 and 601(b)(10) of Regulation
S-K.
Our expansion into new product categories may expose us to new challenges and more risks.,
page 15
13.We note your disclosure elsewhere that you are currently selling your living aids products
to a few selected customers to test the markets for these products. In addition, we note
your disclosure that you only started selling electric wheelchairs in 2018. Please update
your disclosure here to discuss the roll-out of your new electric wheelchairs and living
aids products. To the extent there are known material risks or challenges with respect to
these products please include disclosure here or otherwise advise.
Risks Related to Our Corporate Structure, page 18
14.Please consider the addition of risk factor disclosure relating to your VIE structure and the
risk incumbent upon the potential misuse or misappropriation of controlling nontangible
assets, including chops and seals. Refer to CF Disclosure Guidance: Topic No. 10 for
additional guidance.
Risks Related to Doing Business in China, page 22

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 January 22, 2021 Page 4
 FirstName LastNameErqi Wang
Jin Medical International Ltd.
January 22, 2021
Page 4
15.Please consider the addition of risk factor disclosure relating to regulatory environment in
China, including disclosure on (i) how intellectual property rights and protections may be
insufficient for your material intellectual property in China and (ii) how the increased
global focus on environmental and social issues and China’s potential adoption of more
stringent standards in these areas may adversely impact your operations. Refer
to CF Disclosure Guidance: Topic No. 10 for additional guidance.
We may be subject to penalties if we are not in compliance with the PRC’s regulations relating
to employee’s social insurance and housing..., page 32
16.We note your disclosure that the company has not paid in full the housing funds required
for all of its employees. Please revise to quantify the shortage of contributions to the
housing funds and the sources of funds that will be used to make such contributions.
Disclosure Regarding Forward-Looking Statements, page 43
17.You caution investors not to place "undue reliance" on forward-looking statements based
on statistical data obtained from government publications. Please note that you are
responsible for the entire content of the registration statement and you may not use
language that could be interpreted as a disclaimer of the information contained in the
filing. Please revise your disclosure accordingly.
Use of Proceeds, page 45
18.On page 95, we note your disclosure that you plan to build your "own online platform to
directly promote and sell [y]our products to end users globally." If a principal
intended use of proceeds from this offering will be to develop your online platform, please
expand your disclosure in this section as appropriate or otherwise advise.
Capitalization, page 47
19.It appears you have only considered your equity in the determination of your
capitalization. Please note, your total capitalization table should also include your short
and long term debt balances. Please modify your presentation accordingly and refer to
Item 3.B of Form 20-F for guidance.
COVID-19 Impact, page 52
20.Given the amount of time that has passed since the initial COVID-19 outbreak in
December 2019, please update your disclosure to discuss the specific impact observed in
fiscal year end 2020, including the material operational challenges that your company may
have faced. For example, we note your disclosure that your revenue decreased by
approximately $3.7 million during the fiscal year 2020. However, please include a
discussion of the COVID-19 impact for the fiscal year 2020 for your other material key
performance indicators. In addition, please tell us what consideration you gave to

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 January 22, 2021 Page 5
 FirstName LastNameErqi Wang
Jin Medical International Ltd.
January 22, 2021
Page 5
providing expanded information regarding the specific impacts you have experienced to
your operations and relevant metrics resulting from the COVID-19 pandemic. Refer to CF
Disclosure Guidance: Topic No. 9 and 9A for additional guidance.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 65
21.We note your disclosures in your financial statements and elsewhere that the majority of
your revenue and expense transactions are denominated in RMB and a significant portion
of your assets and liabilities are denominated in RMB.  In light of the fact that the RMB is
not freely convertible into foreign currency and all foreign exchange transactions must
take place through authorized institutions, please expand your disclosures to indicate how
earnings and cash are transferred from your PRC subsidiary and VIE to your entities
outside the PRC and, conversely,  how cash is transferred to your PRC subsidiary and
VIE. Please also disclose restrictions that impact the ability to transfer cash within your
corporate structure. Finally, please disclose the amount of cash denominated in RMB.
22.Your accounts receivable as of September 30, 2019 and March 30, 2020 appear to have
increased at a greater rate than your revenues. In this regard, and based on our
calculations, your days sales outstanding has increased from 114 days at September 30,
2019 to 179 days at March 30, 2020.  Please explain the reason(s) for this apparent
deterioration in days sales outstanding.  If this is a trend that continued through September
30, 2020, please expand your disclosures to provide the following:

•Disclose your Days Sales Outstanding as your latest balance sheet presented and
provide an explanation for increases as compared to prior periods;
•Disclose information regarding the aging of your receivable balances and provide
explanations for changes as compared to prior periods;
•Clarify the typical payment terms of your sales to customers and whether you have
provided any extended payment terms;
•Disclose more specifically how you determined the allowance for doubtful accounts
and how you took into account the above factors; and
•Address the implications of increasing days sales outstanding on your results of
operations, financial position and liquidity.
Refer to Section IV.B.1 of SEC Release No. 33-8350.
Business, page 88
23.We note your disclosure that your success "depends heavily on offering innovative
wheelchair products" and "[y]our R&D department continuously delivers innovative
designs that are both lightweight and ergonomic." Please expand your disclosure to
describe how your products and services are "innovative" and designed to achieve "high
customer satisfaction."
Contractual Arrangements among WFOE, Changzhou Zhongjin and Changzhou Zhongjin’s

 FirstName LastNameErqi Wang
 Comapany NameJin Medical International Ltd.
 January 22, 2021 Page 6
 FirstName LastNameErqi Wang
Jin Medical International Ltd.
January 22, 2021
Page 6
Shareholders, page 91
24.Please include a discussion of the Spousal Consents and parties thereto.
High Quality Products that Focus on Customer Needs, page 94
25.Please substantiate your claim that you have “high quality products” that are the "highest
quality for the costs" or elsewhere in the draft registration statement where you state your
products are "first-class."  Alternatively, please revise your disclosure.
Increase Our Production Capability to Increase Sales, page 96
26.We note your disclosure here that you "believe it is essential to expand and update [y]our
production facilities, and increase [y]our production capability in order to keep up with
the customer demand and sales." However, we note your disclosure that your "facilities
are suitable and adequate for [y]our operations and adequately maintained." Please correct
for this apparent inconsistency or otherwise advise. In addition, please describe in greater
detail the steps you plan to take to expand and update your production facilities.
Research and Development, page 102
27.We note your disclosure here that your "R&D department is led by our CEO, Dr. Erqi
Wang, with a team of than 30 employee." However, we note your disclosure elsewhere
that your R&D team consists of 39 employees on pages 2, 39, 94 and 105. Please correct
this apparent inconsistency or otherwise advise.
Competition, page 103
28.We note your disclosure on page 103 that you "focus on product innovation, operational
improvement, and brand building has strengthened [y]our market position in Japan while
driving rapid growth and expanding margins in the past two years." However, we note
your disclosure on page 97 that your revenues in Japan have decreased from $16,370,440
in 2018 to $14,816,995 in 2019. In addition, it appears that that your reported revenue for
the first half 2020 has decreased to $4,924,134. Similarly, we note your disclosure of
lower gross margins on page 57. Please revise this statement on page 103 or otherwise
advise.
Employees, page 105
29.We note your total number of employees decreased from 341 employees to 251
employees as of November 30, 2020. Please include narrative disclosure describing the
reason for the material decr