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                            November 17, 2021

       Yandai Wang
       Chief Executive Officer
       SOS Limited
       Building 6, East Seaview Park
       298 Haijing Road, Yinzhu Street
       West Coast New District, Qingdoa City
       Shandong Province 266400
       People's Republic of China

                                                        Re: SOS Limited
                                                            Form 20-F for the
fiscal period ending December 31, 2020
                                                            Filed May 5, 2021
                                                            Form 20-F/A for the
fiscal period ending December 31, 2020
                                                            Filed October 12,
2021
                                                            File No. 001-38051

       Dear Mr. Wang:

               We have reviewed your 20-F/A for the fiscal year ended December
31, 2020 in response
       to our comment letter and have the following comments. In some of our
comments, we may ask
       you to provide us with information so we may better understand your
disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 20, 2021 letter.

       Form 20-F for the fiscal period ending December 31, 2020

       Introduction, page iv

   1.                                                   We note your revisions
in the 20-F/A in response to prior comment 3. Please address the
                                                        following at the onset
of Part 1:

                                                              We note that you
refer to SOS as an exempted company registered in the Cayman
                                                            Islands with
limited liability and or an offshore holding company. Revise to clearly
 Yandai Wang
FirstName LastNameYandai Wang
SOS Limited
Comapany 17,
November  NameSOS
              2021 Limited
November
Page 2    17, 2021 Page 2
FirstName LastName
              state that SOS Limited,    is a Cayman Islands holding company
and conform your
              references throughout the filing; and
                Define    subsidiaries    and    variable interest entity(ies),
including the names of the
              entities that reconciles to the information disclosed in the
corporate structure diagram
              on page 50 and the entities listed on page F-7.
Part I, page 1

2.       We note your revisions in the 20-F/A in response to prior comment 1.
Please address the
         following at the onset of Part 1:

                Explain whether the VIE structure is used to replicate foreign
investment in PRC
              based companies where PRC law prohibits direct foreign investment
in the operating
              companies or if the structure provides contractual exposure to
foreign investment in
              such companies rather than replicating an investment;
                Explain that investors may never directly hold equity interests
in your PRC operating
              company(ies) and or VIE;
                Enhance your disclosure to explain that PRC regulatory agencies
could disallow your
              corporate structure which would likely result in a material
change in your operations
              and/or value of the ADSs which could significantly decline in
value or become
              worthless; and
                Add a cross-reference to "Risk Factors - Risks Related to Our
Corporate Structure   .
3.       We note your disclosure on page 1, in both Part 1 and Item 3. Key
Information, and
         throughout your filing that you control and receive the economic
benefits of Qingdao SOS
         Industrial Holding Co., Ltd. business operations through VIE
agreements and that those
         agreements are designed to provide your WFOE with the power, rights,
and obligations
         equivalent in all material respects to those it would possess as the
principal equity holder
         of the VIE. We also note the disclosure that you are 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. As such, when
         describing the design of the VIE agreements and related outcome,
please refrain from
         implying that the VIE agreement is equivalent to those it would
possess as the principal
         equity holder 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.
Item 3. Key Information, page 1

4.       We note your revisions in the 20-F/A in response to prior comment 4.
Please address the
         following at the onset of Item 3:

                Provide a diagram of your corporate structure consistent with
your disclosure on page
 Yandai Wang
FirstName LastNameYandai Wang
SOS Limited
Comapany 17,
November  NameSOS
              2021 Limited
November
Page 3    17, 2021 Page 3
FirstName LastName
              50;
                Clarify which entity investors are purchasing their interest
and the entity(ies) in
              which the company   s operations are conducted;
                Conform your entity references in your discussion on
contractual agreements
              between WFOE and the VIE using the current entity names as
referenced so that this
              discussion aligns with related discussions throughout the filing;
and
                Explain why the contractual arrangements between WFOE and the
VIE may be less
              effective than direct ownership and the difficulty in challenging
legally as well as the
              potential substantial costs to enforce the terms of the
arrangements.
5.       We note your revisions in the 20-F/A in response to prior comment 5.
Please address the
         following at the onset of Item 3:

                Enhance your disclosure to explain, aside from typical legal
and regulatory
              uncertainties, how the legal system in the PRC presents unique
risks to investors with
              regard to risks and uncertainties. For example, that rules and
regulations in the PRC
              can change quickly with little advance notice, the PRC
governments significant level
              of authority to exert influence, the extensive and evolving legal
system, the PRC
              governments oversight over your and your VIEs business
operations, and that the
              interpretation and enforcement of PRC laws could limit the legal
protections
              available to you and the consolidated VIE   s business
operations; and
                Add a cross-reference to    Risk Factors - Risks Related to Our
Corporate Structure   .
6.       We note your revisions in the 20-F/A in response to prior comment 7.
Please enhance
         your disclosure to explain how amounts due under VIE agreements are
settled, quantify
         the cash flows and transfers of other assets by type that have
occurred between the holding
         company, its subsidiaries, and consolidated VIEs, and direction of
transfer other than to
         present cash flow activities between VIEs and Non-VIEs.
7.       We note your revisions in the 20-F/A in response to prior comment 8.
Please address the
         following:

                Present the condensed consolidating schedules on pages 4,
(results of operations and
              cash flows) and 51 together (financial position);
                Include in the condensed consolidating schedules, the financial
position, cash flows
              and results of operations for the parent and any eliminating
adjustments, separately,
              as previously requested;
                Provide a roll-forward of the investment in subsidiaries and
VIEs line item to be
              presented in the parent condensed consolidating schedule; and
                Disclose the entities included in VIEs and Non-VIEs consistent
with your disclosures
              on page F-7.
8.       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
 Yandai Wang
SOS Limited
November 17, 2021
Page 4
         that such approvals are not required, or applicable laws, regulations,
or interpretations
         change and you are required to obtain approval in the future.
Item 3D. Risk Factors, page 7

9.       We note your revisions in the 20-F/A in response to prior comment 11.
Please enhance
         your risk factor disclosure to explain, aside from typical
governmental oversight and
         discretion over the conduct of your business, that the PRC government
may intervene or
         influence your operations at any time, which could result in a
material change in your
         operations and cause the value of your securities to significantly
decline or be worthless.
10.      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.
       You may contact Michelle Miller at 202-551-3368 or Sharon Blume at
202-551-3474 if
you have questions.



FirstName LastNameYandai Wang                                   Sincerely,
Comapany NameSOS Limited
                                                                Division of
Corporation Finance
November 17, 2021 Page 4                                        Office of
Finance
FirstName LastName