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                            May 19, 2023

       Wang Huang
       Chief Executive Officer
       Zepp Health Corp
       Huami Global Innovation Center
       Building B2, Zhong   an Chuanggu Technology Park
       No. 900 Wangjiang West Road
       Hefei, 230088
       People   s Republic of China

                                                        Re: Zepp Health Corp
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            Response dated
January 20, 2023
                                                            File No. 001-38369

       Dear Wang Huang:

              We have reviewed your January 20, 2023 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
       January 6, 2023 letter.

       Form 20-F for the fiscal year ended December 31, 2022

       Risks Related to Our Business, page 19

   1.                                                   Please tell us your
consideration of including a risk factor to indicate that your
                                                        investments may be
deemed to be investment securities within the meaning of the
                                                        Investment Company Act
of 1940. Also, clarify the negative impact to your business
                                                        from being deemed an
investment company, including the inability to raise capital through
                                                        the sale of securities
or to conduct business in the United States. Finally, advise what
                                                        consideration you gave
to highlighting any potential liability from being considered an
                                                        investment company
under the Investment Company Act.
 Wang Huang
FirstName
Zepp HealthLastNameWang Huang
            Corp
Comapany
May        NameZepp Health Corp
     19, 2023
May 19,
Page 2 2023 Page 2
FirstName LastName
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections,
page 141

2.       We note your statement that you reviewed public filings and the
Company   s register of
         members in connection with your required submission under paragraph
(a). Please
         supplementally describe any additional materials that were reviewed
and tell us whether
         you relied upon any legal opinions or third party certifications such
as affidavits as the
         basis for your submission. In your response, please provide a
similarly detailed discussion
         of the materials reviewed and legal opinions or third party
certifications relied upon in
         connection with the required disclosures under paragraphs (b)(2) and
(3).
3.       In order to clarify the scope of your review, please supplementally
describe the steps you
         have taken to confirm that none of the members of your board or the
boards of your
         consolidated foreign operating entities are officials of the Chinese
Communist Party. For
         instance, please tell us how the board members    current or prior
memberships on, or
         affiliations with, committees of the Chinese Communist Party factored
into your
         determination. In addition, please tell us whether you have relied
upon third party
         certifications such as affidavits as the basis for your disclosure.
4.       We note that your disclosures pursuant to Items 16I(b)(2), (b)(3) and
(b)(5) are provided
         for    Zepp Health Corporation or the VIEs.    We also note that your
disclosures on pages 5
         and 89 and the list of principal subsidiaries in Exhibit 8.1 indicate
that you have
         consolidated foreign operating entities in Hong Kong and countries
outside China that are
         not included in your VIEs. Please note that Item 16I(b) requires that
you provide
         disclosures for yourself and your consolidated foreign operating
entities, including
         variable interest entities or similar structures.
             With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
              material consolidated foreign operating entities are organized or
incorporated and
              confirm, if true, that you have disclosed the percentage of your
shares or the shares of
              your consolidated operating entities owned by governmental
entities in each foreign
              jurisdiction in which you have consolidated operating entities.
Alternatively, provide
              this information in your supplemental response.
             With respect to (b)(3) and (b)(5), please provide the information
required by (b)(3)
              and (b)(5) for you and all of your consolidated foreign operating
entities in your
              supplemental response.
5.       With respect to your disclosure pursuant to Item 16I(b)(5), we note
that you have included
         language that such disclosure is    to our knowledge   . Please
supplementally confirm
         without qualification, if true, that your articles and the articles of
your consolidated
         foreign operating entities do not contain wording from any charter of
the Chinese
         Communist Party.
       You may contact Morgan Youngwood, Senior Staff Accountant at
202-551-3479 or
Stephen Krikorian, Accounting Branch Chief at 202-551-3488 if you have
questions regarding
comments on the financial statements and related matters. Please contact Jimmy
McNamara at
202-551-7349 or Jennifer Thompson at 202-551-3737 if you have any questions
about comments
 Wang Huang
Zepp Health Corp
May 19, 2023
Page 3

related to your status as a Commission-Identified Issuer during your most
recently completed
fiscal year.



FirstName LastNameWang Huang                               Sincerely,
Comapany NameZepp Health Corp
                                                           Division of
Corporation Finance
May 19, 2023 Page 3                                        Office of Technology
FirstName LastName