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                              July 5, 2023

       Xiaowu He
       Chief Executive Officer
       Scienjoy Holding Corp
       RM 1118, 11 th Floor, Building 3,
       No. 99 Wangzhou Rd ., Liangzhu St .
       Yuhang District , Hangzhou ,
       Zhejiang Province, 311113 , China

                                                        Re: Scienjoy Holding
Corporation
                                                            Form 20-F filed
April 28, 2023
                                                            Form 20-F/A filed
May 12, 2023
                                                            File No. 001-38799

       Dear Xiaowu He:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

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

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F/A filed on May 12, 2023

       Controls and procedures, page 1

   1.                                                   We note your disclosure
that management has determined that your internal control over
                                                        financial reporting (
ICFR   ) was not effective as of December 31, 2022 due to certain
                                                        material weaknesses.
However, we also note your disclosure that your management, with
                                                        the participation of
your chief executive officer and chief financial officer, has concluded
                                                        that disclosure
controls and procedures (   DCP   ) were effective as of the end of the period
                                                        covered by this report.
Please explain to us how you concluded DCP were effective while
                                                        ICFR was determined not
to be effective.
       Form 20-F filed on April 28, 2023

       Introduction, page iii
 Xiaowu He
Scienjoy Holding Corp
July 5, 2023
Page 2

2.       At the onset of introduction, please disclose prominently that you are
not a Chinese
         operating company but a British Virgin Islands holding company with
operations
         conducted by your subsidiaries and through contractual arrangements
with a variable
         interest entity (VIE) based in China and that this structure involves
unique risks to
         investors. Explain whether the VIE structure is used to replicate
foreign investment in
         Chinese-based companies where Chinese law prohibits direct foreign
investment in the
         operating companies, and disclose that investors may never directly
hold equity interests
         in the Chinese operating company. Your disclosure should acknowledge
that Chinese
         regulatory authorities could disallow this structure, which would
likely result in a material
         change in your operations and/or value of your common stock, including
that it could
         cause the value of such securities to significantly decline or become
worthless.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

        You may contact Becky Chow, Staff Accountant at 202-551-6524, or
Stephen Krikorian,
Accounting Branch Chief, at 202-551-3488 if you have questions regarding
comments on the
financial statements and related matters.



FirstName LastNameXiaowu He                                    Sincerely,
Comapany NameScienjoy Holding Corp
                                                               Division of
Corporation Finance
July 5, 2023 Page 2                                            Office of
Technology
FirstName LastName