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                             March 9, 2023

       Jingwei Zhang
       Chief Financial Officer
       MingZhu Logistics Holdings Limited
       27F Yantian Modern Industry Service Center
       No. 3018 Shayan Road, Yantian District
       Shenzhen, Guangdong, China 518081

                                                        Re: MingZhu Logistics
Holdings Limited
                                                            Amendment No. 4 to
Form 20-F for the fiscal year ended December 31, 2021
                                                            filed March 3, 2023
                                                            Response dated
March 3, 2023
                                                            File No. 001-39654

       Dear Jingwei Zhang:

              We have reviewed your March 3, 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
       February 17, 2023 letter.

       Amendment No. 4 to Form 20-F for the fiscal year ended December 31, 2021

       Financial Statements
       Notes to Consolidated Financial Statements
       Note 2 - Restatement of Previously Issued Financial Statements, page F-9

   1.                                                   We note your revised
disclosures and restatements in response to prior comment 2. We
                                                        note your revised
valuation of 3,189,000 ordinary shares issued in the acquisition of Cheyi
                                                        BVI as purchase
consideration was based on the quoted trading price of $2.12 per share
                                                        on the date of
acquisition. However, it appears you have recorded the revisions in
                                                        purchase consideration
arising from changes in the valuation of shares issued by reducing
                                                        other payables and
accrued liabilities rather than in the statement of changes in
 Jingwei Zhang
MingZhu Logistics Holdings Limited
March 9, 2023
Page 2
         shareholders' equity. Please revise your financial statements and
disclosures as
         appropriate or advise. In addition, please revise the total amount
purchase consideration
         disclosed in notes 1, 12 and 20.
Note 23 - Subsequent events (restatement), page F-35

2.       We note your revised disclosures in response to prior comment 2
relating to the
         acquisition of Yinhua. You disclose that the valuation of 3,826,000
ordinary shares issued
         in the acquisition of Yinhua as purchase consideration was based on
the quoted trading
         price of $1.85 per share on the date of acquisition. Using that price
per share in the
         revised valuation would result in purchase consideration of $8,949,823
(net of 1,126,777
         of cash), with $5,364,709 allocated to goodwill rather than the
$6,397,729 you reported.
         Please revise or advise. In addition, please revise the total amount
of purchase
         consideration paid and per share value disclosed in paragraph 2, as
appropriate.
       You may contact Brian McAllister at (202) 551-3341 or Raj Rajan at (202)
551-3388 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameJingwei Zhang                               Sincerely,
Comapany NameMingZhu Logistics Holdings Limited
                                                              Division of
Corporation Finance
March 9, 2023 Page 2                                          Office of Energy
& Transportation
FirstName LastName