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                              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.
 Erqi Wang
FirstName
Jin MedicalLastNameErqi   Wang
            International Ltd.
Comapany 16,
November   NameJin
               2021 Medical International Ltd.
November
Page 2     16, 2021 Page 2
FirstName LastName
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.
 Erqi Wang
FirstName
Jin MedicalLastNameErqi   Wang
            International Ltd.
Comapany 16,
November   NameJin
               2021 Medical International Ltd.
November
Page 3     16, 2021 Page 3
FirstName LastName
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.
 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,
FirstName LastNameErqi Wang
                                                              Division of
Corporation Finance
Comapany NameJin Medical International Ltd.
                                                              Office of Life
Sciences
November 16, 2021 Page 4
cc:       Ying Li
FirstName LastName