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                           January 6, 2023

       David Hui Shao
       Chief Executive Officer
       YishengBio Co., Ltd
       Building No. 2, 38 Yongda Road
       Daxing Biomedical Industry Park
       Daxing District, Beijing, PRC

                                                        Re: YishengBio Co., Ltd
                                                            Registration
Statement on Form F-4
                                                            Filed December 28,
2022
                                                            File No. 333-269031

       Dear David Hui Shao:

              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.

       Registration Statement on Form F-4 filed December 28, 2022

       Summary Unaudited Pro Forma Condenced Combined Financial Information
       Summary Unaudited Pro Forma Condensed Combined Balance Sheet Data As of
March 31,
       2022, page 55

   1.                                                   Please remove your
presentation for the Summary Unaudited Pro Forma Condensed
                                                        Combined Balance Sheet
Data as of March 31, 2022 since it is no longer included in your
                                                        unaudited pro forma
condensed combined financial information section starting at page
                                                        329.
 David Hui Shao
FirstName
YishengBioLastNameDavid Hui Shao
            Co., Ltd
Comapany
January    NameYishengBio Co., Ltd
        6, 2023
January
Page 2 6, 2023 Page 2
FirstName LastName
Unaudited Pro Forma Condensed Combined Financial Information, page 329

2.       Please address the following comments related to your pro forma
presentations:

                Explain to us why you used Summit financial statements as of
and for the interim and
              full fiscal periods ended June 30, 2022 as the pro forma
historical balances, even
              though both companies have updated their financial statements
periods to September
              30, 2022. Refer to Rule 11-02(c)(3) of Regulation S-X. Revise if
necessary.
                Explain why you have reverted to characterizing the business
combination as a
              reverse recapitalization, despite the revisions made in response
to comment 42 in our
              letter dated October 30, 2022.
                We note your response to our prior comment 7 and your revisions
to reclassify both
              the public warrants and private placement warrants from liability
to equity. Please
              note that our prior comment was specific to the public warrants
only. If you believe
              the private placement warrants should also be reclassified to
equity in your pro forma
              financial statements, please provide us with your analysis under
ASC 815-40. As part
              of your analysis, please address whether there are any terms or
provisions in the
              warrant agreement that provide for potential changes to the
settlement amounts that
              are dependent upon the characteristics of the holder of the
warrant, and if so, how you
              analyzed those provisions in accordance with the guidance in ASC
815-40. We also
              refer you to the April 2021 Staff Statement on Accounting and
Reporting
              Considerations for Warrants Issued by SPACs.
                As a related matter, since the public warrants would have been
equity classified upon
              the consummation of the business combination, please tell us how
you have
              considered whether their related fair value changes as presented
in the pro forma
              statement of operations should have also been eliminated giving
effect as if the
              business combination had occurred at the beginning of the
statement of operation
              periods.
                Lastly, please revise to also present the net loss per share
information for the fiscal
              year ended March 31, 2022 in the table under Note 4 Net Loss per
Share at page 339.
YishingBio Co., Ltd Unaudited Condensed Consolidated Statements of Cash Flows,
page F-84

3.       Please revise your balances for the net decrease in cash and
restricted cash to include the
         effect of foreign exchange rate on cash.
        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.
 David Hui Shao
YishengBio Co., Ltd
January 6, 2023
Page 3

       You may contact Li Xiao at 202-551-4391 or Angela Connell at
202-551-3426 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jimmy McNamara at 202-551-7349 or Jason Drory at 202-551-8342 with any
other
questions.



                                                         Sincerely,
FirstName LastNameDavid Hui Shao
                                                         Division of
Corporation Finance
Comapany NameYishengBio Co., Ltd
                                                         Office of Life
Sciences
January 6, 2023 Page 3
cc:       Dan Ouyang, Esq.
FirstName LastName