September 10, 2024

Dajun Yang
Chairman and Chief Executive Officer
Ascentage Pharma Group International
68 Xinqing Road
Suzhou Industrial Park
Suzhou, Jiangsu
China

       Re: Ascentage Pharma Group International
           Amendment No. 2 to Draft Registration Statement on Form F-1
           Submitted August 27, 2024
           CIK No. 0002023311
Dear Dajun Yang:

     We have reviewed your amended draft registration statement and have the
following
comments.

        Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do
not believe an
amendment is appropriate, please tell us why in your response.

        After reviewing the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional
comments. Unless we note otherwise, any references to prior comments are to
comments in our
August 15, 2024, letter.

Amendment No. 2 to Draft Registration Statement on Form F-1 submitted August
27, 2024
Prospectus Summary
Overview, page 1

1.     We note your response to our prior comment 4 and we resissue the comment
in
       part. Please remove the statement that you are engaged in discovering,
developing and
       commercializing both "first- and best-in-class" therapies from the first
sentence of the
       Prospectus Summary, MD&A and Business sections. Given the current stage
of
       development of the company   s products, such claim appears speculative
and premature.
2.     We note your response to our prior comment 5 and the related revisions
to your
 September 10, 2024
Page 2

       disclosure. Please further revise your disclosure to specifically name
the countries or
       regions in which regulatory trials are currently taking place.
Financial Statements
Notes to unaudited interim condensed consolidated financial information, page
F-75

3.     Please update the notes to your financial statements to disclose your
accounting policy for
       licenses of intellectual property.
       Please contact Eric Atallah at 202-551-3663 or Angela Connell at
202-551-3426 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tamika Sheppard at 202-551-8346 or Laura Crotty at 202-551-7614 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   David Sharon