United States securities and exchange commission logo





                            July 26, 2021

       Jun Wang
       Chief Executive Officer
       Yubo International Biotech Limited
       Room 105, Building 5, 31 Xishiku Avenue
       Xicheng District, Beijing, China

                                                        Re: Yubo International
Biotech Limited
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed July 12, 2021
                                                            File No. 333-255805

       Dear Mr. Wang:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
[Month day, year] letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Dilution, page 24

   1.                                                   We note your response
to prior comment 19. Please expand to disclose the average price
                                                        per share paid by
shareholders in connection with the reverse merger.
       Business
       Our Service and Products
       Endometrial Stem Cell Bank, page 31

   2.                                                   We note the revisions
you made in response to prior comment 26 describing the current
                                                        stage of development of
your stem cell bank. Please revise to clarify whether there are
                                                        any remaining material
regulatory and/or operational steps necessary to complete the stem
 Jun Wang
FirstName  LastNameJun   Wang
Yubo International Biotech Limited
Comapany
July       NameYubo International Biotech Limited
     26, 2021
July 26,
Page  2 2021 Page 2
FirstName LastName
         cell bank and your anticipated timeline. If your timeline is not
known, so state.
Light Application Products, page 32

3.       We note your response to prior comment 24. For each of your light
application products
         that you indicate you plan to launch in the near future, please expand
your disclosure to
         describe the respective current stage of development and the material
remaining steps to
         bring each product to market.
Results of Operations, page 49

4.       Please revise your disclosures to address the following for each of
the periods presented,
         as applicable:
             Separately quantify the sales increase from the sale of nebulizers
and
             the basidiomycetes compound drink.
             Separately quantify the increase in operating expenses from sales
commissions,
             employee compensation, occupancy, and other operating expenses. In
this regard,
             please provide a table that breaks down your operating expenses
for the period ended
             March 31, 2021 and 2020 similar to the one you provided for the
years ended
             December 31, 2020 and 2019. In addition, for all periods
presented, further explain in
             detail the reasons for the increase/decrease from prior periods
for each of the line
             items presented in the table. For example, clarify why employee
compensation
             increased from the prior periods.
             Regarding operating expenses for the year ended December 31, 2020,
disclose the
             types of costs that are included in this line item that ties to
the $737,489 in other
             operating expense recorded besides $40,000 in research and
development expenses.
Yubo International Biotech Limited
Notes To Consolidated Financial Statements
For the Three-Month Periods Ended March 31, 2021 and 2020
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-30

5.       Your revenue recognition policy disclosure here appears to use the
language of the former
         accounting guidance, ASC 605. Please confirm to us whether your
revenue recognition
         policies for the periods presented comply with the current accounting
literature, ASC 606.
         If true, revise to discuss your revenue recognition accounting policy
under ASC 606 and
         provide the required disclosures. Accordingly, revise your disclosures
under the headings
         "New Accounting Pronouncements" in your notes to the financial
statements and
         "Revenue Recognition" under the Critical Accounting Policy and
Estimates disclosure on
         page 49 as well.
 Jun Wang
Yubo International Biotech Limited
July 26, 2021
Page 3

       You may contact Sasha Parikh at 202-551-3627 or Lynn Dicker at
202-551-3616 if you
have questions regarding comments on the financial statements and related
matters. Please
contact David Gessert at 202-551-2326 or Christine Westbrook at 202-551-5019
with any other
questions.



                                                         Sincerely,
FirstName LastNameJun Wang
                                                         Division of
Corporation Finance
Comapany NameYubo International Biotech Limited
                                                         Office of Life
Sciences
July 26, 2021 Page 3
cc:       Mark C. Lee, Esq.
FirstName LastName