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                               June 28, 2022

       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. 7 to
Registration Statement on Form S-1
                                                            Filed June 10, 2022
                                                            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 May
16, 2022 letter.

       Amendment No. 7 to Form S-1 Filed June 10, 2022

       Prospectus Summary, page 1

   1.                                                   We note your response
to prior comment 5 that you did not seek advice from PRC legal
                                                        counsel in making the
determination whether permissions related to the CAC and the
                                                        CSRC's Overseas Listing
Regulations were required and re-issue the comment in part.
                                                        Please revise the
disclosure in the prospectus to expressly state that you did not rely on the
                                                        advice of counsel in
making this determination and include an explanation as to why you
                                                        did not obtain the
advice of counsel with respect to such determination.
 Jun Wang
Yubo International Biotech Limited
June 28, 2022
Page 2
Risk Factors
You may experience difficulties in effecting service of legal process,
enforcing foreign
judgments..., page 20

2.     We note your revised disclosure in response to prior comment 9 and
re-issue the
       comment. Please expand on your risk factor to note that the fact that
many of your senior
       executive officers and directors reside within China may make it even
more difficult to
       enforce any judgments obtained from foreign courts against such persons
compared to
       other non-U.S. jurisdictions.
       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 Conlon Danberg at 202-551-4466 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
June 28, 2022 Page 2
cc:       Barbara A. Jones, Esq.
FirstName LastName