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                                                             September 25, 2024

Toby Guanhua Wu
Chief Financial Officer
Aesthetic Medical International Holdings Group Limited
1122 Nanshan Boulevard
Nanshan District, Shenzhen
Guangdong Province, China 518052

       Re: Aesthetic Medical International Holdings Group Limited
           20-F for Fiscal Year Ended December 31, 2023 File No. 1-39088
           Response Letter dated September 19, 2024
Dear Toby Guanhua Wu:

        We have reviewed your September 19, 2024 response to our comment letter
and have the
following comment. Please respond to this letter within ten business days by
providing the
requested information or advise us as soon as possible when you will respond.
If you do not
believe a comment applies to your facts and circumstances, please tell us why
in your response.
After reviewing your response to this letter, we may have additional comments.
Unless we note
otherwise, any references to prior comments are to comments in our September
10, 2024 letter.

Response Letter dated September 19, 2024
Risks relating to doing business in the PRC

1.     We note your response to previous comment 1 but are unable to agree that
the legal risks
       associated with being in and having operations in mainland China do not
apply to your
       operations in Hong Kong at the current stage. Specifically, please
highlight the risk that
       the PRC government may intervene or influence your operations in Hong
Kong at any
       time, which could result in a material change in your operations and/or
the value of your
       securities or otherwise revise your statement regarding the legal and
operational risks so
       that it is clear that the legal and operational risks associated in
operating in the PRC apply
       to your present operations in Hong Kong.




       Please contact Conlon Danberg at 202-551-4466 or Margaret Sawicki at
202-551-7153
with any questions.
 September 25, 2024
Page 2



                     Sincerely,

                     Division of Corporation Finance
                     Office of Industrial Applications and
                     Services