TEXT-EXTRACT
2
filename2.txt

                                                           November 5, 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
           Response Letter dated October 23, 2024
           File No. 1-39088
Dear Toby Guanhua Wu:

        We have reviewed your October 23, 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.

Response Letter dated October 23, 2024
Risks relating to doing business in the PRC

1.     We note your response to previous comment 1 with proposed revised
disclosure
       regarding the legal and operational risks associated with doing business
in the PRC.
       We also note that in your August 27, 2024 response letter, you had
proposed to
       include the following disclosure further on in the same paragraph:

       "In particular, the operational risks associated with being based in and
having
       operations in mainland China may also apply to operations in the special
       administrative regions of Hong Kong. With respect to the legal risks
associated with
       being based in and having operations in mainland China, the laws,
regulations and the
       discretion of the governmental authorities in mainland China discussed
in this annual
       report are expected to apply to entities and businesses in mainland
China, rather than
       entities or businesses in Hong Kong which operate under different sets
of laws from
       mainland China. However, the legal risks associated with being based in
and having
       operations in mainland China could apply to the operations in Hong Kong,
if the laws,
       regulations and the discretion of the governmental authorities in
mainland China
 November 5, 2024
Page 2

      become applicable to entities and businesses in Hong Kong in the future."
(emphasis
      added)

      Please confirm you will revise these subsequent statements so that your
disclosure
      expressly states that the legal and operational risks associated in
operating in the PRC
      apply to your present operations in Hong Kong. In this regard, we note
that while the
      proposed language from your October 23, 2024 response letter appears
sufficient to
      highlight the risk that the PRC government may intervene or influence
your
      operations in Hong Kong at any time, the subsequent language quoted above
would
      continue to suggest 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.
      Please contact Conlon Danberg at 202-551-4466 or Margaret Sawicki at
202-551-
7153 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services