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United States securities and exchange commission logo





                             May 17, 2024

       Tiewei Song
       Chief Executive Officer
       BIMI Holdings Inc.
       9th Floor, Building 2
       Chongqing Corporation Avenue
       Yuzhong District, Chongqing,
       P. R. China, 400010

                                                        Re: BIMI Holdings Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Correspondence
dated May 8, 2024
                                                            File No. 001-34890

       Dear Tiewei Song:

              We have reviewed your May 8, 2024 response to our comment letter
and have the
       following comment(s).

              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 March 7,
       2024 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Regulation of Overseas Listing, page 19

   1.                                                   Please further revise
your disclosure to affirmatively state whether the holding company
                                                        and its subsidiaries
are covered by permissions requirements from the CSRC. Clarify
                                                        whether you relied upon
an opinion of counsel in that determination, and if not, explain
                                                        why. In this regard,
your proposed disclosure only speaks to your subsidiaries, and it does
                                                        not explicitly state if
you have determined the regulations apply to the holding company
                                                        and its subsidiaries or
not.
 Tiewei Song
BIMI Holdings Inc.
May 17, 2024
Page 2

        Please contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at
202-551-3336
if you have questions regarding comments on the financial statements and
related matters. Please
contact Taylor Beech at 202-551-4515 or Mara Ransom at 202-551-3264 with any
other
questions.



                                                           Sincerely,
FirstName LastNameTiewei Song
                                                           Division of
Corporation Finance
Comapany NameBIMI Holdings Inc.
                                                           Office of Trade &
Services
May 17, 2024 Page 2
cc:       Pang Zhang-Whitaker
FirstName LastName