March 12, 2020

Dong Hu
Chief Executive Officer
Ebang International Holdings Inc.
26-27F, Building 3
Xinbei Qianjiang International Building
Qianjiang Economic and Technological Development Zone
Yuhang District, Hangzhou, Zhejiang
People's Republic of China

       Re: Ebang International Holdings Inc.
           Draft Registration Statement on Form F-1
           Submitted February 14, 2020
           CIK No. 0001799290

Dear Mr. Hu:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so we may
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Draft Registration Statement on Form F-1 submitted February 14, 2020

Prospectus Summary, page 2

1.     Please briefly describe the trends related to Bitcoin price drop, market
demand of your
       machines and retail prices of those machines that began in 2018, as
mentioned on page
       13 and the impact on your business. Please also disclose whether those
trends have
       continued to date.
 Dong Hu
FirstName LastNameDong HuInc.
Ebang International Holdings
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Implications of Being an Emerging Growth Company, page 4

2.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you or anyone authorized to do
so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
Capitalization Table, page 62

3.       We note from the notes to the financial statements that as of
September 30, 2019 you had
         $14.9 million of related party debt due during 2022. In light of the
fact that these are long
         term debt arrangements, please revise your Capitalization table to
include these
         obligations. You should also consider including subsequently issued
debt in the "as
         adjusted" column of your Capitalizaiton table.
Enforceability of Civil Liabilities, page 65

4.       We note your disclosure on page 48 and in this section that you have
been advised by your
         counsel with respect to Peoples Republic of China law matters and your
disclosure in this
         section that you have been advised by your counsel with respect to
Cayman Islands law
         matters. Please confirm that the consents you intend to file will
include each counsel's
         consent to these references.

Key Factors Affecting Our Results of Operations
Expansion and diversification of our product offerings, page 76

5.       You disclose that you intend to commence a cryptocurrency mining
business by the third
         quarter of 2020. Please describe any material costs incurred to date
as part of your
         preparation to enter this new line of business.
Service - Management and Maintenance, page 80

6.       You disclose that your mining machine hosting services are primarily
provided to buyers
         of your Bitcoin mining machines. Please expand your disclosure to
discuss the material
         details of hosting services provided to other customers who have not
purchased your
         mining machines. In your response also tell us whether those customers
supply their own
         mining machine or, if true, have the option to lease the Bitcoin
mining machines from
         you. Also, please tell us if the machine hosting services provided
with the purchase of a
         Bitcoin mining machine are done under separate contract or are part of
the contract to
         purchase a Bitcoin mining machine.
 Dong Hu
FirstName LastNameDong HuInc.
Ebang International Holdings
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Results of Operations
Cost of revenues
General and Administrative Expenses, page 82

7.       We note in your general and administrative expenses section the
material decline in your
         research and development expenses between the year ended December 31,
2018 and the
         nine months ended September 30, 2019. While we acknowledge your
general disclosures
         about the adverse effect downward Bitcoin pricing has on your
business, it is not entirely
         clear to us whether this would be a key driver in R&D activity. Please
expand your
         disclosure to include a narrative accompaniment that offers further
details regarding
         material changes in the items presented. Please refer to Item 303 of
Regulation S-K and
         the Commission s Guidance Regarding Management s Discussion and
Analysis of
         Financial Condition and Results of Operations, SEC Release No.

Internal Control Over Financial Reporting, page 90

8.       We note your remediation plan for the two identified material
weaknesses in your internal
         control over financial reporting. Please disclose your estimated costs
to complete the
         related remediation plan, if material.
Contractual Obligations and Commitments, page 91

9.       Please revise the table in this section to set forth your commitments
as of the latest fiscal
         year end balance sheet date. For guidance, see Item 5.F.1 of Form
Our Strategies, page 107

10.      We note your disclosure that you intend to provide cryptocurrency
trading related
         services. Please elaborate on the types of trading services that you
intend to provide.
         Please disclose any governmental regulations, any material risks or
challenges related to
         such services.
After-Sales Services and Warranties, page 115

11.      You disclose that you provide warranties on your mining machines.
Please tell us your
         current warranty liability and provide a tabular reconciliation of the
changes in your
         aggregate product warranty liability for the reporting periods, in the
notes to your
         financial statements, to comply with the disclosure requirements of
ASC 460-10-50-8(c)
         or explain why the amount of loss cannot be reasonably estimated.
Also, we note your
         disclosure on page 115 that during the warranty period, maintenance
and after-sale
         services are provided by you, which includes technical support,
equipment repair and
         maintenance. Please tell us if you account for the services provided
under the warranty as
 Dong Hu
FirstName LastNameDong HuInc.
Ebang International Holdings
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         a separate performance obligation and if so, how you allocate the
transaction price to the
         product and service. See guidance in ASC 606-10-55-34.
Intellectual Property, page 116

12.      We note your reference to licensing agreements in the first paragraph
on page 117. Please
         disclose the scope and term of any material license agreement and file
any material license
         agreements as exhibits to your registration statement. Please also
disclose the duration and
         scope of patents that are material to your business.
Leased Properties, page 118

13.      Please disclose when your material leases expire and file any material
lease agreements as
         exhibits to your registration statement.

Related Party Transactions
Private Placements, page 142

14.      We note the information provided on Note 11   Shareholders' equity.
Please revise to
         disclose the consideration the company received in connection with
these issuances. With
         respect to each entity discussed in this section, please expand to
disclose the nature of
         your relationship that would give rise to the entity being considered
a related party.
Lock-Up Agreements, page 171

15.      Please file the lock-up agreements as exhibits to the registration
statement. Refer to Item
         601(b)(10) of Regulation S-K.
Audited Financial Statements
Consolidated Statements of Operations and Comprehensive Loss, page F-4

16.      We note from your disclosure in Note 14 that service revenue was
greater than 10% of
         total revenue for the nine months ended 9/30/19. Please revise to
separately disclose
         product and service on face of your statements of operations in
accordance with Rule 5-
         03(b) of Regulation S-X.
17.      We note your presentation of Value-added tax refund as an offset to
operating expenses
         on the face of your statements of income and comprehensive loss.
Please tell us why you
         believe it is appropriate to present this amount within your loss from
operations or
         alternatively, please revise to disclose the refund below the subtotal
for loss from
Revenue Recognition, page F-13

18.      We note your disclosure on page 73 of MD&A that the Bitcoin price drop
in 2018 also led
         to your offering of credit sales to certain significant, long-standing
customers in China,
 Dong Hu
FirstName LastNameDong HuInc.
Ebang International Holdings
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         instead of full prepayment before delivery of products. Please expand
your revenue
         recognition disclosure in Note 2 to the financial statements to
disclose your payment terms
         as well as the existence of any significant financing components in
accordance with ASC
         606-10-50-12. Also, we note from page 13 that this price drop
adversely impacted the
         ability of your customers who purchased products on credit to make
payments and you
         consider such portion of payment as implicit price concession and
retroactively adjusted
         your revenue based on such subsequent information. Please tell us how
you estimate the
         amount of implicit price concessions when determining variable
consideration for these
         contracts. See guidance in ASC 606-10-32-7. Additionally, please
explain to us how you
         distinguish between price concessions (i.e., reductions of revenue)
and customer credit
         risk relating to collectability (i.e., bad debt expense) that may be
known at contract
         inception when accounting for your credit sales contracts. Cite the
accounting guidance on
         which you base your conclusions.
Notes to consolidated financial statements
Contingencies, page F-26

19.      We note your disclosure of a civil action, filed by your customer, in
the Hangzhou
         Intermediate People's Court in December 2017 regarding the performance
of 500 units of
         mining machines. You also have disclosed the court's requirement that
you were to
         restrict cash in various amounts. To help us better understand your
disclosures tell us
         what amounts of restricted cash are currently ordered by the courts.
In addition, please
         explain why you are not able to estimate probable losses in light of
the damages already
         awarded by the court.
20.      Please revise your disclosures in Note 17 to disclose all amounts in
US dollars, your
         reporting currency. Your disclosure in the Legal Proceedings section
on page 119 should
         be similarly revised.
Exhibits and Financial Statement Schedules, page II-2

21.      You disclose on page 92 that you operate primarily in China. In
addition, on page F-24,
         you disclose significant restricted net assets. Please provide
Parent-only financial
         statements pursuant to Rule 5-04 of Regulation S-X or tell us why you
are not required to
         do so.

22.      Please update your exhibit index to include employment contracts
required by Item
         601(b)(10) of Regulation S-K, as contemplated by Item 8 of Form F-1,
rather than a "form
         of" employment agreement. In the alternative, please tell us if these
agreements are not
         required to be publicly filed in your home country, are not otherwise
publicly disclosed,
         and therefore are not filed based on Item 601(b)(10)(iii)(C)(5) of
Regulation S-K.
       You may contact Charles Eastman, Staff Accountant, at 202-551-3794 or
Claire Erlanger,
Senior Accountant, at 202-551-3301 if you have questions regarding comments on
the financial
 Dong Hu
Ebang International Holdings Inc.
March 12, 2020
Page 6

statements and related matters. Please contact Thomas Jones, Staff Attorney, at
202-551-3602 or
Asia Timmons-Pierce, Special Counsel, at 202-551-3754 with any other questions.

FirstName LastNameDong Hu
                                                          Division of
Corporation Finance
Comapany NameEbang International Holdings Inc.
                                                          Office of
March 12, 2020 Page 6
cc:       Weiheng Chen, Esq.
FirstName LastName