April 23, 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. Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted April 10, 2020 CIK No. 0001799290 Dear Mr. Hu: We have reviewed your amended 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 better 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 comments. Amendment No. 2 to Draft Registration Statement on Form F-1 submitted April 10, 2020 General 1. Please ensure that the opinion of your PRC counsel includes discussion of the new PRC Foreign Investment Law that took effect on January 1, 2020 and the extent that it may be applicable to and have material effects on any of your PRC businesses. Include disclosure, as necessary, under the risk factors and regulations sections of the filing. 2. Please revise the annex of the opinion to present the names in English or revise the body of the opinion to explicitly name, in English, each of the entities referenced. You may Dong Hu Ebang International Holdings Inc. April 23, 2020 Page 2 also revise your opinion to qualify the extent that the referenced annex includes all of your PRC entities. 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 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. Sincerely, FirstName LastNameDong Hu Division of Corporation Finance Comapany NameEbang International Holdings Inc. Office of Manufacturing April 23, 2020 Page 2 cc: Weiheng Chen, Esq. FirstName LastName