United States securities and exchange commission logo

                             June 30, 2022

       Lei Chen
       Chief Financial Officer
       Ebang International Holdings Inc.
       Building 7, No. 5 Nangonghe Road, Linping Street
       Yuhang District, Hangzhou, Zhejiang, 311100
       People's Republic of China

                                                        Re: Ebang International
Holdings Inc.
                                                            Form 20-F for the
Year Ended December 31, 2021
                                                            File No. 001-39337

       Dear Mr. Chen:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for the Year Ended December 31, 2021

       Exhibit 12.1 and 12.2 Certifications Pursuant to Section 302 of the
Sarbanes Oxley Act, page 1

   1.                                                   We note from Item 15B
of your Form 10K, that management has evaluated and concluded
                                                        on the effectiveness of
your internal control over financial reporting as of December 31,
                                                        2021 and you have
included management's report on page 133. In light of the fact that
                                                        you have included
management's report on ICFR in your filing, we believe that your
                                                        certifications pursuant
to Section 302 of the Sarbanes Oxley Act should include paragraph
                                                        4(b). In this regard,
paragraph 4(b) should be included to disclose that management has
                                                        "designed such internal
control over financial reporting, or caused such internal control
                                                        over financial
reporting to be designed under our supervision, to provide reasonable
                                                        assurance regarding the
reliability of financial reporting and the preparation of financial
                                                        statements for external
purposes in accordance with generally accepted accounting
                                                        principles." Please
revise accordingly.
 Lei Chen
FirstName  LastNameLei  ChenInc.
Ebang International Holdings
June       NameEbang International Holdings Inc.
     30, 2022
June 30,
Page 2 2022 Page 2
FirstName LastName

Item 3. Key Information, page 1

2.       At the onset of Item 3, provide a clear description of how cash is
transferred through your
         organization and disclose your intentions to distribute earnings or
settle amounts owed
         under applicable agreements. State whether any transfers, dividends,
or distributions have
         been made to date between the holding company, its subsidiaries and
         entities, or to investors, and quantify the amounts where applicable.
Part I, page 1

3.       At the onset of Part I, please revise to disclose prominently the
             whether your auditor is subject to the determinations announced by
the PCAOB on
             December 16, 2021;
             whether and how the Holding Foreign Companies Accountable Act, the
             Holding Foreign Companies Accountable Act, and related regulations
will affect your
             company, including the time frame change in PCAOB inspections for
             consecutive years instead of three years;
             whether you have been or expect to be identified by the Commission
under the
             HFCAA; and
             a cross-reference to your more detailed disclosure in your risk
factors, including the
             heading of the risk factor.
4.       At the onset of Part I, please disclose prominently that you are not a
Chinese operating
         company but a Cayman Islands holding company with operations conducted
by your
         subsidiaries based in China and that this structure involves unique
risks to investors. If
         true, disclose that these contracts have not been tested in court.
Provide a cross-reference
         to your detailed discussion of risks facing the company as a result of
this structure.
5.       At the onset of Part I, clearly disclose how you will refer to the
holding company,
         subsidiaries, and other entities when providing the disclosure
throughout the document so
         that it is clear to investors which entity the disclosure is
referencing and which
         subsidiaries or entities are conducting the business operations.
Refrain from using terms
         such as    we    or    our    when describing activities or functions
of a subsidiary or other
         entity. For example, disclose, if true, that your subsidiaries and/or
other entities conduct
         operations in China, that the other entity is consolidated for
accounting purposes but is not
         an entity in which you own equity, and that the holding company does
not conduct
         operations. Disclose clearly the entity (including the domicile) in
which investors are
         purchasing an interest.
Notes to the Financial Statements
Note 3. Short-term Investments, page F-17

6.       We note from your disclosure in Note 2 on page F-10, that short-term
investments consist
         of investments in marketable securities which are accounted for under
ASC 321. Please
 Lei Chen
Ebang International Holdings Inc.
June 30, 2022
Page 3
         revise to include the disclosures required by ASC 321-10-50, which
include disclosure of
         the portion of unrealized gains and losses for the period that relates
to equity securities
         still held at the reporting date. Also, we note your disclosure that
you hold debt classified
         investments that are recorded as available for sale securities. Please
revise to include the
         disclosures required by ASC 320-10-50-2.

7.       As it appears your officers and directors are located in China, please
include a
         separate    Enforceability of Civil Liabilities    section which
discloses the difficulty of
         bringing actions and enforcing judgements against these individuals.
This section should
         include disclosures consistent with your Risk Factor disclosure on
page 49.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Claire Erlanger at (202) 551-3301 or Jean Yu at (202)
551-3305 with
any questions.

FirstName LastNameLei Chen                                      Sincerely,
Comapany NameEbang International Holdings Inc.
                                                                Division of
Corporation Finance
June 30, 2022 Page 3                                            Office of
FirstName LastName