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                               October 27, 2020

       Shuibo Zhang
       Chief Executive Officer
       Jiuzi Holdings, Inc.
       4F No. 1 Building, Jinsha Lake Business Center
       Economic Technology District
       Hangzhou, Zhejiang, 311103
       People   s Republic of China

                                                        Re: Jiuzi Holdings,
Inc.
                                                            Amendment No. 1 to
                                                            Registration
Statement on Form F-1
                                                            Filed October 13,
2020
                                                            File No. 333-248416

       Dear Mr. Zhang:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 14, 2020 letter.

       Amendment No. 1 to Form F-1 Filed October 13, 2020

       Establish display centers and distribution centers, page 51

   1.                                                   We note your response
to prior comment 5. Please revise your summary to disclose that
                                                        you do not have any
specific or immediate plans to build distribution centers. In addition,
                                                        please revise where
appropriate to disclose how you intend to use the portion of your
                                                        offering proceeds that
are allotted to developing distribution centers. In this regard, please
                                                        disclose the amount of
proceeds that you will use for these projects and significant
 Shuibo Zhang
Jiuzi Holdings, Inc.
October 27, 2020
Page 2
       milestones and their related costs. To the extent that the distribution
centers are not a
       priority, please revise your use of proceeds accordingly.
Franchise Arrangement and Business Model, page 52

2.     We note your response to prior comment 7. In the bulleted disclosure at
the bottom of
       page 52, you disclose the "franchise fee" for five different periods, or
phases, of a store
       launch. Please tell us whether the term "franchise fee" refers to the
expected operational
       costs associated with each period or the actual fee payable to the
franchisor during each
       period. If your disclosure refers to the operational costs incurred by
the franchisor during
       each period, please revise your disclosure for clarity. In this regard,
we note that a
       "franchise fee" is the typically understood to be the fee payable by the
franchisee to the
       franchisor and should only be used in your disclosure in this manner.
Additionally, please
       revise your added disclosure at page 53 to disclose the terms of your
cooperation or
       partnership agreements with preferred lenders, if material.
       You may contact Keira Nakada at (202) 551-3659 or Rufus Decker at (202)
551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Morris at (202) 551-3314 or Mara Ransom at (202) 551-3264 with
any other
questions.



                                                              Sincerely,
FirstName LastNameShuibo Zhang
                                                              Division of
Corporation Finance
Comapany NameJiuzi Holdings, Inc.
                                                              Office of Trade &
Services
October 27, 2020 Page 2
cc:       William Rosenstadt
FirstName LastName