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                             July 21, 2023

       Nan Wang
       Chief Financial Officer
       SINOVAC BIOTECH LTD
       No. 39 Shangdi Xi Road
       Haidian District, Beijing 100085

                                                        Re: SINOVAC BIOTECH LTD
                                                            Form 20-F
                                                            Filed May 1, 2023
                                                            File No. 001-32371

       Dear Nan Wang:

              We have reviewed your July 10, 2023 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       June 26, 2023 letter.

       Amendment No. 1 to Annual Report on Form 20-F

       Cash and Asset Flow Through Our Organization, page 2

   1.                                                   We note your response
to prior comment 3 regarding how cash is transferred through your
                                                        organization and
reissue in part. Consistent with your response, please revise your
                                                        disclosure to disclose
(i) Sinovac Antigua did not receive any dividend from its
                                                        subsidiaries and there
was no cash transfer between Sinovac Antigua and its subsidiaries
                                                        in 2022, (ii) Sinovac
Antigua did not distribute any dividend and did not distribute any
                                                        dividend to investors,
including U.S. investors, in 2020, 2021 and 2022, and has no
                                                        intention to distribute
dividends in the near future and (iii) $263.2 million in dividends
                                                        were paid by Sinovac
Life Sciences Co., Ltd. to Sinovac Hong Kong and its other
                                                        shareholders.
       Item 16I. Disclosure Regarding Foreign Jurisdiction that Prevents
Inspection, page 94
 Nan Wang
SINOVAC BIOTECH LTD
July 21, 2023
Page 2

2.    With respect to your disclosure pursuant to Item 16I(b)(5), we note that
you have included
      language that such disclosure is    to our knowledge.    Please
supplementally confirm
      without qualification, if true, that your articles and the articles of
your consolidated
      foreign operating entities do not contain wording from any charter of the
Chinese
      Communist Party.
       You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Doris Stacey Gama at 202-551-3188 or Jason Drory at 202-551-8342 with
any other
questions.



                                                          Sincerely,
FirstName LastNameNan Wang
                                                          Division of
Corporation Finance
Comapany NameSINOVAC BIOTECH LTD
                                                          Office of Life
Sciences
July 21, 2023 Page 2
cc:       Benjamin Su, Esq.
FirstName LastName