Dykema Gossett PLLC 111 E. Kilbourn Ave. Suite 1050 Milwaukee, WI 53202 www.dykema.com Tel: 414-488-7300
		Kate Bechen Direct Dial: (414) 488-7333 Email: KBechen@dykema.com

August 1, 2025

U.S. Securities and Exchange Commission

Division of Corporate Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attention: Daniel Crawford, Tim Buchmiller, Tracie

Mariner, and Kevin Vaughn

Dear Mr. Crawford, Mr. Buchmiller, Ms. Mariner and Mr. Vaughn:

This response letter (this “Response”) is submitted on behalf of Scienture Holdings, Inc. (the “Company”) in response to the comments that the Company received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) in a letter addressed to Dr. Narasimhan Mani, dated July 24, 2025 (the “Comment Letter”), with respect to the Company’s Draft Registration Statement on Form S-3 (the “Draft Registration Statement”), confidentially submitted with the SEC on July 8, 2025. The Company concurrently is filing a Form S-3 (the “Registration Statement”), which reflects the changes discussed in this Response that the Company made to address the Staff’s comments and other updates.

For reference purposes, each of the Staff’s numbered comments from the Comment Letter is set forth in bold text below, followed by the Company’s response to each comment. The responses below are based on information provided to Dykema Gossett PLLC by the Company.

Draft Registration Statement on Form S-3

Exhibits

Response: In response to the Staff’s comments, the Company has filed a form of indenture as Exhibit 4.5 to the Registration Statement.

Thank you for your review and consideration of the matters set forth in this Response and in the Registration Statement. If you have any questions, please contact the undersigned at (414) 488-7333 or KBechen@dykema.com.