United States securities and exchange commission logo

                           April 8, 2022

       Yu-Hsin Lin
       Chief Executive Officer
       5820 Oberlin Drive, Suite 101
       San Diego, CA 92121

                                                        Re: BELITE BIO, INC
Statement on Form F-1
                                                            Filed April 5, 2022
                                                            File No. 333-264134

       Dear Dr. Lin:

              We have reviewed your registration statement and have the
following comment. In our
       comment, we may ask you to provide us with information so we may better
understand your

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to the comment, we may have additional comments.

       Registration Statement on Form F-1

       Risk Factors
       Risks Related to Our Industry, Business and Operations
       In the event that we elect to carry out clinical trials in China and/or
to expand our operations into
       China in the future, page 67

   1.                                                   We note your response
to our prior comment 3 and reissue the comment in part. We also
                                                        note your disclosure on
page 1 that you have received approval to commence patient
                                                        enrollment for a Phase
3 clinical trial in Hong Kong, among other jurisdictions. Given
                                                        your planned clinical
trials in Hong Kong, please revise your disclosure here to also
                                                        discuss the relevant
material risks in the context of your operations in Hong Kong.
 Yu-Hsin Lin
April 8, 2022
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

       You may contact Eric Atallah at 202-551-3663 or Brian Cascio at
202-551-3676 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Ansart at 202-551-4511 or Christine Westbrook at 202-551-5019
with any other

FirstName LastNameYu-Hsin Lin
                                                           Division of
Corporation Finance
Comapany NameBELITE BIO, INC
                                                           Office of Life
April 8, 2022 Page 2
cc:       Portia Ku, Esq.
FirstName LastName