QDMI QDM International

Filed: 8 Apr 21, 8:00pm


QDM International Inc.

7th Floor, Building 5A

Room 715, 7F, The Place Tower C, No. 150 Zunyi Road

Changning District, Shanghai, China 200051


April 9, 2021




Tonya K. Aldave

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, NE

Washington, D.C. 20549


 Re: QDM International Inc.
   Registration Statement on Form S-1
   Initially filed February 10, 2021, as amended
   File No. 333-252967



Dear Ms. Aldave:


Pursuant to Rule 461 under the Securities Act of 1933, as amended, QDM International Inc. hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become effective at 4:00 p.m. ET on Tuesday, April 13, 2021, or as soon as thereafter practicable.


Very truly yours,
/s/ Huihe Zheng
Huihe Zheng
President and Chief Executive Officer


cc: Ellenoff Grossman & Schole LLP