December 11, 2018

Jonas Grossman
Chief Executive Officer
Chardan Healthcare Acquisition Corp.
17 State Street, 21st Floor
New York, NY 10004

       Re: Chardan Healthcare Acquisition Corp.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed December 4, 2018
           File No. 333-228533

Dear Mr. Grossman:

        We have reviewed your amended registration statement and have the
following
comments. In some of our comments we may ask you to provide us information so
that 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 that our comments apply to your
facts and
circumstances or do not believe that 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.

Pre-effective Amendment 1 to Registration Statement on Form S-1 filed December
4, 2018

Exhibit 3.2, page 6

1.     We note that your forum selection provision identifies the Court of
Chancery of the State
       of Delaware as the exclusive forum for certain litigation, including any
"derivative
       action." Please disclose whether this provision applies solely to state
law claims. If it
       does not apply to solely state law claims, then please note that Section
27 of the Exchange
       Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
       liability created by the Exchange Act or the rules and regulations
thereunder, and Section
       22 of the Securities Act creates concurrent jurisdiction for federal and
state courts over all
       suits brought to enforce any duty or liability created by the Securities
Act or the rules and
       regulations thereunder. If this provision applies to claims arising
under the Securities Act,
       please disclose that there is uncertainty as to whether a court would
enforce such
 Jonas Grossman
Chardan Healthcare Acquisition Corp.
December 11, 2018
Page 2
         provision and to state that shareholders will not be deemed to have
waived the company's
         compliance with the federal securities laws and the rules and
regulations thereunder. If
         this provision does not apply to actions arising under the Securities
Act or Exchange Act,
         please ensure that the exclusive forum provision in the governing
documents states this
         clearly.

         In addition, under an appropriately titled risk factor please describe
the exclusive forum
         provision and the types of actions to which it relates, and disclose
that such a provision
         may limit a shareholder's ability to bring a claim in a judicial forum
that it finds favorable
         for disputes with the company and its directors, officers, or other
employees and may
         discourage lawsuits with respect to such claims.
        You may contact Dale Welcome, Staff Accountant, at (202) 551-3865 or W.
John Cash,
Accounting Branch Chief, at (202) 551-3768 if you have questions regarding
comments on the
financial statements and related matters. Please contact Edward M. Kelly,
Senior Counsel, at
(202) 551-3728 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with
any other
questions.



                                                                Sincerely,
FirstName LastNameJonas Grossman
                                                                Division of
Corporation Finance
Comapany NameChardan Healthcare Acquisition Corp.
                                                                Office of
Manufacturing and
December 11, 2018 Page 2                                        Construction
FirstName LastName