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United States securities and exchange commission logo
November 21, 2023
Pun Leung Liu
Chief Financial Officer
YXT.COM Group Holding Limited
Floor 20, Building 2, No. 209, Zhuyuan Road
High-tech District, Suzhou,
Jiangsu, 215011, People s Republic of China
Re: YXT.COM Group
Holding Limited
Amendment No. 8 to
Draft Registration
Statement on Form F-1
Submitted October
30, 2023
CIK No. 0001872090
Dear Pun Leung Liu:
We have reviewed your amended draft registration statement and have
the following
comments.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to this
letter and your amended
draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
October 12, 2023 letter.
Amendment No. 8 to Draft Registration Statement on Form F-1
Prospectus Summary, page 6
1. We note your response
to prior comment 2. With respect to your disclosure that you have
obtained all approvals
required for your operations in China, please expand your
disclosure to provide
an explanation as to whether you consulted counsel and, if not, why
you did not consult
counsel and why you believe you do not need any permissions or
approvals.
Pun Leung Liu
FirstName
YXT.COMLastNamePun Leung Liu
Group Holding Limited
Comapany 21,
November NameYXT.COM
2023 Group Holding Limited
November
Page 2 21, 2023 Page 2
FirstName LastName
General
2. We note your response to prior comment 4; however, we continue to note
changes you
made to your disclosure appearing on the cover page, Summary and Risk
Factor sections
relating to legal and operational risks associated with operating in
China and PRC
regulations and it continues to be unclear to us that there have been
changes in the
regulatory environment in the PRC since the amendments that were filed
on January 10,
2023 and April 5, 2023 warranting revised disclosure to mitigate the
challenges you face
and related disclosures. As a nonexclusive example, on page 12, you no
longer address the
changes to China s economic, political or social conditions or
government policies. Please
tell us the reasons for these changes or revise your disclosure
throughout the registration
statement as applicable.
3. We note your response to prior comment 5. We continue to consider your
response and
may have additional comments.
Please contact Brittany Ebbertt at 202-551-3572 or Christine Dietz at
202-551-3408 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alexandra Barone at 202-551-8816 or Jan Woo at 202-551-3453 with any
other
questions.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Li He