July 29, 2024

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
           Registration Statement on Form F-1
           Filed July 12, 2024
           File No. 333-280772
Dear Pun Leung Liu:

       We have reviewed your registration statement and have the following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Form F-1 filed July 12, 2024
Capitalization, page 91

1.     Please revise to disclose total capitalization for each of the columns
presented, which
       should include total indebtedness plus equity, and revise to remove the
total liabilities,
       mezzanine equity and shareholders' (deficit) /equity line item. Refer to
Item 3B of Form
       20-F.
2.     Please revise to include the derivative liability for the preferred
stock conversion feature
       in the capitalization table.
Dilution, page 94

3.     Please revise to also disclose the pro forma net tangible book value and
the per share
       value reflecting the automatic conversion of preferred stock and provide
us with the
       related calculations for those amounts.
 July 29, 2024
Page 2

General

4.     Given the recent deconsolidation of certain subsidiaries of the Company,
please
       supplementally provide a legal analysis of whether the Company and/or
any of its
       subsidiaries meets the definition of    investment company    under
Section 3(a)(1)(C) of the
       1940 Act. Please include in your analysis all relevant calculations
under Section
       3(a)(1)(C), identifying each constituent part of the numerator(s) and
denominator(s).
       Please also describe and discuss: (i) your proposed treatment of the
Company   s cash and
       cash equivalents for purposes of Section 3(a)(1)(C); and (ii) any other
substantive
       determinations and/or characterizations of assets that are material to
your calculations.
5.     On page 85 of the registration statement, you describe Yunxuetang
Information as a
          qualifying majority owned subsidiary.    However, on page 16 of the
registration
       statement, Yunxuetang Information is described as a WFOE, and the
corporate structure
       chart on page 6 of the registration statement reflects Yunxuetang
Information is a wholly
       owned subsidiary. Please supplementally clarify the varying descriptions
for the same
       subsidiary, and if appropriate, within the registration statement.
        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
statement.

       Please contact Brittany Ebbertt at 202-551-3572 or Chris Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Lauren Pierce at 202-551-3887 or Jan Woo at 202-551-3453 with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:   Li He