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UPLOAD Filing

Origin Agritech LTD
Date: May 6, 2025 · CIK: 0001321851 · Accession: 0000000000-25-004761

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File numbers found in text: 000-51576

Referenced dates: April 11, 2025

Date
May 6, 2025
Author
Division of
Form
UPLOAD
Company
Origin Agritech LTD

Letter

Re: Origin Agritech LTD Form 20-F for Fiscal Year Ended December 31, 2024 Amendment No. 1 to Form 20-F for Fiscal Year Ended December 31, 2024 Response Letter dated April 11, 2025 File No. 000-51576 Dear Chi Kin Cheng:

May 6, 2025

Chi Kin Cheng Chief Financial Officer Origin Agritech LTD Origin R&D Center, Shuangbutou Village Xushuang Road, Songzhuang Town Tongzhou District, Beijing, China 101119

We have reviewed your April 11, 2025 response to our comment letter and have the following comment.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 11, 2025 letter.

Amendment No. 1 to Annual Report on Form 20-F Risk Factors Risks relating to doing business in China, page 22

1. We note your added disclosure regarding the enforceability of civil liabilities in response to previous comment 7. In your future filings, please also disclose the risks discussed in the section captioned "Enforceability of Civil Liabilities" in a separate risk factor, which should contain disclosures consistent with the separate enforceability section. Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related May 6, 2025 Page 2

matters. Please contact Robert Augustin at 202-551-8483 or Conlon Danberg at 202-551- 4466 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services

Show Raw Text
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<FILENAME>filename2.txt
<TEXT>
 May 6, 2025

Chi Kin Cheng
Chief Financial Officer
Origin Agritech LTD
Origin R&D Center, Shuangbutou Village
Xushuang Road, Songzhuang Town
Tongzhou District, Beijing, China 101119

 Re: Origin Agritech LTD
 Form 20-F for Fiscal Year Ended December 31, 2024
 Amendment No. 1 to Form 20-F for Fiscal Year Ended December 31, 2024
 Response Letter dated April 11, 2025
 File No. 000-51576
Dear Chi Kin Cheng:

 We have reviewed your April 11, 2025 response to our comment letter and
have the
following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe
the comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March
11, 2025 letter.

Amendment No. 1 to Annual Report on Form 20-F
Risk Factors
Risks relating to doing business in China, page 22

1. We note your added disclosure regarding the enforceability of civil
liabilities in
 response to previous comment 7. In your future filings, please also
disclose the risks
 discussed in the section captioned "Enforceability of Civil Liabilities"
in a separate
 risk factor, which should contain disclosures consistent with the
separate
 enforceability section.
 Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
 May 6, 2025
Page 2

matters. Please contact Robert Augustin at 202-551-8483 or Conlon Danberg at
202-551-
4466 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
</TEXT>
</DOCUMENT>