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November 21, 2023
Steven Wang
Chief Financial Officer
Hollysys Automation Technologies, Ltd.
No. 2 Disheng Middle Road
Beijing Economic-Technological Development Area
Beijing , P. R. China 100176
Re:Hollysys Automation Technologies, Ltd.
Form 20-F for the year ended June 30, 2023
File No. 1-33602
Dear Steven Wang:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            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 a
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.
Form 20-F for the year ended June 30, 2023
Item 16I Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 115
1.We note your statement that you reviewed your register of members and public filings
made by your shareholders in connection with your required submission under paragraph
(a), as filed in Exhibit 15.2. Please supplementally describe any additional materials that
were reviewed as the basis for your submission under paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination.
            In closing, 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

 FirstName LastNameSteven Wang
 Comapany NameHollysys Automation Technologies, Ltd.
 November 21, 2023 Page 2
 FirstName LastName
Steven Wang
Hollysys Automation Technologies, Ltd.
November 21, 2023
Page 2
absence of action by the staff.
            Contact Andrew Mew at (202) 551-3377 if you have any questions about comments
related to your status as a Commission-Identified Issuer during your most recently completed
fiscal year.  Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at 202-551-3301
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing