SecProbe.io

February 1 5, 2013

Via E -mail
Ms. Liu Jia
Chief Financial Officer
Recon Technology Ltd .
1902 Building C
King Long International Mansion
9 Fulin Road, Beijing 100107
People’s Republic of China

Re: Recon Technology Ltd.
 Form 10 -K for Fis cal Year En ded June 30, 2012
 Filed September 28 , 2012
 File No . 1-34409

Dear Ms. Liu :

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response .  If you do not believe our comments apply 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 filing and the information you provide in
response to these comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ended June 30, 2012

Business, page 1

1. We note you r disclosure at page 12 relating to the Catalogue of Industries for Guiding
Foreign Investment (Revised 2007).  Please update your disclosure to address the effects,
if any, on your business in respect of the revised Catalogue promulgated in December
2011.

Ms. Liu Jia
Recon Technology Ltd .
February 15, 2013
Page 2

 Management’s Discussion and Analysis of Financial Condition and Results of Operation ,
page 16

2. On page 11, you disclose  that for fiscal years 2012 and 2011, you spent ¥6,533,419
($1,033,818) and ¥3,078,391 , respectively, on research and development activities.  To
the extent applicable, please expand your discussion to describe the general purpose of
any capital commitments and anticipated sources of funding for such activities.  Refer to
Item 303(a) of Regulation S -K.

Certain Relationships and Related Transact ions, and Director Independence, page 37

3. Expand this section to discuss the various contractual arrangements among your entities
and founders, as described in Note 1 to your financial statements.

Closing Comments

 We urge all persons who are responsible for the accuracy and adequacy of the di sclosure
in the filing to be certain that the filing includes all information required under the Securities Act
of 193 3 and the  Securities Exchange Act of 1934 , and that they have provided all information
investors require for an informed investment decisi on.  Since the company and its management
are in possession of all facts relating to a company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written s tatement from the company
acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any ac tion with respect to the filing; and
 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Caroline Kim, Staff Attorney, at  (202) 551 -3878 or  Sirimal Mukerjee,
Staff Attorney,  at (202) 551 -3340  with any questions.

Sincerely,

        /s/H. Roger Schwall

        H. Roger Schwall
        Assistant Director
CC: Bradley A. Haneberg
 Kaufman & Canoles, P.C.