SecProbe.io

Mail Stop 4628
March 20 , 2018

Via Email
Ms. Liu Jia
Chief Financial Officer
Recon Technology, Ltd.
Room 1902 , Building C, King  Long International Mansion
No. 9 Fulin Road , Beijing 100107
Peoples Republic of China

Re: Recon Technology, Ltd.
 Form 20-F for the Fiscal Year e nded June 30, 2017
Filed  September 28, 2017
File No.  001-34409

Dear  Ms. Jia :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
informa tion or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments .

Form 20 -F for the  Fiscal  Year e nded June 30, 2017

Note 7. Purchase Advances, Net , page F -14

1. We note  that your  provision to the allowance for doubtful accounts of p urchase advances
was ¥2,862,230  for the year ended June 30, 2015 and ¥12,368,755 for the year ended
June 30, 2016.  However, aside from the  general reference s on page s 50 and F-14, we do
not see disclosure of any specific details about  purchase advances and provis ions, such as
descriptions of  the equipment  and projects , difficulties with  suppliers , or reassessments of
profitability , as would ordinar ily accompany disclosure under  Item 5 .

Please submit a schedule of the various payments that comprise the balance associ ated
with the allowance at the end of each period, along with the dates those payments were
made and a description of the inventory or equipment and the projects contemplated

Liu Jia
Recon Technology, Ltd.
March 20, 2018
Page 2

 when you placed the order s, including the expected dates for equipment receipt and
project completion , and describe any terms establishe d for sequential  payments .

Tell us  the reasons you later canceled or postponed the order s or otherwise determined
that an allowance was necessary , and explain how you assessed the effects  of changing
relationships with supplier s and needs for equipment  on your oper ations .

Please clarify whether the assets associated  with purchase advances as of June  30, 2017
represent future inventory , or relate to equipment being acquired for a specific contract
with a third party .  Tell us your rationale for the current asset classification,  specify the
dates your s uppliers have agreed to provide  such inventory or equipment to you , along
with the timefra me that you expect to realize the value in a subsequent sale .

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, ac tion or absence of
action by the staff.

You may contact  Joseph Klinko, Staff Accountant, at (202) 551 -3824 , John Cannarella,
Staff Accountant , at (202) 551 -3337 or me at  (202) 551 -3686  with any questions.

Sincerely,

 /s/ Karl Hiller

Karl Hiller
Branch  Chief
Office of Natural Resources