SecProbe.io

Mail Stop 4628

April 25, 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 ended June 30, 2017
 Response d ated April 3, 2018
File No. 001-34409

Dear  Ms. Jia :

We have reviewed  your April 3, 2018  response to our comment  letter  and have the
following comment s.  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
information 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.
Unless we note otherwise, our references to prior comments are to comments in our  March 20,
2018  letter .

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

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

1. We note your response to prior comment one , concer ning your accounting for purchase
advances  that were made to obtain equipment, materials, or other goods  or representation
of local partner s in anticipation of obtaining contracts  for an internet system project, a
pipeline project, and a gas storage project , in order to meet the specific requirements of
the counterparties  in advance of obtaining the contract s.  We understand that you planned
to develop and sell specialized industrial automation control and information solutions as
part of the project fulfillment process , but never obtained contracts  for the projects .

Liu Jia
Recon Technology, Ltd.
April 25, 2018
Page 2

We note that although you have historically report ed purchase advances as a current
asset , the impairment that you recognized during  2016 included advances that had been
made as early as 2010 .  Given the nature of work that you envisioned , it is unclear why
you would not follow the guidance for contractual arrangements referenced in FASB
ASC 605 -35-15-2 and 3, and the guidance f or pre -contract costs in FASB ASC  605-35-
25-39 and 41 .  This  permits  certain types of costs to be deferr ed, when incurred in
anticipation of a contract,  provided that recovery is considered probable .

If there is uncertainty concerning the determination or ultimate realization  of contract
costs deferred , you should  disclose the amount s, the nature and status of principal items
comprising the amount s, and the portion that is expected to be collected beyond one year
to comply with FASB ASC 910 -20-50-1.  For prepayments made in anticipation of
specific contracts  that qualify for deferral and which are deferred as pre-contact costs ,
disclose your accounting  policy pertaining to the  deferral s and recoverability  assessment ,
and the amounts involved  to comply with FASB ASC 910 -340-50-1.

2. Please expand your disclosures to address t he general requirements of FASB ASC 605 -
35-50, and FASB ASC 606 -10-50, as applicable .

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