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April 11, 2024
Liu Jia
Chief Financial Officer
Recon Technology, Ltd
Room 601, No. 1 Shui’an South Street
Chaoyang District, Beijing 100012
People’s Republic of China
Re:Recon Technology, Ltd
Form 20-F for the Fiscal Year ended June 30, 2023
Filed October 30, 2023
Response dated March 22, 2024
File No. 001-34409
Dear Liu Jia:
            We have reviewed your March 22, 2024 response to our comment letter and have the
following comments.
            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. Unless
we note otherwise, any references to prior comments are to comments in our February 28, 2024
letter.
Form 20-F for the Fiscal Year Ended June 30, 2023
Item 16C. Principal Accountant Fees and Services, page 101
1.We have read your response to prior comment 3, which includes various revisions to the
amounts previously reported as audit and audit-related fees, and a description of the audit-
related fees indicating these were paid to your auditors for reviews of your interim
financial information and documents filed with the SEC. However, you have not provided
an explanation for the numerical changes and the audit-related fees that you describe
would ordinarily need to be reported in the category for audit fees.

 FirstName LastNameLiu Jia
 Comapany NameRecon Technology, Ltd
 April 11, 2024 Page 2
 FirstName LastNameLiu Jia
Recon Technology, Ltd
April 11, 2024
Page 2
We encourage you to read the guidance on categorization of fees that resides in the
seventh and eight paragraphs of Section II.H of SEC Release 33-8183, issued January 28,
2003. The following is a brief summary of that guidance.

•Audit Fees - fees for services normally provided in connection with statutory and
regulatory filings or engagements, including services necessary to perform an audit or
review in accordance with GAAS, and services that generally only the independent
accountant reasonably can provide, such as comfort letters, statutory audits, attest
services, consents and assistance with and review of documents filed with the SEC.

•Audit Related Fees - fees for assurance and related services traditionally performed
by the independent accountant, such as employee benefit plan audits, due diligence
related to mergers and acquisitions, accounting consultations and audits in connection
with acquisitions, internal control reviews, attest services not required by statue or
regulation, and consultations on financial accounting and reporting standards.

Please revisit and revise your classification of fees consistent with the guidance above and
provide us with a description of the composition of the audit fees, for each firm and
period, as to the amounts pertaining to the annual audit, and separately for interim
reviews, specifying the particular interim periods, and other services.

Given your disclosures indicating you paid Friedman $285,000 for audit and audit-related
services pertaining to your 2022 fiscal year, and paid Friedman, Marcum Asia, and
Enrome combined, $450,000 for similar work pertaining to your 2023 fiscal year, tell us
how your rationale of being concerned about costs, for the decision to change auditors in
the midst of the audit, reconciles with the approximate 58% increase in fees. If there were
incremental reasons for your decision to change auditors in the midst of the audit, please
include details of those circumstances along with your reply.

As you indicate the fees paid to Marcum Asia were contractual and based on the extent of
audit progress until dismissal, please further clarify whether the fees for the audit planning
and three weeks of field work were based on rates and hours, a percentage applied to
a total contractual cost, or other factors.  Tell us your expectation for the total cost of the
Marcum Asia audit, had the firm not been dismissed, based on the engagement letter.
Item 19 Exhibits
Exhibit 15.1, page 106
2.We note that in response to prior comment 6 you provided draft consents from both
Friedman and Enrome to be filed as exhibits to an amended Form 20-F.  However, while
the draft consent from Friedman appears to generally conform to your circumstances, the
draft consent from Enrome states that the firm consents to the use of its audit report dated
October 27, 2023 by incorporation by reference "in this Registration Statement on Form
20-F" and consents to be named as experts in the same Registration Statement.

 FirstName LastNameLiu Jia
 Comapany NameRecon Technology, Ltd
 April 11, 2024 Page 3
 FirstName LastName
Liu Jia
Recon Technology, Ltd
April 11, 2024
Page 3
We understand that your intention is to update with more current financial information
(using incorporation-by-reference) your previously filed Registration Statement on Form
F-1 (File No. 333-271547), rather than a registration statement on Form 20-F, to include
the consolidated financial statements that will be filed in your Amendment No. 2 to Form
20-F for the fiscal year ended June 30, 2023, accompanied by the October 27, 2023 audit
report from Enrome (and the October 28, 2022 audit report from Friedman).

Please coordinate with Enrome to obtain a consent that is consistent with the requirements
of your registration statement on Form F-1, and with regard to the firms audit opinion that
will be included in Amendment No. 2 to your Form 20-F, which you will be filing soon.
            Please contact Yong Kim at 202-551-3323 or Jenifer Gallagher at 202-551-3706 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation