SecProbe.io

CORRESP
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Room 1902, Building C, King Long International
Mansion

No. 9 Fulin Road, Beijing, China 100107
+86 (10) 8494-5799

April 3, 2018

Karl Hiller, Branch Chief

Joseph Klinko, Staff Accountant

Office of Natural Resources

U.S. Securities and Exchange Commission

Mail Stop 4628

100 F Street, N.E.

Washington, D.C. 20549-4631

    Re:
    Recon Technology, Ltd.

    SEC comment letter dated March 20, 2018 regarding Form 20-F for the Fiscal Year ended June 30, 2017 Filed September 28, 2017, File No. 001-34409

Dear Sirs:

On behalf of Recon Technology, Ltd. (the
“Company”), we are writing to respond to the comments of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) set forth in the above-referenced letter.

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

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

 1. We note that your provision to the allowance for doubtful accounts of purchase 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
references on pages 50 and F-14, we do not see disclosure of any specific details about purchase advances and provisions, such
as descriptions of the equipment and projects, difficulties with suppliers, or reassessments of profitability, as would ordinarily
accompany disclosure under Item 5.

Please submit a schedule
of the various payments that comprise the balance associated 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 when
you placed the orders, including the expected dates for equipment receipt and project completion, and describe any terms established
for sequential payments.

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

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
suppliers have agreed to provide such inventory or equipment to you, along with the timeframe that you expect to realize the value
in a subsequent sale.

The Company acknowledges the comments and provides details regarding
the provision to the allowances for doubtful accounts of purchase advances, reassessment of the provision and the reasons for the
cancelled purchase orders.

Background of the Company’s
business operation and the relevant accounting policy in the last five years

Before the oil
industry recession in 2014, the Company’s incremental business depended heavily on the Da Qing Oilfield projects and
the oil pipeline projects in the Southwest Oilfields of China Petrochemical Corporation (“Sinopec”) which is the
second largest oil and gas producer in China and one of the largest integrated energy groups in the world. The Company was
also seeking business opportunities to participate in some large scale projects, including the underground natural gas
storage project in the Hua Bei Oilfields of China National Petroleum Corporation (“CNPC”), beyond its prior line
of business. CNPC is the largest oil and gas producer in China and one of the largest integrated energy groups in the world.
In order to win the bids and complete contracts on time, the Company  typically ordered the customized products before
the projects started, and sometimes even before the official bidding process began. CNPC and Sinopec enhanced their internal
operating and project management processes, and the Company  also improved its procurement process and efficiency and
significantly reduced early inventory acquisitions and related purchase advances.

Full advance payment is generally
required when the Company places orders, especially when customized products or imported products are required.

Purchase advances are the amounts
prepaid to suppliers for purchases of inventory and are recognized as inventory when the final amount is paid to the suppliers
and the inventory is delivered. Goods to be delivered or services to be rendered for related projects that will be utilized within
one year are classified as current assets, and those utilized after one year are classified as non-current assets. The Company’s
management (“Management”) makes assessment of projects and progress periodically. The Company’s accounting policy
and procedure regarding allowances for purchase advances or the timing of write-offs were set based on its past experiences over
the years with different clients and its knowledge of client project status or progress. An allowance for doubtful accounts is
recorded in the period in which a loss is determined to be probable. The Company also makes a specific allowance if there is strong
evidence indicating that a purchase advances is likely to be unrecoverable. The Company maintains offices at each client site for
those targeted projects in order to communicate with clients on a regular basis and manage client services in a productive manner
in response to project needs. Frequent communications with clients and cooperation with local partners also allow the Company to
have considerable knowledge about its different clients and their project progresses, which in certain instances constitute part
of the basis for determining treatment of an accounting item. Advances are charged off against the allowance after all means of
collection have been exhausted, and the potential for recovery is considered remote.

From fiscal 2014 through fiscal
2017, our industry saw significant decreases in oil prices, which reduced our clients’ capital expenditures on previously
committed projects. This letter discusses the impact of these reductions in capital expenditures, the adverse impact on our operations
from 2013 through 2016 and detailed information about purchase advances, allowances for doubtful accounts and write offs of those
amounts.

Project Inventory Purchases
Advances

All numbers are in RMB as
otherwise noted.

    Balance
    Charge
    to expense
    Component

    Fiscal Year 2015

    Major

    Miscellaneous

    Purchase
    Advances
      22,845,030

    Allowance
    for doubtful accounts
      (4,222,492 )
      2,862,230
      2,400,020
    (1)
      462,210

    Purchase
    Advances, net as of June 30, 2015
      18,622,538

    Balance

    Fiscal
    Year 2016

    Purchase
    Advances
      17,914,552

    Allowance
    for doubtful accounts
      (16,591,247 )
      12,368,755
      12,822,305
    (2)(3)
      (453,550 )

    Purchase
    Advances, net as of June 30, 2016
      1,323,305

    Balance

    Fiscal
    Year 2017

    Purchase
    Advances
      11,877,790

    Allowance
    for doubtful accounts
      (401,790 )
      381,436
      330,093

      51,343

    Purchase
    Advances, net as of June 30, 2017
      11,476,000

    Item
    Project
    Payment Date
    Advanced

        payment

    Amount

        Utilized

    Uncovered

        Balance

    Allowance

        Charged
        to

        Expenses

    Written
off

    Purchase item
    Expected Revenue
    Expected project start date
    Expected project completion date
    Project follow-up

    2015 (1)
    2016 (2)
    2017 (3)

    (i)
    Project
    A11
    11/27/2013
     1,000,000
    (799,960)*
    200,040
     100,020
     100,020
    200,040
    RTU

    Control cabinet

    Variable frequency motor Sensor
     RMB
    11 million
    Middle
    of year 2014
    End
    of year 2015
    The
                                         overall Project A11 ceased.

        As of fiscal year 2017,
        only a small scale pilot program was implemented.

    12/20/2013
     1,000,000

    1,000,000
     500,000
     500,000
     1,000,000

    1/4/2014
     3,600,000

    3,600,000
     1,800,000
    1,800,000
     3,600,000

    Sub
    Total
    4,800,040
    2,400,020
    2,400,020
    4,800,040

    6/26/2014
     1,868,271

     1,868,271

    1,868,271
     1,868,271

    12/23/2014
    550,000

    550,000

     550,000
    550,000

    3/2/2015
    362,364

    362,364

     362,364
    362,364

    Sub
    Total
    2,780,635
    -
    2,780,635
    2,780,635
    ——
    ——
    ——
    ——
    ——

    (ii)
    Project
    Pipeline
    12/5/2012
     3,041,700

     3,041,700

    3,041,700
     3,041,700
    Pipeline
    monitoring system
    RMB
    5 million
    March
    2014
    June
    2015
    Project
                                         ceased.

        Please refer to (3)(a)
        for further plan.

    5/28/2013
    500,000

    500,000

     500,000
    500,000

    Sub
    Total
    3,541,700
    -
    3,541,700
    3,541,700
    ——
    ——
    ——
    ——
    ——

    (iii)
    Project
    Hua Bei
    5/6/2010
     4,102,260
    (2,051,130)
    **
    2,051,130
     -
    2,051,130
     2,051,130
    DCS
    system of Emerson

    Radar hydrostatic gauge
    RMB
    10.5 million
    Early year 2011
    End
    of year 2012
    The
                                         Project was postponed and implementation plan was amended thereafter.

        Please refer to (3)(b)
        for further plan.

    5/25/2010
     4,097,640
    (2,048,820)
    **
    2,048,820
    -
    2,048,820
     2,048,820

    Sub
    Total
    4,099,950
    -
    4,099,950
    4,099,950
    ——
    ——
    ——
    ——
    ——

    Sum
    15,222,325
    2,400,020
    12,822,305
    15,222,325
    ——
    ——
    ——
    ——
    ——

 Note:

* Components of automation hardware, PLC, RTU, Control valve
blocks etc., were delivered to the Company in December 2013.

** Half of each down payment was collected back in cash in June
and December 2013.

 (1) For the fiscal year 2015, the Company recorded ¥2.4 million of allowance for ¥4.8 million of purchase
advances for Project A11.

 (i) Project A11

In 2013, the Company was
informed of the Da Qing Oilfield’s oil and gas production Internet system projects (also known as “Project
A11”) and began to work with Da Qing local companies (the “local partners”) in anticipation of a winning
bid for the projects. The Company’s decision to work with the local partners was based on the customary industry
practice. Da Qing Oilfield, like other oilfield companies in China, selects contractors for its oilfield projects
predominantly from bidders who are pre-qualified based on its criteria. The Company, while meeting all the technical
requirements, had not obtained such a bidder qualification from Da Qing Oilfield during the relevant periods. In order to win
the projects, the Company was required to collaborate with a pre-qualified bidder and the local partners. Based on project information available at that time, the Company expected to generate ¥11 million
of revenue and ¥3 million  of gross profit and Project A11 would start in mid-2014. Since the local partner
required the Company to make advances to purchase inventories to fulfill the project requirements, the Company made ¥5.6
million, in aggregate, of purchase advances in November through December 2013 and in January 2014 to purchase automation
products and other goods. The advances were made in light of the Company’s expected participation in Project A11.

During fiscal 2015, the Company
recorded an allowance of ¥2.4 million of the purchase advances as a result of Da Qing Oilfield’s delay in the start of
Project A11 and expected Project 11 to start in the following year based on the available information at that time. Management
believed ¥2.4 million of estimated allowance was the best estimate and a fair representation of the risk of this project.

 (2) During the fiscal year 2016, the Company recorded ¥12.4 million of allowances, mostly from ¥12.8
million of purchase advances for the following projects:

 (i) An additional ¥5.2 million for Project
A11;

In addition to the above-mentioned
¥4.8 million, the Company also made additional purchase advances in the aggregate amount of ¥2.78 million in June and December
2014 and March 2015 for Project A11. The Company made the advances based on the purchase orders advised by the local partner. The
Company and its local partner had considered the purchase advances necessarily to provide them with a competitive advantage in
the project delivery process.

During fiscal year 2016, as a
result of the Da Qing Oilfield’s changes in development direction and investment plan, Project A11 was postponed but not
terminated. The Company was unable to estimate when Project A11 would continue and recorded a full allowance of ¥5.2 million
for purchase advances for Project A11.

By fiscal year 2017, there was
still no official notice of relaunch or termination of Project A11. The Company had tried to negotiate with the local partner
to use the advances in alternative projects. However, the local partner ceased operation. Although the Company was not able to
locate the local partner, the Company diligently pursued the partner by communicating with others in the industry and staff of
Da Qing oilfield, so by the end of fiscal 2016 the Company had provided an allowance for the advances but had not written them
off. As of the date of this letter, the Company noticed that only a pilot program of A11 project was announced and there is still
no further progress beyond that.

 (ii) ¥3.5 million for a pipeline project in
the Southwest Oilfield of Sinopec (“Project Pipeline”)

The Company made ¥3.5 million
of advances to Beijing Ji Ren Hong Hui Ltd (“Ji Ren Hong Hui”), a distributor of petrochemical equipment, in December
2012 and May 2013 for its pipeline-testing project in the Southwest bureau of Sinopec in Sichuan province. Based on project information
available at that time, the Company expected to generate ¥5 million of revenue and ¥1.5 million of gross profit and Project Pipeline
would start on March 2014.

At the end of fiscal year
2016, Sinopec did not start the project bidding process nor did it launch Project Pipeline. Pursuant to the contract terms,
Ji Ren Hong Hui was not required to refund the advances to the Company. Ji Ren Hong Hui, however, agreed to provide the
Company with a payment credit and supply the automation system ordered by the Company upon further request. The Company
intends to use the payment credit after winning similar projects in the coming years. Since the Company did not expect to
purchase the similar systems in the near future, it provided a full allowance for the advances made to Ji Ren Hong Hui.
Management did, however, plan to use this credit in future periods if and to the extent if successfully bid for appropriate
projects, so Management determined that a write-off was not warranted in fiscal 2016.

 (iii) ¥4.1 million for the Hua Bei Oilfield
gas storage project (“Project Hua Bei”).

In 2010, the Company was informed
of Project Hua Bei. Based on the Company’s experience with the gas storage construction, Management believed it would succeed
in bidding the project. Based on project information available at that time, the Company expected to generate ¥10.5 million
of revenue and ¥2.3 million of gross profit and Project Hua Bei would start in early 2011. In May 2010, the Company made advances
of approximately ¥8.2 million to a distributor of Emerson and Siemens to order the required equipment, electronic system and
specialized products, which were custom-made.

In June and December 2013,
the Company collected ¥4.1 million of total advances in cash as Project Hua Bei was not started as expected and no
purchase instruction was executed. Besides, after continuing negotiations with the suppliers, the Company obtained credit
from the suppliers to purchase electronic equipment within a market value o