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Room 1902, Building C, King Long International
Mansion

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

June 22, 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 May 24, 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 your response to prior comment one, concerning your accounting for and disclosures about
purchase advances. Based on your response, it remains unclear why you do not believe FASB ASC 605-35-25-39 and 41 are applicable,
as you previously indicated that purchase advances were incurred with the objective of securing contracts to complete three customer-specific
projects, and considering this guidance covers costs incurred in anticipation of contracts, in advance of obtaining those contracts.

If the purchase advances
referenced in your prior response were not intended to result in obtaining contracts, provide further details about the arrangements
and explain how the facts and circumstances are not characteristic of the work that would be performed in the arrangements outlined
in FASB ASC 605-35-15-2 and 3, and are instead encompassed in the arrangements outlined in FASB ASC 605-35-15-6, if this is your
view. Otherwise, comply with the specific disclosure requirements referenced in our prior comment; and disclose your method of
accounting for contracts and pre-contract costs.

The Company acknowledges the comments and concluded that FASB
ASC 605-35-25-39 and 41 are applicable to us. We will include the following proposed disclosures in our significant accounting
policies section of our footnotes in our future filings:

“Purchase Advances - Purchase
advances are the amounts prepaid to suppliers for purchases of customized equipment in anticipation of obtaining planned contracts
for the Company’s hardware and software revenues and these advances are considered as pre-contract costs.

Pre-Contract Costs – The
Company defers purchase advances made that it expects to be used in connection with the anticipated contracts, so long as recovery
is considered probable, and recognized as inventory when the customized equipment is delivered and received. If it subsequently
confirms that the Company is unable to secure the planned contracts with a customer after making the purchase advances, the Company
evaluates the probable recoverability of the advance and charges the improbable recovery amounts as purchase advances allowances.
The Company determines that the recovery of such purchase advances is improbable when the Company is unable to request that a supplier
refund the purchase advances or obtain credits to change the purchase order to other customized equipment.

The Company evaluates its purchase
advances on a semi-annually basis. If it expects to receive its customized equipment within one year, the purchase advances are
classified as current assets. If it does not expect to utilize the purchase advances within one year, the purchase advances will
be classified as long-term assets. As of June 30, 2018, 2017 and 2016, the Company expected to receive its purchased advances,
net of allowance, within one year.

Contract
Costs - Direct costs, such as material, labor, and subcontracting costs and indirect costs allocable to
contracts include the costs of contract supervision, tools and equipment, supplies, quality control and inspection,
insurance, repairs and maintenance for quality assurance purposes before clients’ initial acceptance, depreciation and
amortization are included in the inventory work-in-process and recognized as cost of revenues when the product is shipped and
accepted. The Company uses the completed contract method for revenue recognition. Once products are delivered, installed and
debugged for intended use and accepted by a client, which may last from weeks to months (this process is decided by the
client’s individual project construction arrangement), the Company records revenue and deferred revenue if there is any
requirement of quality assurance or maintenance per contract. Deferred revenue varies from 5% to 10% of contract amount and
the period after which such revenue is recognized is generally one year following installation. The Company does not confirm
revenue from deferred items until the end of the whole maintenance period. Minor costs for repair during the maintenance
period after initial acceptance are recorded as cost of goods sold as they are incurred. All other general and administrative
costs and selling costs are charged to expenses as incurred. The Company generally ships its products approximately one week
to six months after production begins and the timing depends on the size of the overall project.

As of June 30, 2018, 2017 and 2016, except
for the Projects mentioned in our prior response, the Company has no contract with processing period above one year. In addition,
we hereby confirm that we will adopt ASC 606 on July 1, 2018 and such presentation will be disclosed in our June 30, 2018 Form
20-F.

 2. We believe that you will need to more clearly disclose the nature of and reasons for significant
purchase advances, including a description of any related and expected future revenue generating activity, the timeframe in which
such activity is planned, and any uncertainties regarding the prospect for recovering the amounts. You should also expand your
Critical Accounting Policies and Estimates disclosure to address the key assumptions underlying your accounting for material arrangements
and the reasonably likely material effects of resolving any uncertainties on your financial statements. If you prefer to limit
compliance to future filings, please submit the revisions that you propose and explain your rationale and view as to the materiality
of current arrangements.

The Company acknowledges the comments and
will disclose the following proposed disclosure in our liquidity and capital resource section to more clearly disclose the nature
of and reasons for significant purchase advances, including a description of any related and expected future revenue generating
activity, the timeframe in which such activities is planned, and any uncertainties regarding the prospect for recovering the amounts
as follows:

“Purchase Advances

Purchase advances are
the amounts prepaid to suppliers for purchases of customized equipment in anticipation of obtaining planned contracts for
the Company’s hardware and software revenues and these advances are considered as pre-contract costs. As of June 30, 2018,
we prepaid approximately ¥XX purchase advances to our suppliers as compared to approximately ¥11.5 million at June
30, 2017. The change in purchase advances is mainly due to the change in our anticipation of securing new sales contacts and
to secure the materials for our timely performance under such contracts. The production of our product required custom-made
equipment from our suppliers. To ensure that we can secure the required customized equipment, we would need to make full
prepayment for our intended purchases. As a standard practice in the petroleum extraction industry, we generally must submit
a bid in order to secure the sales contract. The bidding process generally takes between one month to one year and the timing
depends on the size of the overall project, which timing and size are generally controlled by our client. In order to secure
timely purchase delivery and to meet our product delivery schedule, we normally would prepay for the purchase advances if we
believe that we are more than likely to win the bid for the sales contract. After winning the bid and the sale contract is
secured, we normally need to deliver our products approximately within one week to six months. Based on our historical
experience, we are generally able to realize our purchase advances on the customized equipment that we ordered. If we do not
secure the sales contract after making prepayment, we seek to negotiate with our suppliers for them either to issue refund of
the purchase advances or issue credits for us to purchase similar products with similar models with our future contracts. If
we determine that our suppliers are unlikely to refund or credit for future purchases or if we are unlikely to secure
projects to use those products in the foreseeable future, we provide a 100% allowance on the improbable recovery
amounts.”

We also will expand our disclosure in our
Critical Accounting Policies and Estimates section to address the key assumptions underlying our accounting for material arrangements
and the reasonably likely material effects of resolving any uncertainties on our financial statements as follows:

“Estimates and assumptions - The
preparation of the consolidated financial statements in conformity with U.S. GAAP requires that management make estimates and assumptions
that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the dates of
the financial statements and the reported amounts of revenues and expenses during the reporting periods. Estimates are adjusted
to reflect actual experience when necessary. Significant accounting estimates reflected in the Company’s consolidated financial
statements include allowance for doubtful accounts related to trade accounts receivable, other receivables and purchase advances,
allowance for inventory, the useful lives of property and equipment, valuation allowance for deferred tax assets and the fair value
of share- based payments. Since the use of estimates is an integral component of the financial reporting process, actual results
could differ from those estimates.

The key assumptions
underlying the Company’s accounting for material arrangements and the reasonably likely material effects of resolving
any uncertainties on the Company’s allowance for doubtful accounts related to purchase advances. The production of
the Company’s products requires custom-made equipment from its suppliers. To ensure that it can secure the
required customized equipment, the Company often needs to make full prepayment for its intended purchases. As a standard
practice in the petroleum extraction industry, the Company generally must submit a bid in order to secure the sales contract.
The bidding process generally takes between one month to one year and the timing depends on the size of the overall project,
which timing and size are generally controlled by its client. In order to secure timely purchase delivery and to meet its
product delivery schedule, the Company normally prepays for the purchase advances if the Company believes that it is more
than likely to win the bid for the sales contract. After winning the bid and securing the sale contract, the Company normally
needs to deliver its products approximately within one week to six months. Based on the Company’s historical
experience, the Company generally is able to realize its purchase advances on the customized equipment that it orders. If the
Company does not secure the sales contract after making prepayment, its seeks to negotiate with its suppliers for them either
to refund the purchase advances or issue credits for the Company to purchase similar products with similar models with its
future contracts. If the Company determines that its suppliers are unlikely to refund or credit for future purchases or if it
is unlikely to secure projects to use those products in the foreseeable future, the Company provides a 100% allowance on the
specific advances. As of June 30, 2018, the Company has approximately ¥XX of purchase advances that it are still pending
of securing sales contract bid, of which we estimate ¥XX will not be realizable and have accordingly provided an
allowance. In addition, we have written off ¥XX during the year ended June 30, 2018  that have aged more  than two years
and the Company does not expect to recover the amount in the near future. The balance of ¥XX of such allowance remains
outstanding at June 30, 2018 as it has not yet exceeded two years in aging or otherwise been deemed uncollectible.”

The Company confirms that its annual report
on Form 20-F for the year ending June 30, 2018 will address matters relating to the status of uncertainties as to its order book,
prepayments and recovery of prepayments and performance under existing contracts.

Thank you in advance for your assistance
in reviewing this response. Should you have any questions with respect to the above response, please contact me.

    Sincerely,

    Recon Technology, Ltd.

    By:
    /s/ Jia Liu

    Name:
    Jia Liu

    Its:
    Chief Financial Officer

cc: Anthony Basch, Partner, Kaufman & Canoles,
P.C.

Joy Pan, Partner, Friedman LLP