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October 21, 2022
Yanlai Shi
Chief Executive Officer
RYB Education, Inc.
4/F, No. 29 Building, Fangguyuan Section 1, Fangzhuang
Fengtai District, Beijing 100078
People’s Republic of China
Re:RYB Education, Inc.
Form 20-F for Fiscal Year Ended December 31, 2021
Response Dated August 23, 2022
File No. 001-38203
Dear Yanlai Shi:
            We have reviewed your August 23, 2022 response to our comment letter 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 business days by providing the requested
information or advise 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 July 26, 2022 letter.
Response Dated August 23, 2022
Item 3. Key Information, page 3
1.We note your response to comment 7 and re-issue in part. We note your proposed cross-
references to specific risks, however, please include both the risk factor title and the
relevant page number, not just the risk factor title.
2.We note your response to comment 8 and re-issue in part. While you propose to disclose
that you have relied on an opinion of counsel to conclude that you have the necessary
approvals and permissions to operate your business, please also include the name of your
mainland China counsel. In addition, while we note the proposed additional disclosure in
the risk factor titled "Our business generates and processes a large amount of data, and

 FirstName LastNameYanlai Shi
 Comapany NameRYB Education, Inc.
 October 21, 2022 Page 2
 FirstName LastName
Yanlai Shi
RYB Education, Inc.
October 21, 2022
Page 2
we are required to comply with PRC and other applicable laws relating to privacy and
cybersecurity. The improper use or disclosure of data could have a material and adverse
effect on our business and prospects" in response to comment 8, it does not appear that
this risk factor is cross-referenced, or the proposed additional disclosure included, in your
proposed revised disclosure to be added to the introduction of Item 3. Please revise the
proposed additional disclosure to be added to Item 3 to explain the basis for your
conclusions why you are not required to have a cybersecurity review by the China
Securities Regulatory Commission or the Cyberspace Administration of China.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact James Giugliano at 202-551-3319 or Suying Li at 202-551-3335 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Yuting Wu