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SEC Comment Letter for XChange TEC.INC (XHG) (CIK 0001769256) (XHG) — Mar 23, 2026

XChange TEC.INC (XHG) (CIK 0001769256)
Date: March 23, 2026 · CIK: 0001769256 · Accession: 0000000000-26-002900

Financial Reporting Regulatory Compliance

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File numbers found in text: 001-39111

Date
March 23, 2026
Author
Division of
Form
UPLOAD
Company
XChange TEC.INC (XHG) (CIK 0001769256)

Letter

Re: XChange TEC.INC Form 20-F for Fiscal Year Ended September 30, 2024 Form 20-F for Fiscal Year Ended September 30, 2025 File No. 001-39111 Dear Zhichen Sun:

March 23, 2026

Zhichen Sun Chief Executive Officer XChange TEC.INC Room 613, No.259, Guoxia Road Yangpu District, Shanghai, 200433 People s Republic of China

We have completed our review of your filings. 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.

Sincerely,
Division of
Corporation Finance
Office of Finance
cc: Marc Rivera, Esq.

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 23, 2026

Zhichen Sun
Chief Executive Officer
XChange TEC.INC
Room 613, No.259, Guoxia Road
Yangpu District, Shanghai, 200433
People s Republic of China

 Re: XChange TEC.INC
 Form 20-F for Fiscal Year Ended September 30, 2024
 Form 20-F for Fiscal Year Ended September 30, 2025
 File No. 001-39111
Dear Zhichen Sun:

 We have completed our review of your filings. 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.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Marc Rivera, Esq.
</TEXT>
</DOCUMENT>