SEC Company Response from XChange TEC.INC (XHG) (CIK 0001769256) (XHG) — Mar 30, 2026

XChange TEC.INC (XHG) (CIK 0001769256)
Date: March 30, 2026 · CIK: 0001769256 · Accession: 0001213900-26-036268

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File numbers found in text: 333-290136

Date

March 30, 2026

Author

Zhichen Sun

Form

CORRESP

Company

XChange TEC.INC (XHG) (CIK 0001769256)

Letter

XChange TEC.INC

Room 613, No.259, Guoxia Road

Yangpu District, Shanghai, 200433

People's Republic of China

March 30, 2026

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

Washington, DC 20549

Attention: Aisha Adegbuyi and Tonya Aldave

Re: XChange TEC.INC

Registration Statement on Form F-3

Registration No. 333-290136

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, XChange TEC.INC, a Cayman Islands exempted company (the "Company"), hereby respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 4:30 P.M. (Eastern Time) on April 1, 2026, or as soon thereafter as possible on such date.

Once the Registration Statement has been declared effective, please confirm that event with Jeffrey Kennedy of ArentFox Schiff LLP at (312) 258-5526.

Very truly yours,
XChange TEC.INC

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CORRESP
 1
 filename1.htm

 XChange TEC.INC

 Room 613, No.259, Guoxia Road

 Yangpu District, Shanghai, 200433

 People's Republic of China

 March 30, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporate Finance

 Washington, DC 20549

 Attention: Aisha Adegbuyi and Tonya Aldave

 Re:
 XChange TEC.INC

 Registration Statement on Form F-3

 Registration No. 333-290136

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the
Securities Act of 1933, as amended, XChange TEC.INC, a Cayman Islands exempted company (the "Company"), hereby respectfully
requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective
at 4:30 P.M. (Eastern Time) on April 1, 2026, or as soon thereafter as possible on such date.

 Once the Registration Statement
has been declared effective, please confirm that event with Jeffrey Kennedy of ArentFox Schiff LLP at (312) 258-5526.

 Very truly yours,

 XChange TEC.INC

 By:
 /s/ Zhichen Sun

 Name:
 Zhichen Sun

 Title:
 Chief Executive Officer

SecProbe.io