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April 11, 2024
Peng Xue
Chief Executive Officer
BingEx Limited
Building 6
Zhongguancun Dongsheng International Science Park
No.1 Yongtaizhuang North Road
Haidian District, Beijing 100192
People’s Republic of China
Re:BingEx Limited
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted April 1, 2024
CIK No. 0001858724
Dear Peng Xue:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
January 23, 2024 letter.
Amendment No. 4 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1
1.We note that throughout your prospectus you removed the word "uncertainties" at various
times and replaced it with "change(s),” that there "may be change(s)" or “subject to
change(s).”  For example, we note the following revisions:
•On page 5 that Certain PRC laws, regulations, and legal requirements are constantly
changing and may change with little advance notice, and that "their interpretation and
enforcement are subject to changes."

 FirstName LastNamePeng Xue
 Comapany NameBingEx Limited
 April 11, 2024 Page 2
 FirstName LastName
Peng Xue
BingEx Limited
April 11, 2024
Page 2
•On page 8 that "t[t]here may be changes" regarding the interpretation and application
of current and future PRC laws, regulations, and rules regarding the status of the
rights of our Cayman Islands holding company with respect to its contractual
arrangements with the VIE and its shareholders.

The Sample Letters sought specific disclosures relating to (i) uncertainties regarding the
status of the rights of the Cayman Islands holding company with respect to its contractual
arrangements with the VIE, and (ii) the risk and uncertainties regarding the enforcement
of laws and that the rules and regulations in China can change quickly with little advance
notice.  We do not believe that your revised disclosure referencing the "change(s)" or that
there "may be change(s)" or “subject to change(s)” conveys the same risk.    Please revise
your disclosure to include the specific disclosure sought in our prior comments 4 and
5 from our August 13, 2021 letter, accordingly.
2.Revise your prospectus summary and include a risk factor to provide disclosure about the
facts that raise substantial doubt about your ability to continue as a going concern.
Summary of Consolidated Financial Data, page 18
3.Please revise to present separate tables of the condensed consolidating schedules by year
to improve readability.
Note 1. Description of Business and Organization
Organization, page F-9
4.We note from your disclosure that in May 2023, “shareholding interests of VIE’s
subsidiaries were transferred to the Company’s subsidiaries.” As a result of this
restructuring, you state that you now conduct operations through your PRC subsidiaries
and the VIE. Please revise your disclosure to provide further information regarding the
nature of this restructuring transaction, including significant terms. In addition, please
clarify for us why the balance sheet of your VIE, as reflected on page F-13, did not
decline in a proportional manner similar to that of total revenues.
Note 12. Income Tax, page F-36
5.We note from the income tax reconciliation that in 2023 there was a significant impact on
the income tax expense due to a change in tax rates. Please revise to disclose the nature of
this change in tax rate, including when the change became effective. Refer to FASB ASC
740-10-50-12.

 FirstName LastNamePeng Xue
 Comapany NameBingEx Limited
 April 11, 2024 Page 3
 FirstName LastName
Peng Xue
BingEx Limited
April 11, 2024
Page 3
            Please contact Jennifer O'Brien at 202-551-3721 or Kimberly Calder at 202-551-3701 if
you have questions regarding comments on the financial statements and related matters. Please
contact Anuja Majmudar at 202-551-3844 or Kevin Dougherty at 202-551-3271 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Shu Du