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November 10, 2022
Pun Leung Liu
Chief Financial Officer
YXT.COM Group Holding Limited
Floor 20, Building 2, No. 209, Zhuyuan Road
High-tech District, Suzhou,
Jiangsu, 215011, People’s Republic of China
Re:YXT.COM Group Holding Limited
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted October 27, 2022
CIK No. 0001872090
Dear Pun Leung Liu:
            We have reviewed your amended draft registration statement 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 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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
October 12, 2022 letter.
Amendment No. 4 to Draft Registration Statement on Form F-1
VIE Consolidating Schedule (Unaudited), page 25
1.The line item "Equity in loss of the Group's entities" and related footnote (2) to the
consolidating statement of operations implies that the income (loss) of the VIEs is treated
similar to an equity method investment.  Please revise to separately present, and
appropriately label, amounts related to your subsidiaries, which may be equity method
investments, and amounts related to the VIEs.  For example, amounts related to the VIEs
may be labeled "Income/(loss) of the VIEs."  Similar revisions should be made to the
“Investments deficit to the Group's entities” and "Investments to the Group’s entities" line

 FirstName LastNamePun Leung Liu
 Comapany NameYXT.COM Group Holding Limited
 November 10, 2022 Page 2
 FirstName LastName
Pun Leung Liu
YXT.COM Group Holding Limited
November 10, 2022
Page 2
items and related footnote in the consolidating balance sheets.  For example, amounts
related to the VIEs may be labeled "Net assets of the VIEs."
Risk Factors
From time to time, we may become defendants in legal proceedings..., page 37
2.We note your disclosure that “the other shareholder of CEIBS PG holding the remaining
40% equity interest, stated publicly that we had infringed its intellectual property rights
and CEIBS was not aware of and did not recognize the associated share purchase of
Shanghai China Europe and Shanghai Fenghe by Yunxuetang Network, the VIEs.” With
respect to the dispute involving CEIBS PG, please discuss any potential risks related to
challenges of your ownership stake in CEIBS PG.
Consolidated Financial Statements
1. Principal Activities and Organization
(b) History of the Group and Basis of Presentation for the Reorganization, page F-14
3.We note your response and revised disclosures to prior comment 9.  Please further revise
to remove your reference to "ownership" from the percentage of ownership column in the
VIEs table on pages F-15 and F-85 as this implies you have some kind of equity
ownership in the VIEs.  Please relabel this column so that it appropriately reflects the fact
that you hold only an economic interest in the VIEs via contractual arrangements.
General
4.We make reference to the response to our prior comment 31 that you provided in your
September 28, 2021 letter. Our prior comment 31 requested, in part, that you provide an
analysis of the status of the Company and its subsidiaries under Section 3(a)(1)(C) of the
1940 Act. Your response focused on the application of Rule 3a-8 under the 1940 Act and
did not include the requested calculation(s) under Section 3(a)(1)(C). Although we
understand that it is the Company’s intent to rely on Rule 3a-8, we reissue our request that
you provide all relevant calculations under Section 3(a)(1)(C) (on an unconsolidated
basis), identifying each constituent part of the numerator(s) and denominator(s). To the
extent that your analysis depends on the legal treatment of subsidiary entities under
Section 3(a)(2) of the 1940 Act, please provide a legal analysis supporting such treatment.

 FirstName LastNamePun Leung Liu
 Comapany NameYXT.COM Group Holding Limited
 November 10, 2022 Page 3
 FirstName LastName
Pun Leung Liu
YXT.COM Group Holding Limited
November 10, 2022
Page 3
            You may contact Brittany Ebbertt, Senior Staff Accountant, at (202) 551-3572 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding
comments on the financial statements and related matters. Please contact Alexandra Barone,
Staff Attorney, at (202) 551-8816 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Li He