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January 27, 2023
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. 5 to Draft Registration Statement on Form F-1
Submitted January 10, 2023
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
November 10, 2022 letter.
Amendment No. 5 to Draft Registration Statement on Form F-1 Submitted January 10, 2023
VIE Consolidating Schedule (Unaudited), page 25
1.We note your revised disclosure and response to prior comment 1.  Please further revise
footnote (3) to the tables on pages 25 and 26 to remove the reference to "primary
beneficiaries of VIEs" as this line represents only eliminations between the company and
other subsidiaries.  Also, please explain what is reflected in the amounts in the
VIE column on page 26 in the line item "investments in the Group's entities'."  In this
regard, it appears this amount should be zero in the VIE column.

 FirstName LastNamePun Leung Liu
 Comapany NameYXT.COM Group Holding Limited
 January 27, 2023 Page 2
 FirstName LastName
Pun Leung Liu
YXT.COM Group Holding Limited
January 27, 2023
Page 2
Management
Compensation of Directors and Executive Officers, page 199
2.Please update to include executive compensation disclosure for the fiscal year ended
December 31, 2022.
General
3.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F, or
include the representations noted in Instruction 2 thereto as an exhibit to your registration
statement.
4.In your response to prior comment 4 you declined to provide the requested calculation and
analysis under Section 3(a)(1)(C) of the 1940 Act on the grounds that the company
intends to rely on Rule 3a-8. We reissue our request for a comprehensive analysis of the
company’s status under Section 3(a)(1)(C) (including the detailed statutory calculation),
as this is fundamental to the staff’s general assessment of the company’s investment
company status and could become critically important if it is found that the company is
unable to rely on Rule 3a-8.
            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