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United States securities and exchange commission logo
May 2, 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. 6 to
Draft Registration Statement on Form F-1
Submitted April 5, 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.
Amendment No. 6 to Draft Registration Statement on Form F-1
General
1.We note that the Company offers corporate learning solutions that are subscription based,
non-subscription based, as well as software developed for others through non-subscription
based solutions. Please tell us the amount of R&D recognized by the Company associated
with the development of each learning solution. Also, please provide the relevant GAAP
references supporting recognition of R&D associated with each learning solution revenue
stream.

 FirstName LastNamePun Leung Liu
 Comapany NameYXT.COM Group Holding Limited
 May 2, 2023 Page 2
 FirstName LastName
Pun Leung Liu
YXT.COM Group Holding Limited
May 2, 2023
Page 2
2.The Company indicated that “ASC Topic 985-20-25-1 clarifies and confirms that the costs
of developing an issuer’s computer software products… are indeed ‘research and
development costs’ for purposes of ASC Topic 730”. You disclose that the Company’s
subscription-based services generally do not provide customers with the right to take
possession of the software supporting the platform. Accordingly, it appears that your
subscription-based services do not meet the criteria of ASC 985-20-15-5 to be in the scope
of ASC 985-20 and would alternatively be in the scope of ASC 350-40. Please further
clarify how you have considered the guidance in ASC 350-40 to capitalize or expense
costs associated with your subscription based service offering.
3.The Company has disclosed that research and development expenses consist principally of
research and development activities including employee-related costs for personnel
engaged in content development and technology development, consulting services, rental
expenses for office space and other costs associated with product development efforts.
Please clarify how the Company determined whether such expenses represented cost of
revenues or R&D. Please cite the relevant GAAP guidance. In addition, to the extent that
you consider content creation to be part of R&D, please describe whether such expenses
relate to existing cloud-based learning platform subscriptions and clarify if the company
considers such expenses to be cost of revenues or R&D, citing the relevant GAAP
guidance.
            Please contact Asaf Barouk, Attorney Advisor, at 202-551-4029 with any questions about
the above. You may contact 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