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June 10, 2024
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. 9 to Draft Registration Statement on Form F-1
Submitted May 28, 2024
CIK No. 0001872090
Dear Pun Leung Liu:
            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
November 21, 2023 letter.
Amendment No. 9 to Draft Registration Statement on Form F-1
Prospectus Summary
Recent Development, page 15
1.We note your disclosure that you lost control of CEIBS PG and as a result it will be
deconsolidated from your consolidated financial statements from January 15, 2024. Given
the significant impact this will have on your financial statements, please revise to provide
full pro forma financial statements as if control was lost as of the earliest period presented.
Refer to Article 11 of Regulation S-X.

 FirstName LastNamePun Leung Liu
 Comapany NameYXT.COM Group Holding Limited
 June 10, 2024 Page 2
 FirstName LastName
Pun Leung Liu
YXT.COM Group Holding Limited
June 10, 2024
Page 2
Capitalization, page 88
2.Please revise to reflect both your capitalization and indebtedness for each scenario
presented. Refer to guidance in Item 3.B of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Material Cash Requirements, page 121
3.Revise your disclosure and the table to include your short-term and long-term borrowings
and related interest payments.
Critical Accounting Policies and Estimates
Goodwill, page 124
4.We note that you performed a quantitative goodwill impairment analysis that considered
the final decision of the HKIAC arbitration tribunal on January 15, 2024. Please tell us the
percentage by which the estimated fair value of your reporting unit exceed the carrying
value for this goodwill impairment test. If the reporting unit is at risk of impairment,
disclose the percentage by which the fair value exceeded the carrying value and describe
any potential events and/or changes in circumstances that would reasonably be expected
to negatively affect any key assumptions. If you determined that the fair value
substantially exceeded the carrying value of your reporting unit please disclose that fact.
Principal Shareholders, page 177
5.We note your disclosure that the 16,931,824 issued and outstanding ordinary shares held
by Unicentury Holdings Limited, beneficially owned by Mr. Xiaoyan Lu, will be re-
designated into Class B ordinary shares, and that this will give him effective control of the
company. Please disclose whether Mr. Xiaoyan Lu exchanged any consideration to the
company as part of this re-designation.
Consolidated Financial Statements
11. Short-Term and Long-Term Borrowings, page F-43
6.Please revise to disclose the combined aggregate amount of maturities for all long-term
borrowings for each of the five years following the date of the latest balance sheet
presented. Refer to ASC 470-10-50-1. Additionally, revise to disclose the terms of
repayment for each of your loans that supports the amount classified as short-term
borrowings as of December 31, 2023. To the extent any amounts due within the next 12-
months are excluded from short-term borrowings, explain why and provide the accounting
guidance you relied on to support your presentation. Refer to ASC 470-10-50-4.

 FirstName LastNamePun Leung Liu
 Comapany NameYXT.COM Group Holding Limited
 June 10, 2024 Page 3
 FirstName LastName
Pun Leung Liu
YXT.COM Group Holding Limited
June 10, 2024
Page 3
            Please contact Brittany Ebbertt at 202-551-3572 or Chris Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters. Please
contact Lauren Pierce at 202-551-3887 or Jan Woo at 202-551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Li He