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CORRESP
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SunCar
Technology Group Inc.

c/o
Shanghai Feiyou Trading Co., Ltd.

Suite
209, No. 656 Lingshi Road

Jing’an
District, Shanghai, 200072

People’s
Republic of China

  March
  9, 2023

Via
Edgar

Cara
Wirth/Donald Field

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:

    SunCar
    Technology Group Inc.

    Amendment
    No. 1 to Registration Statement on Form F-4

    Filed
    February 24, 2023, File No. 333-269295

Dear
Ms. Wirth and Mr. Field:

We
have set forth below responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the
“SEC”) contained in its letter of March 7, 2023 with respect to the Amendment No. 1 to Registration Statement on Form F-4
(the “F-4/A”) filed with the SEC on February 24, 2023 by SunCar Technology Group Inc. (the “Company”). For your
convenience, the text of the Staff’s comments is set forth below followed in each case by the Company’s response. Please
note that all references in the responses refer to the relevant revisions in the Amendment No. 2 to the Registration Statement on Form
F-4 (the “F-4/A No.2”) filed with the SEC concurrently with the submission of this letter.

Each
of the responses by the Company to the Staff’s comments is set forth in bold below, following each comment.

Amendment
No. 1 to Registration Statement on Form F-4 Filed February 24, 2023

Questions
and Answers about the Business Combination and the Extraordinary General Meeting Q: What is the effect of the GEM Purchase Agreement?
page 12

1. We
                                            note your amended disclosure in response to comment 7 and we reissue it in part. In the answer
                                            to this Question and in the Risk Factor on page 72, please revise to quantify the number
                                            of securities that may be issued under the GEM Purchase Agreement and any possible negative
                                            impact on future stock prices as a result.

Response:
In response to the Staff’s comment, the Company has revised the answer to the Question on page 12 and the Risk Factor on page 72
in the F-4/A No. 2.

Summary
of the Proxy Statement/Prospectus

Regulatory
Approvals, page 20

2. We
                                            note your amended disclosure regarding the Provisions on Strengthening Confidentiality and
                                            Archives Administration of Overseas Securities Offering and Listing by Domestic Companies,
                                            or the Confidentiality and Archives Provisions, announced on February 24, 2023. Please revise
                                            to discuss in detail:

 ● the
                                            provisions, including whether the provisions apply beyond the initial issuance and listing
                                            period;

 ● the
                                            applicability of the provisions to you and your subsidiaries;

 ● the
                                            compliance requirements, and if those requirements are currently uncertain, please state
                                            as much; and

 ● the
                                            risks of non-compliance.

Additionally,
please revise to define “work manuscripts” and provide examples of such documents that might be generated by securities companies
and securities service institutions. Please also name the “competent authorities” that are required to approve the work manuscripts
and describe the relevant “approval procedures” that must be followed in order to transfer such documents outside of the
PRC. If you already have the relevant confidentiality and archives management systems in place, please revise to state as much.

Response:
In response to the Staff’s comment, the Company has revised disclosures regarding the Confidentiality and Archives Provisions in
the Regulatory Approvals on page 21, Risk Factors on pages 53 and 69, and “CSRC Regulations of Overseas Securities Offering and
Listing by Domestic Companies” on page 196 of the F-4/A No.2.

Unaudited
Pro Forma Condensed Combined Balance Sheet, page 164

3. Please
                                            revise to put footnote (2) next to the pro forma adjustments decreasing amounts due to related
                                            party, current, and note payable to related party.

Response:
In response to the Staff’s comment, the Company has revised page 164 to put footnote (2) next to the pro forma adjustments describing
amounts due to related party, current, and note payable to related party.

Unaudited
Pro Forma Condensed Combined Statement of Operations

For
the Six Months Ended December 31, 2022, page 165

4. It
                                            appears that adjustment (1) decreasing general and administrative expenses for the six months
                                            ended December 31, 2022 by $575,000 should not be included in your pro forma statement of
                                            operations for this period. This adjustment has already been included as a pro forma adjustment
                                            in the unaudited pro forma condensed statement of operations for the year ended June 30,
                                            2022 and footnote (1) on page 169 indicates that these are costs that will be expensed upon
                                            the closing of the business combination, as if it occurred on July 1, 2021, and are non-recurring.
                                            Please revise or advise.

Response:
In response to the Staff’s comment, the Company has revised page 165 to remove the adjustments related to general and administrative
in accordance with the Staff’s instruction. In addition, the Company also revised page 30 and 169 to reflect the revision on page
165.

Consolidated
Financial Statements of Auto Services Group Inc., page F-1

5. Since
                                            this is an initial registration of Suncar’s Class A ordinary shares, please update
                                            to include audited financial statements for Auto Services Group Inc. for the year ended December
                                            31, 2022. Alternatively, please provide as an exhibit to your filing, a representation by
                                            management that this entity is not required to comply with the 12-month requirement in any
                                            other jurisdiction outside the United States and that complying with the 12-month requirement
                                            is impracticable or involves undue hardship. Refer to the Instructions to Item 8.A.4 of Form
                                            20-F.

Response:
In response to the Staff’s comment, the Company has provided an exhibit to the F-4/A No.2 a representation letter by management
according to Instructions to Item 8.A.4 of Form 20-F.

Should
you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please call or email our
legal counsel, Giovanni Caruso at (212) 407-4866, gcaruso@loeb.com. Thank you for your time and attention to this filing.

    Sincerely,

    /s/
    Yongsheng Liu

    Yongsheng
    Liu

    Sole
    Director

    cc:
    Giovanni
    Caruso, Esq.