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TUNGRAY TECHNOLOGIES
INC.

November 8, 2023

Mr. Kyle Wiley

Staff Attorney

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    Tungray Technologies Inc.

    Amendment No. 5 to Registration Statement on Form
    F-1

    Filed October 4, 2023

    File No. 333-270434

Dear Mr. Wiley:

This
letter is in response to the letter dated October 30, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) addressed Tungray Technologies Inc. (the
“Company,” “we,” and “our”). For ease of reference, we have recited the Commission’s comments
in this response and numbered them accordingly. The amendment to Registration Statement on Form F-1 (the “Registration Statement”)
is being filed to accompany this letter.

Amendment No. 5 to Registration Statement
on Form F-1

Risk Factors

Risks Related to Doing Business in Singapore

Any adverse material changes to the Singapore
market (whether localized or resulting from

economic or other conditions)..., page
51

 1. We note
                                            your disclosure that the spread of COVID-19 did not have any material impact on the Company’s
                                            business during the six months ended June 30, 2023, and the years ended December 31, 2022
                                            and 2021. We also note your disclosure on page 85 that "during the six months ended
                                            June 30, 2023, due to the end of the COVID-19 pandemic, the market needs for printers and
                                            other automation equipment returned to a normal level which resulted in a sharp decrease
                                            in the new purchase demand of customers in 2023." Please revise your discussion regarding
                                            the impact of the COVID-19 pandemic or advise.

Response: The Company has
modified the relevant description of the impact of the COVID-19 pandemic on the Company's business during the six months ended June 30,
2023 on page 22-23, 36, 52, 83, 84 and F-30.

Kyle Wiley

Staff Attorney

November 8, 2023

Page 2 of 4

Management's Discussion and Analysis
of Financial Condition and Results of Operations of

Tungray

Key Factors Affecting Results of Operations,
page 82

 2. We note
                                            that management considers customer retention a key factor affecting your results of operations.
                                            We also note that your overall customer retention rates decreased from 52.2% during the six
                                            months ended June 30, 2022, to 45.6% during the same period in 2023, which is also a decrease
                                            from the 48.8% retention rate for fiscal year 2022. Please revise to include a discussion
                                            of the reasons for this decrease.

Response: The Company has
included the reasons for the decrease in customer retention on page 83.

Financial Statements

Note 2. Summary of significant accounting
policies

Prepayments, page F-10

 3. It is unclear
                                            if the disclosed policy for prepayments on page F-10 is applicable to prepaid expenses or
                                            perhaps another asset such as receivables. Please revise your policy disclosure, if necessary,
                                            and advise us.

Response: The Company has
modified the policy disclosure for prepayments on page F-10.

Note 17. Subsequent events, page F-30

 4. Please
                                            revise to disclose the date through which you evaluated subsequent events. Refer to ASC 855-10-50-1(a).

Response: The Company has
revised to disclose the date through which it evaluated subsequent events on page F-30.

General

 5. We note
                                            the changes you made to your disclosure appearing on the cover page, Summary and Risk Factor
                                            sections relating to legal and operational risks associated with operating in China and PRC
                                            regulations. It is unclear to us that there have been changes in the regulatory environment
                                            in the PRC since the amendment that was filed on June 27, 2023, warranting revised disclosure
                                            to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based
                                            Companies sought specific disclosure relating to the risk that the PRC government may intervene
                                            in or influence your operations at any time, or may exert control over operations of your
                                            business, which could result in a material change in your operations and/or the value of
                                            the securities you are registering for sale. The Sample Letters also sought specific disclosures
                                            relating to uncertainties regarding the enforcement of laws and that the rules and regulations
                                            in China can change quickly with little advance notice. We do not believe that your revised
                                            disclosure referencing the PRC government’s intent to strengthen its regulatory oversight
                                            conveys the same risk. Please revise or advise.

Kyle Wiley

Staff Attorney

November 8, 2023

Page 3 of 4

Response: The Company has
revised the disclosures relating to legal and operational risks associated with operating in China and PRC regulations throughout the
Registration Statement, including on pages 3, 5, 18-19, 21, 24, 26-27, 49-50, 53-57, 59-62, 75, 122, 159, and 167.

We
appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel,
Jinhua (Anna) Wang, Esq., of Robinson & Cole LLP, at (212) 451-2942.

[Signature Page Follows]

Kyle Wiley

Staff Attorney

November 8, 2023

Page 4 of 4

    Very truly yours,

    By:
    /s/ Wanjun Yao

    Wanjun Yao

    Chief Executive Officer

cc:

Jinhua (Anna) Wang, Esq.

Robinson & Cole LLP

[signature page to
the SEC response letter]