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United States securities and exchange commission logo
June 6, 2023
Botao Ma
Chief Executive Officer
Zhibao Technology Inc.
Floor 3, Building 6, Wuxing Road, Lane 727
Pudong New Area, Shanghai 201204
Re:Zhibao Technology Inc.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted May 18, 2023
CIK No. 0001966750
Dear Botao Ma:
            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.
Form DRS S-1 submitted May 18, 2023
General
1.Please revise to include interim financial statements at a minimum for the period ended
December 31, 2022, covering the first six months of fiscal year 2023, in your next
amendment.
Accounts Receivable, Net, page F-11
2.We note your policy disclosure on page F-11 that "[a]ccount balances are charged off
against the allowance after all means of collection have been exhausted and the potential
for recovery is considered remote" and your aging of accounts receivable on page F-18
that indicates accounts receivable of RMB 517,202 and RMB 536,655 were greater than

 FirstName LastNameBotao Ma
 Comapany NameZhibao Technology Inc.
 June 6, 2023 Page 2
 FirstName LastName
Botao Ma
Zhibao Technology Inc.
June 6, 2023
Page 2
one year past due as of June 30, 2021 and 2022, respectively. We also note that you
did not write-off any accounts receivable during those periods.  Please tell us and revise to
disclose how much greater than one year these accounts receivable are past due and
how you determined the potential for recovery was not remote.
Insurance brokerage services, page F-12
3.We note your response to comment 24. Please tell us and revise to clarify if you have the
contractual right to receive renewal fees other than incentives on renewal contracts. If you
do have the contractual right to receive renewal fees other than incentives on renewal
contracts please disclose which insurance products that applies to and quantify the amount
of renewal fees recognized.
4.We note your response to comment 24 and your disclosure on page F-12 that "[w]hen the
insurance policies are renewed for more than one year, a higher commission fee rate is
applied retrospectively.” Please tell us the specific authoritative US GAAP guidance that
is the basis for your accounting policy.  In addition, to the extent you only have the right
to receive incentive income on renewals, please tell us and revise to reconcile the
aforementioned policy with the following policy disclosure on page F-12 that “[t]he
Company did not include such an incentive in the transaction price because the Company
cannot reliably estimate the variable consideration as it lacked sufficient historical renew
information. Because the Company does not expect material incentives in the future, the
Company will recognize incentives as revenues upon confirmation with the insurance
companies.”
3 - Accounts Receivable, page F-17
5.We note the headings “Less than 1 year” and “Over 1 year” in your aging of accounts
receivable table on page F-18. Please revise to separately present the amounts of your
accounts receivable that are past due, i.e., greater than 60 days.
6.We note your response to comment 26 that you do not determine delinquency status of
accounts receivables until the insurance suppliers file a bankruptcy or liquidation with the
Court. Please tell us and revise to disclose if this means that you do not write-off an
accounts receivable until the insurance supplier files for bankruptcy or liquidation with the
Court.
7.We note your response to comment 26. Please revise your accounts receivable policy on
page F-11 to disclose that accounts older than 60 days are considered past due, consistent
with your response.

 FirstName LastNameBotao Ma
 Comapany NameZhibao Technology Inc.
 June 6, 2023 Page 3
 FirstName LastName
Botao Ma
Zhibao Technology Inc.
June 6, 2023
Page 3
8.We note your response to comment 27. Please refer to the guidance in ASC 310-10-50-
11B and revise to include a roll forward of the activity in the allowance for doubtful
accounts for all of its components and for each period presented. In addition, please revise
your disclosure in the “Results of Operations” section to discuss the changes in your
allowance for doubtful accounts or lack thereof, considering the significant variation in
the amount of and aging of your accounts receivable at each period end.
            You may contact William Schroeder at 202-551-3294 or Amit Pande at 202-551-3423 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Madeleine Mateo at 202-551-3465 or John Dana Brown at 202-551-3859 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Richard I. Anslow