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 July 7, 2025

Jinhong Deng
Chief Executive Officer
Yimutian Inc.
6/F, Building B-6, Block A
Zhongguancun Dongsheng Technology Campus
No. 66 Xixiaokou Road
Haidian District, Beijing 100192
People s Republic of China

 Re: Yimutian Inc.
 Registration Statement on Form F-1
 Filed June 9, 2025
 File No. 333-287877
Dear Jinhong Deng:

 We have reviewed your registration statement and have the following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form F-1
Summary Consolidated Financial Data and Operating Data, page 17

1. Please present in a separate column in the condensed consolidating
schedules the
 financial position, cash flows, and results of operations of the WFOE as
of and for
 the years ended December 31, 2023 and 2024. Also, present as separate
line
 items, disaggregated intercompany amounts such as for intercompany
receivables and
 payables.
2. In light of the total shareholders deficit balances of your other
subsidiaries, VIEs and
 VIEs' subsidiaries, it is unclear why Yimutian Inc. is reporting a
long-term
 investments balance of RMB 507,962. Please clarify and advise us. Also,
revise the
 description of the long-term investments line-item to more clearly
describe its nature.
 July 7, 2025
Page 2

 In this regard, identifying your interest in the VIEs as an investment
may be confusing
 since you do not own the equity of the VIEs.
3. Please explain to us why the amounts reported for Yimutian Inc. in the
condensed
 consolidating schedules does not agree with the corresponding amounts
reported
 in the parent only financial information in Note 28.
Share-based Compensation, page F-34

4. Please add a rollforward of activity for share-based options for the
most recent year
 for which an income statement is provided. Refer to ASC
718-10-50-2(c)(1). Please
 also revise to disclose the key assumptions used to estimate the fair
value of options
 granted in 2024.
Revenue Information, page F-40

5. Please expand your revenue disclosure to include a reconciliation of
contract
 liabilities. Refer to ASC 606-10-50-8.
Fair Value Measurement, page F-41

6. Please revise to disclose the key assumptions used to estimate the fair
value of
 exchangeable notes as of December 31, 2024.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Anastasia Kaluzienski at 202-551-3685 or Robert
Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements
and related
matters. Please contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin
at 202-
551-3574 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Shu Du
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