SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 29, 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.
 Amendment No. 1 to Registration Statement on Form F-1
 Filed July 22, 2025
 File No. 333-287877
Dear Jinhong Deng:

 We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our July 7, 2025
letter.

Amendment No. 1 to Registration Statement on Form F-1
Cash Flows Through Our Organization, page 11

1. We note your disclosure in this amendment that in 2023 and 2024, the
WFOE made
 payments to the VIEs for intragroup transactions in the amounts of RMB
30.0 million
 and RMB 2.8 million, respectively. We also note your disclosure on page
11 of the
 registration statement on Form F-1 filed on June 9, 2025 that in 2023
and 2024, the
 WFOE made payments to the VIEs for intragroup transactions in the
amounts of
 RMB 64.8 million and RMB 67.6 million. Please tell us in sufficient
detail the reason
 for this change.
 July 29, 2025
Page 2

Summary Consolidated Financial Data and Operating Data, page 17

2. Please revise so that the presentations of financial information in
tabular form read
 consistently from left to right in the same chronological order
throughout the filing.
 Similarly, numerical data included in narrative sections should be
consistently
 ordered. We refer you to the guidance in SAB Topic 11:E.
3. We note your response to prior comment 1 and reissue in part. Please
present as
 separate line items, disaggregated intercompany amounts. The objective
of this
 disclosure is to allow an investor to evaluate the nature of assets held
by, and the
 operations of, entities apart from the VIE, as well as the nature and
amounts
 associated with intercompany transactions.
4. Please explain to us why the balance sheet amounts reported for the VIEs
and VIEs'
 Subsidiaries in the condensed consolidating schedules do not agree with
the
 corresponding consolidated assets and liabilities information of the
Group s VIEs as
 of December 31, 2023 and 2024 reported in Note 1. In this regard the
consolidated
 assets and liabilities information of the Group's VIEs reported in Note
1 should
 present the carrying amounts prior to intercompany eliminations. In
addition, the
 presentation should be sufficiently disaggregated to disclose
significant intercompany
 balances. We refer you to ASC 810-50 paragraphs 2AA.d and 3.bb.
Dilution, page 85

5. Revise to clarify that on both a historical and pro forma basis you have
a net tangible
 deficit, not book value. In addition, you should clarify that after
giving effect to your
 sale of ADSs in the offering there will be a pro forma as adjusted net
tangible deficit,
 and the offering will result in an immediate decrease in net tangible
deficit to existing
 shareholders. Similarly, revise the line-item descriptions of the per
share and ADS
 amounts, as needed, to accurately reflect the amounts presented.
Index to Financial Statements, page F-1

6. We note that you have provided the unaudited interim consolidated
financial
 statements as of and for the three-month period ended March 31, 2025. In
this regard,
 please revise to clearly label your interim financial statement
information as
 "unaudited" where appropriate throughout the filing, including, but not
limited to the
 following sections: summary of consolidated financial data and operating
data,
 capitalization, dilution, selected combined financial and other data,
management s
 discussion and analysis of the financial condition and results of
operations.
Parent Company Only Condensed Financial Information, page F-81

7. We note your response to prior comment 3 indicating that the information
in Note 28
 reflects Yimutian Inc.'s financials after eliminating all intercompany
transactions and
 balances. Parent company only financial information should report the
actual balances
 on the parent company's books. Please revise as necessary or advise us.
 July 29, 2025
Page 3

 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
</TEXT>
</DOCUMENT>