SecProbe.io

CORRESP
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 filename1.htm

 Skadden,
Arps, Slate, Meagher & Flom

 世達國際律師事務所

 Partners
 42/F, EDINBURGH TOWER, THE LANDMARK
 Affiliate Offices

 Geoffrey Chan *
 15 QUEEN'S ROAD CENTRAL, HONG KONG
 ------------

 Shu Du *
 _______
 Boston

 Andrew L. Foster *

 Chicago

 Chi T. Steve Kwok *
 TEL: (852) 3740-4700
 Houston

 Haiping Li *
 FAX: (852) 3740-4727
 Los angeles

 Rory McAlpine ¨
 www.skadden.com
 New york

 Jonathan B. Stone *

 Palo Alto

 Paloma P. Wang ¨

 Washington, D.C.

 Friven Yeoh ¨

 Wilmington

 ¨ ( Also Admitted In England & Wales)

 ------------

 * (also Admitted In New York)

 Abu Dhabi

 Beijing

 Registered Foreign Lawyer

 Brussels

 Yuting Wu (New York)

 Frankfurt

 London

 Munich

 Paris

 São Paulo

 Seoul

 Singapore

 Tokyo

 Toronto

 June
9 , 2025

 VIA EDGAR

 Mr.
 Robert Littlepage

 Ms. Claire DeLabar

 Mr. Mitchell Austin

 Ms. Charli Wilson

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re: Yimutian Inc. (CIK No. 0001991605)
 Response to the Staff's Comments on the Draft Registration Statement on
Form F-1 Confidentially Submitted on February 7, 2024

 Dear Mr. Littlepage, Ms. DeLabar, Mr. Austin, and Ms. Wilson:

 On behalf of our client, Yimutian Inc., a foreign
private issuer organized under the laws of the Cayman Islands (the " Company "), we submit to the staff (the " Staff ")
of the Securities and Exchange Commission (the " Commission ") this letter setting forth the Company's responses
to the comments contained in the Staff's letter dated February 26, 2024 on the Company's draft registration statement on Form
F-1 confidentially submitted on February 7, 2024 (the " Draft Registration Statement ").

 U.S. Securities and Exchange Commission

 June 9, 2025

 Page 2

 Concurrently with the submission of this letter,
the Company is filing the registration statement on Form F-1 (the " Registration Statement ") and certain exhibits via
EDGAR with the Commission. In accordance with the Jumpstart Our Business Startups Act, as amended, the Company is, concurrently with the
Registration Statement, filing the draft registration statement and all amendments thereto that were previously submitted for the non-public
review of the Staff.

 The Staff's comments are repeated below in
bold and are followed by the Company's responses. The Company has included page references in the Registration Statement where the
language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth
in the Registration Statement.

 Comments in Letter Dated February 26, 2024

 Amendment No. 1 to Draft Registration Statement to Form F-1
submitted February 7, 2024

 Prospectus Summary

 Who Are We, page 1

 1. We note your reliance on open source and third-party models for your various aspects of your business (e.g., collection of supply
information, customer service, and demand). Please include a risk factor addressing the risk to your business, financial results and operations
associated with your reliance on open-source and third party models.

 In response to the Staff's comment, the Company has
revised the disclosure on page 45 of the Registration Statement.

 Contractual Arrangements and Corporate Structure, page 9

 2. Please revise your disclosure here and on page 94 to remove all references to "direct ownership" to remove any inference
that the Company has direct ownership of the contractual arrangements with the VIE.

 In response to the Staff's comment, the Company has
revised the disclosure on pages 9 and 87 of the Registration Statement.

 U.S. Securities and Exchange Commission

 June 9, 2025

 Page 3

 Business

 Our Strengths, page 123

 3. Please remove the term "indisputable" from the title of this section, as your position as the "largest agricultural
B2B platform in mainland China" is able to be challenged or contested .

 In response to the Staff's comment, the Company has
revised the disclosure on pages 5 and 112 of the Registration Statement.

 Financial Statements, page F-1

 4. Please include unaudited interim financial statements for at least the first six months of fiscal 2023 and 2022 in the filing since
the effectiveness of the registration statement is more than 9 months after the last audited financial year. Please also revise the financial
information and MD&A accordingly.

 The Staff's comment is duly noted. The Company has
included the audited consolidated financial statements as of and for the years ended December 31, 2023 and 2024 in the Registration
Statement and revised the financial information and MD&A accordingly. As such, the Company has not included unaudited interim
financial statements for the first six months of fiscal 2023 and 2022 in the Registration Statement. The Company expects to include
interim financial statements of fiscal year 2025 as appropriate in a subsequent filing.

 Note 22. Subsequent Events, page F-47

 5. Please expand the disclosure to include the amount of the share-based compensation and deemed dividend
to be recognized in December 2023.

 The Company has disclosed the amount of the share-based compensation
and deemed dividend in its 2023 full year consolidated financial statements on pages F-5 and F-7 of the Registration Statement.

 * * *

 If you have any questions regarding the Registration
Statement, please contact the undersigned by phone at +852 3740-4858 or via e-mail at shu.du@skadden.com.

 Very truly yours,

 /s/ Shu Du

 Shu Du

 cc: Mr. Jinhong Deng, Chief Executive Officer, Yimutian Inc.

 Mr. Shijie Chen, Chief Financial Officer, Yimutian Inc.

 Ms. Dan Ouyang, Esq., Partner, Baker McKenzie LLP