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Correspondence 0001213900-26-013771 from Yimutian Inc. (YMT)

Yimutian Inc.
Date: Feb. 9, 2026 · CIK: 0001991605 · Accession: 0001213900-26-013771

Offering / Registration Process Regulatory Compliance Business Model Clarity

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Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
Feb. 9, 2026
Author
/s/ Shu Du
Form
CORRESP
Company
Yimutian Inc.

Letter

VIA EDGAR Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Yimutian Inc. (CIK No. 0001991605) Registration Statement on Form F-1

Dear Sir/Madam,

On behalf of our client, Yimutian Inc., a foreign private issuer organized under the laws of the Cayman Islands (the " Company "), we are filing herewith the Company's registration statement on Form F-1 (the " Registration Statement ") and certain exhibits via EDGAR with the Securities and Exchange Commission (the " Commission ") in connection with a proposed registered public offering (the " Proposed Offering ") of the Company's Class A ordinary shares, par value US$0.00001 per share, to be represented by American depositary shares (" ADSs ").

In accordance with the Jumpstart Our Business Startups Act, as amended, the Company is, concurrently with the Registration Statement, filing the draft registration statement that was previously submitted for the non-public review of the staff of the Commission (the " Staff ").

Draft Registration Statement

U.S. Securities and Exchange Commission

February 9, 2026

Page 2

The Company plans to request that the Commission declare the effectiveness of the Registration Statement on or about February 11, 2026. To that end, the Company, together with the placement agent for the Proposed Offering, will promptly submit joint acceleration requests following the filing of the Registration Statement. The Company would greatly appreciate the Staff's timely assistance and support to the Company in meeting the proposed timetable for the Proposed Offering.

* * *

Draft Registration Statement

U.S. Securities and Exchange Commission

February 9, 2026

Page 3

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

Show Raw Text
CORRESP
 1
 filename1.htm

 Skadden, Arps, Slate, Meagher & Flom

 Partners
 Geoffrey Chan *
 Shu Du *
 Andrew L. Foster *
 Chi T. Steve Kwok *
 Haiping Li *
 Jonathan B. Stone *
 Paloma P. Wang ¨
 Friven Yeoh ¨
 ¨
 (Also Admitted in England & Wales)
 *
 (Also Admitted in New York)

 世達國際律師事務所

 42/F, EDINBURGH TOWER, THE
LANDMARK

 15 QUEEN'S ROAD CENTRAL,
HONG KONG

 ________

 TEL: (852) 3740-4700

 FAX: (852) 3740-4727

 www.skadden.com

 AFFILIATE OFFICES -----------
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 HOUSTON
 LOS ANGELES
 NEW YORK
 PALO ALTO WASHINGTON D.C. WILMINGTON
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SEOUL
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TOKYO
 TORONTO

 February 9, 2026

 VIA EDGAR

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re: Yimutian Inc. (CIK No. 0001991605)
 Registration Statement on Form F-1

 Dear Sir/Madam,

 On behalf of our client, Yimutian Inc., a foreign
private issuer organized under the laws of the Cayman Islands (the " Company "), we are filing herewith the Company's
registration statement on Form F-1 (the " Registration Statement ") and certain exhibits via EDGAR with the Securities
and Exchange Commission (the " Commission ") in connection with a proposed registered public offering (the " Proposed
Offering ") of the Company's Class A ordinary shares, par value US$0.00001 per share, to be represented by American depositary
shares (" ADSs ").

 In accordance with the Jumpstart Our Business
Startups Act, as amended, the Company is, concurrently with the Registration Statement, filing the draft registration statement that
was previously submitted for the non-public review of the staff of the Commission (the " Staff ").

 Draft Registration Statement

 U.S. Securities and Exchange Commission

 February 9, 2026

 Page 2

 The Company plans to request that the Commission
declare the effectiveness of the Registration Statement on or about February 11, 2026. To that end, the Company, together with the
placement agent for the Proposed Offering, will promptly submit joint acceleration requests following the filing of the Registration
Statement. The Company would greatly appreciate the Staff's timely assistance and support to the Company in meeting the proposed
timetable for the Proposed Offering.

 * * *

 Draft Registration Statement

 U.S. Securities and Exchange Commission

 February 9, 2026

 Page 3

 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: Jinhong Deng, Chief Executive Officer and Chairman of the Board of Directors,
 Yimutian Inc.

 Shijie Chen, Chief Financial Officer, Yimutian Inc.