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December 14, 2023
Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
401, 4 / F, Building 12
1601 South Guangzhou Avenue
Haizhu District, Guangzhou, Guangdong, PRC
Re:YSX Tech Co., Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted November 17, 2023
File No. 377-06871
Dear Jie Xiao:
            We have reviewed your amended draft registration statement and have the following
comments.
            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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted November 17, 2023
Cover Page
1.We note your response to prior comment 2 that "there have not been recent statements or
regulatory actions by the Chinese government related to the use of variable interest
entities since the submission of our draft registration statement on September 15,
2023." We also note that your revised disclosure references regulations that came into
effect in the past ten months. Please note that our request for disclosure regarding "how
recent statements and regulatory actions by China's government, such as those related to
the use of variable interest entities and data security or anti-monopoly concerns, have or
may impact the company's ability to conduct its business, accept foreign investment, or
list on a U.S. or other foreign exchange" is not limited to statements and actions made
since the submission of your registration statement or since the beginning of this year, but

 FirstName LastName Jie Xiao
 Comapany NameYSX Tech Co., Ltd
 December 14, 2023 Page 2
 FirstName LastName
 Jie Xiao
YSX Tech Co., Ltd
December 14, 2023
Page 2
to relevant statements and actions since the Sample Letter to China-Based Companies was
issued in December 2021. Please further revise your disclosure accordingly. To the extent
you disclose that no such statements and regulatory actions have or may impact your
ability to conduct your business, accept foreign investment, or list on a foreign exchange,
please clarify if you are relying on the opinion of counsel in making such determinations
and, if not, why not. If you are not relying on the opinion of counsel, please discuss the
bases for such determinations.
2.We note your response to prior comment 4 that "we are the primary beneficiary and
receive the economic benefits of the VIEs to the extent that we consolidate the financial
results of the VIEs in our consolidated statements under U.S. GAAP." However, your
revised disclosure states that "we are the primary beneficiary of the VIEs to the extent that
we consolidate the financial results of the VIEs in our consolidated statements under U.S.
GAAP, as we receive the economic benefits of the VIEs through certain contractual
arrangements . . . ." Revise to conform with your response, and particularly clarify that
you receive the economic benefits of the VIEs only to the extent that you consolidate the
financial results of the VIEs in your consolidated statements under U.S. GAAP, as you
state in your response. Please make conforming changes on page 1 of the prospectus
summary and also make applicable changes where you state that the "WFOE has the right
to receive substantially all of the economic benefits of the VIEs" without qualifying such
statement with disclosure of the conditions you have satisfied for consolidation of the
VIEs under U.S. GAAP. Also make conforming changes on page 2 and in your risk factor
entitled "We may not be able to consolidate the financial results . . . " on page 39. In this
regard, any references to control or benefits that accrue to you because of the VIEs should
be limited to a clear description of the conditions you have satisfied for consolidation of
the VIEs under U.S. GAAP.
            Please contact Patrick Kuhn at 202-551-3308 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Linda Ni