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Correspondence 0001104659-24-097329 from YSX Tech Co., Ltd (YSXT)

YSX Tech Co., Ltd
Date: Sept. 5, 2024 · CIK: 0001993463 · Accession: 0001104659-24-097329

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File numbers found in text: 333-280312

Referenced dates: August 9, 2024

Date
September 5, 2024
Author
/s/ Jie Xiao
Form
CORRESP
Company
YSX Tech Co., Ltd

Letter

Via Edgar Division of Corporation Finance Office of Trade & Services Washington, D.C., 20549 Re: YSX Tech Co., Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed August 9, 2024 File No. 333-280312

Dear Mr. Fetterolf,

This letter is in response to the letter dated August 9, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to YSX Tech Co., Ltd (the “Company”, “we”, or “our”). For ease of reference, we have recited the Commission’s comments in this response. An amendment to the registration statement on Form F-1 is being filed to accompany this letter (the “Amendment”).

Amendment No. 1 to Registration Statement on Form F-1 filed on August 9, 2024

Risk Factors, page 23

1. We note your revised disclosure in response to comment 1. Please further revise the second risk factor to restore the language in the body of the risk factor, as you did in the title of the risk factor, that "PRC laws and regulations...can change quickly with little advance notice." Also restore the language that "it may be more difficult to evaluate the outcome of administrative and court proceedings and the level of legal protection we enjoy in the mainland China legal system than in more developed legal systems."

Response: We acknowledge Staff’s comment and further revised the second risk factor to restore the language in the body of the risk factor, that "PRC laws and regulations...can change quickly with little advance notice." We also restored the language that "it may be more difficult to evaluate the outcome of administrative and court proceedings and the level of legal protection we enjoy in the mainland China legal system than in more developed legal systems."

Exhibit 99.7

2. We re-issue comment 6. Please revise section 1.2.1 of the opinion to exclude the PRC Companies. We also note that you revised section 1.2.2 of the opinion to delete the exclusion of the PRC Companies; please revise to restore the original language excluding the PRC Companies from each of (a) and (b).

Response: We acknowledge Staff’s comment and have revised section 1.2.1 of the opinion to exclude the PRC Companies. We have also restored the original language excluding the PRC Companies from each of (a) and (b) of section 1.2.2 of the opinion.

We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.

Very truly yours,
/s/ Jie Xiao

Show Raw Text
CORRESP
1
filename1.htm

September 5, 2024

Via Edgar

Mr. Brian Fetterolf

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

  Re:
  YSX Tech Co., Ltd

  Amendment No. 1 to Registration Statement on Form F-1 Filed August 9, 2024

  File No. 333-280312

Dear Mr. Fetterolf,

This letter is in response to the letter
dated August 9, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to YSX Tech Co., Ltd (the “Company”, “we”, or “our”). For ease of reference, we have recited
the Commission’s comments in this response. An amendment to the registration statement on Form F-1 is being filed to accompany this
letter (the “Amendment”).

Amendment No. 1 to Registration Statement on Form F-1
filed on August 9, 2024

Risk Factors, page 23

1. We note your revised disclosure in response to comment 1.
                             Please further revise the second risk factor to restore the language in the body of the risk factor, as
                             you did in the title of the risk factor, that "PRC laws and regulations...can change quickly with little
                             advance notice." Also restore the language that "it may be more difficult to evaluate the outcome
                             of administrative and court proceedings and the level of legal protection we enjoy in the mainland China
                             legal system than in more developed legal systems."

  Response: We acknowledge Staff’s comment and further revised
                              the second risk factor to restore the language in the body of the risk factor, that "PRC laws and
                              regulations...can change quickly with little advance notice." We also restored the language that "it
                              may be more difficult to evaluate the outcome of administrative and court proceedings and the level of
                              legal protection we enjoy in the mainland China legal system than in more developed legal systems."

Exhibit 99.7

2. We re-issue comment 6. Please revise section 1.2.1 of the
                             opinion to exclude the PRC Companies. We also note that you revised section 1.2.2 of the opinion to delete
                             the exclusion of the PRC Companies; please revise to restore the original language excluding the PRC Companies
                             from each of (a) and (b).

Response: We acknowledge Staff’s comment and have revised section 1.2.1 of the opinion to exclude the PRC Companies. We have also restored
the original language excluding the PRC Companies from each of (a) and (b) of section 1.2.2 of the opinion.

We appreciate the assistance the Staff
has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman
Fischer & Li LLC, at (212) 530-2206.

    Very truly yours,

    /s/ Jie Xiao

    Name:
    Jie Xiao

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC