SecProbe.io

CORRESP
 1
 filename1.htm

 September 2,
 2025

 VIA
EDGAR

 Ms.
Jan Woo

 Ms.
Aliya Ishmukhamedova

 Office
of Technology

 Division
of Corporation Finance

 Securities
and Exchange Commission

 100
F Street N.E.

 Washington,
D.C. 20549

 RE:
 Youxin
 Technology Ltd (CIK: 0001964946)

 Registration
 Statement No. 333-289453 on Form F-1 (the "Registration Statement")

 Ladies
and Gentlemen:

 Aegis
Capital Corp. ("Aegis"), acting as the sole underwriter in a firm commitment offering pursuant to the Registration Statement
on Form F-1 filed with the Securities and Exchange Commission on August 8, 2025, as amended on August 18, 2025, (the "Registration
Statement"), hereby concurs in the request by Youxin Technology Ltd that the effective date of the above-referenced Registration
Statement be accelerated to 5:00 p.m. (Eastern Time) on September 4, 2025, or as soon as practicable thereafter, pursuant to Rule 461
of the Securities Act of 1933 (the "Securities Act"). Aegis affirms that it is aware of its obligations under the Securities
Act as it pertains to the firm commitment offering, pursuant to the Registration Statement.

 Very truly yours,

 AEGIS CAPITAL CORP.

 By:
 /s/
 Robert Eide

 Name:
 Robert Eide

 Title:
 Chief Executive Officer

CORRESP
 1
 filename1.htm

 Youxin
Technology Ltd

 Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

 Tianhe
District, Guangzhou, Guangdong Province ♦ People's Republic of China

 September
2, 2025

 VIA
EDGAR

 Ms.
Jan Woo

 Ms.
Aliya Ishmukhamedova

 Office
of Technology

 Division
of Corporation Finance

 Securities
and Exchange Commission

 100
F Street, N.E.

 Washington,
DC 20549

 RE:
 Youxin
 Technology Ltd (CIK: 0001964946)

 Registration
 Statement No. 333-289453 on Form F-1 (the "Registration Statement")

 Dear
Ms. Woo and Ms. Ishmukhamedova:

 Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the "Securities Act"), Youxin Technology Ltd hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 5:00 p.m. Eastern Time, September 4, 2025, or as soon thereafter as practicable.

 Please
feel free to direct any questions or comments concerning this request to our U.S. legal counsel, Anthony W. Basch of Kaufman & Canoles,
P.C.

 By:
 Youxin
 Technology Ltd

 By:

 /s/
 Shaozhang Lin

 Name:

 Mr.
 Shaozhang Lin

 Title:

 Chief
 Executive Officer

CORRESP
 1
 filename1.htm

 Youxin
Technology Ltd

 Room
1005, 1006, 1007

 No.
122 Huangpu Avenue West, Tianhe District, Guangzhou, Guangdong Province, People's Republic of China

 August
8, 2025

 Ms.
Aliya Ishmukhamedova

 Ms.
Jan Woo

 Office
of Technology

 Division
of Corporate Finance

 U.S.
Securities and Exchange Commission

 Mail
Stop 4631

 100
F Street, N.E.

 Washington,
D.C. 20549-4631

 Re:
 Youxin
 Technology Ltd

 Draft
Registration Statement on Form F-1

 Submitted
May 29, 2025

 CIK
No. 0001964946

 Dear
Ms. Aliya Ishmukhamedova and Ms. Jan Woo:

 This
letter is in response to the letter dated June 12, 2025, from the staff (the "Staff") of the Securities and Exchange Commission
(the "Commission") addressed to Youxin Technology Ltd (the "Company," "we," and "our").
For ease of reference, we have recited the Staff's comments in this response and numbered them accordingly.

 Draft
Registration Statement on Form F-1

 Cover
Page

 1.
 Please
 revise the cover page to disclose that you are a "controlled company" under Nasdaq listing standards. In this discussion,
 please disclose clearly which of your officers or directors owns or controls a significant portion of the outstanding common shares.
 In addition, please quantify the aggregate percentage of voting power controlled by Shaozhang Lin as a result of his beneficial ownership,
 the Voting Agreement, and the Voting Trust Agreement. Additionally, please include a cross reference to risk factor disclosure and
 a longer discussion of the exemptions available to you as a "controlled company."

 Response:
We have revised the cover page to disclose that we are a "controlled company" under Nasdaq listing standards and included
a cross reference to both the appropriate risk factor disclosure and the longer discussion of the exemptions available to us as a "controlled
company".

 2.
 Please
 revise your disclosure regarding the impact of both the Holding Foreign Companies Accountable Act (HFCAA) and Accelerating HFCAA
 on your company. Please revise to update disclosure.

 Response:
We have revised our disclosure regarding the impact of both the Holding Foreign Companies Accountable Act (HFCAA) and Accelerating HFCAA
on our company on the cover page and on page 53.

 3.
 Please
 revise the cover page narrative to highlight the maximum number of shares that could be issued upon exercise of your Series A warrants
 and your Series B warrants.
 For
 guidance, refer to Regulation S-K, Item 501(b)(2).

 Response:
We have revised the cover page narrative to highlight the maximum number of shares that could be issued upon exercise of our Series A
warrants and our Series B warrants based on the assumed public offering price, which is equal to the closing price of our Class A Shares
on The Nasdaq Capital Market.

 General

 4.
 You
 state on the cover page that the exercise of large numbers of Series A and Series B warrants will result in significant dilution
 for purchases of your Class A shares and will cause further drops in the market for your Class A shares which may result in potentially
 subjecting the Class A shares to delisting from Nasdaq. Please add appropriate risk factor disclosure regarding the potential to
 be delisted from Nasdaq.

 Response:
We have revised our disclosure on the cover page to add a cross-reference to the appropriate risk factor disclosure regarding the potential
to be delisted from Nasdaq. Additionally, we have revised an existing and the appropriate risk factor disclosure on page 18 to expand
on the potential and the impact of delisting from Nasdaq.

 5.
 We
 note the changes you made to your disclosure appearing on the cover page, Summary and Risk Factor sections relating to legal and
 operational risks associated with operating in China and PRC regulations. It is unclear to us that there have been changes in the
 regulatory environment in the PRC since the prior review of your registration statement on Form F-1 that was declared effective by
 the SEC on December 19, 2024 warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample
 Letters to China-Based Companies sought specific disclosure relating to cash management policies, the risk that the PRC government
 may intervene in or influence your operations at any time, or may exert control over operations of your business, which could result
 in a material change in your operations and/or the value of the securities you are registering for sale. The Sample Letters also
 sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China
 can change quickly with little advance notice. We do not believe that your revised disclosure referencing the PRC government's
 intent to strengthen its regulatory oversight conveys the same risk. Please revise or advise.

 Response:
We have revised our disclosure to align with the specific risk factors as outlined in the Sample Letters.

 Should
you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

 Sincerely,

 /s/
 Shaozhang Lin

 Shaozhang
 Lin

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 12, 2025

Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 1005, 1006, 1007, No. 122 Huangpu Avenue West, Tianhe District
Guangzhou, Guangdong Province
People s Republic of China

 Re: Youxin Technology Ltd
 Draft Registration Statement on Form F-1
 Submitted May 29, 2025
 CIK No. 0001964946
Dear Shaozhang Lin:

 We have conducted a limited review of your draft registration statement
and have the
following comments.

 Please respond to this letter by providing any requested information
and by publicly
filing your registration statement and non-public draft submission 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 filed
registration statement, we may have additional comments.

Draft Registration Statement on Form F-1
Cover Page

1. Please revise the cover page to disclose that you are a "controlled
company" under
 Nasdaq listing standards. In this discussion, please disclose clearly
which of your
 officers or directors owns or controls a significant portion of the
outstanding common
 shares. In addition, please quantify the aggregate percentage of voting
power
 controlled by Shaozhang Lin as a result of his beneficial ownership, the
Voting
 Agreement, and the Voting Trust Agreement. Additionally, please include
a cross-
 reference to risk factor disclosure and a longer discussion of the
exemptions available
 to you as a "controlled company."
 June 12, 2025
Page 2
2. Please revise your disclosure regarding the impact of both the Holding
Foreign
 Companies Accountable Act (HFCAA) and Accelerating HFCAA on your
company.
 Please revise to update disclosure.
3. Please revise the cover page narrative to highlight the maximum number
of shares that
 could be issued upon exercise of your Series A warrants and your Series
B warrants.
 For guidance, refer to Regulation S-K, Item 501(b)(2).
General

4. You state on the cover page that the exercise of large numbers of Series
A and Series
 B warrants will result in significant dilution for purchases of your
Class A shares and
 will cause further drops in the market for your Class A shares which may
result in
 potentially subjecting the Class A shares to delisting from Nasdaq.
Please add
 appropriate risk factor disclosure regarding the potential to be
delisted from Nasdaq.
5. We note the changes you made to your disclosure appearing on the cover
page,
 Summary and Risk Factor sections relating to legal and operational risks
associated
 with operating in China and PRC regulations. It is unclear to us that
there have been
 changes in the regulatory environment in the PRC since the prior review
of your
 registration statement on Form F-1 that was declared effective by the
SEC on
 December 19, 2024 warranting revised disclosure to mitigate the
challenges you face
 and related disclosures. The Sample Letters to China-Based Companies
sought
 specific disclosure relating to cash management policies, the risk that
the PRC
 government may intervene in or influence your operations at any time, or
may exert
 control over operations of your business, which could result in a
material change in
 your operations and/or the value of the securities you are registering
for sale. The
 Sample Letters also sought specific disclosures relating to
uncertainties regarding the
 enforcement of laws and that the rules and regulations in China can
change quickly
 with little advance notice. We do not believe that your revised
disclosure referencing
 the PRC government s intent to strengthen its regulatory oversight
conveys the same
 risk. Please revise or advise.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 We also remind you that your registration statement must be on file at
least two
business days prior to the requested effective date and time. Refer to Rules
460 and 461
regarding requests for acceleration. Please allow adequate time for us to
review any
amendment prior to the requested effective date of the registration statement.

 Please contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at
202-551-3453
with any other questions.

 Sincerely,
 June 12, 2025
Page 3

 Division of Corporation Finance
 Office of Technology
cc: Anthony W. Basch, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe
District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
18, 2024

VIA
EDGAR

Mr.
Larry Spirgel

Ms.
Aliya Ishmukhamedova

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    RE:
    Youxin
    Technology Ltd (CIK: 0001964946)

    Registration
    Statement No. 333-274404 on Form F-1 (the “Registration Statement”)

Dear
Mr. Spirgel, Ms. Ishmukhamedova, Ms. Collins, and Ms. Chen:

Youxin
Technology Ltd hereby withdraws its original request that the above-captioned registration statement (the “Registration Statement”)
be declared effective at 5:00 p.m., Eastern Time, on Tuesday, December 18, 2024.

Please
feel free to direct any questions or comments concerning this request to our U.S. legal counsel, Anthony W. Basch of Kaufman & Canoles,
P.C.

    By:
    Youxin
    Technology Ltd

    By:

    /s/
    Shaozhang Lin

    Name:

    Mr.
    Shaozhang Lin

    Title:

    Chief
    Executive Officer

CORRESP
1
filename1.htm

December
18, 2024

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Re:

    Youxin
    Technology Ltd

    Registration
    Statement on Form F-1

    File
    No. 333-274404

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned,
for itself and the other underwriters, hereby join in the request of Youxin Technology Ltd that the effective date of the above-referenced
registration statement be accelerated so as to permit it to become effective at 5:00 p.m., Eastern time, on Thursday, December 19, 2024,
or as soon thereafter as practicable.

Pursuant
to 460 under the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated
October 11, 2024 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such
preliminary prospectus.

The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

    Very
    truly yours,

    Aegis
    Capital Corp.

    As
    representative of the underwriters

    By:
    /s/
    Robert Eide

    Name:
    Robert
    Eide

    Title:
    Chief
    Executive Officer

CORRESP
1
filename1.htm

Youxin Technology Ltd

Room 1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe District, Guangzhou, Guangdong Province ♦
People’s Republic of China

December 18, 2024

VIA EDGAR

Mr. Larry Spirgel

Ms. Aliya Ishmukhamedova

Ms. Kathleen Collins

Ms. Chen Chen

Office of Technology

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    RE:
    Youxin Technology Ltd (CIK: 0001964946)

    Registration Statement No. 333-274404 on Form F-1 (the “Registration Statement”)

Dear Mr. Spirgel, Ms. Ishmukhamedova, Ms. Collins,
and Ms. Chen:

Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), Youxin
Technology Ltd hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become
effective at 5:00 p.m. Eastern Time, December 19, 2024, or as soon thereafter as practicable.

Please feel free to direct any questions or comments
concerning this request to our U.S. legal counsel, Anthony W. Basch of Kaufman & Canoles, P.C.

    By:
    Youxin Technology Ltd

    By:
    /s/ Shaozhang Lin

    Name:
    Mr. Shaozhang Lin

    Title:
    Chief Executive Officer

CORRESP
1
filename1.htm

December
18, 2024

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Re:

    Youxin
    Technology Ltd

    Registration
    Statement on Form F-1

    File
    No. 333-274404

Ladies
and Gentlemen:

Reference
is made to that certain letter filed as correspondence by Aegis Capital Corp. (“Aegis”) with the U.S. Securities and Exchange
Commission via EDGAR on December 17, 2024, in which Aegis joined the Company’s request for the acceleration of the effective date
of the above-referenced Registration Statement for December 18, 2024 at 5:00 p.m. Eastern Time, or as soon thereafter as practicable,
in accordance with Rule 461 under the Securities Act of 1933. The Company is withdrawing such request for acceleration of the effective
date and Aegis joins in the request of the Company and hereby formally withdraws such request for acceleration of the effective date
of the Registration Statement at such time. The Company and Aegis reserve the right to resubmit another request for acceleration of the
Registration Statement at a future date.

    Very
    truly yours,

    Aegis
    Capital Corp.

    As
    representative of the underwriters

    By:
    /s/
    Robert Eide

    Name:
    Robert
    Eide

    Title:
    Chief
    Executive Officer

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe
District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
17, 2024

VIA
EDGAR

Mr.
Larry Spirgel

Ms.
Aliya Ishmukhamedova

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    RE:
    Youxin
    Technology Ltd (CIK: 0001964946)

    Registration
    Statement No. 333-274404 on Form F-1 (the “Registration Statement”)

Dear
Mr. Spirgel, Ms. Ishmukhamedova, Ms. Collins, and Ms. Chen:

Youxin
Technology Ltd hereby withdraws its original request that the above-captioned registration statement (the “Registration Statement”)
be declared effective at 4:00 p.m., Eastern Time, on Tuesday, December 17, 2024.

Please
feel free to direct any questions or comments concerning this request to our U.S. legal counsel, Anthony W. Basch of Kaufman & Canoles,
P.C.

    By:
    Youxin
    Technology Ltd

    By:

    /s/
    Shaozhang Lin

    Name:

    Mr.
    Shaozhang Lin

    Title:

    Chief
    Executive Officer

CORRESP
1
filename1.htm

December
17, 2024

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Re:

    Youxin
    Technology Ltd

    Registration
    Statement on Form F-1

    File
    No. 333-274404

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned,
for itself and the other underwriters, hereby join in the request of Youxin Technology Ltd that the effective date of the above-referenced
registration statement be accelerated so as to permit it to become effective at 5:00 p.m., Eastern time, on Wednesday, December 18, 2024,
or as soon thereafter as practicable.

Pursuant
to 460 under the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated
October 11, 2024 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such
preliminary prospectus.

The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

    Very
    truly yours,

    Aegis
    Capital Corp.

    As
    representative of the underwriters

    By:
    /s/
    Robert Eide

    Name:
    Robert
    Eide

    Title:
    Chief
    Executive Officer

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe
District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
17, 2024

VIA
EDGAR

Mr.
Larry Spirgel

Ms.
Aliya Ishmukhamedova

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    RE:
    Youxin
    Technology Ltd (CIK: 0001964946)

    Registration
    Statement No. 333-274404 on Form F-1 (the “Registration Statement”)

Dear
Mr. Spirgel, Ms. Ishmukhamedova, Ms. Collins, and Ms. Chen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), Youxin Technology Ltd hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 5:00 p.m. Eastern Time, December 18, 2024, or as soon thereafter as practicable.

Please
feel free to direct any questions or comments concerning this request to our U.S. legal counsel, Anthony W. Basch of Kaufman & Canoles,
P.C.

    By:
    Youxin
    Technology Ltd

    By:

    /s/
    Shaozhang Lin

    Name:

    Mr.
    Shaozhang Lin

    Title:

    Chief
    Executive Officer

CORRESP
1
filename1.htm

December
17, 2024

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Re:

    Youxin
    Technology Ltd

    Registration
    Statement on Form F-1

    File
    No. 333-274404

Ladies
and Gentlemen:

Reference
is made to that certain letter filed as correspondence by Aegis Capital Corp. (“Aegis”) with the U.S. Securities and Exchange
Commission via EDGAR on December 13, 2024, in which Aegis joined the Company’s request for the acceleration of the effective date
of the above-referenced Registration Statement for December 17, 2024 at 4:00 p.m. Eastern Time, or as soon thereafter as practicable,
in accordance with Rule 461 under the Securities Act of 1933. The Company is withdrawing such request for acceleration of the effective
date and Aegis joins in the request of the Company and hereby formally withdraws such request for acceleration of the effective date
of the Registration Statement at such time. The Company and Aegis reserve the right to resubmit another request for acceleration of the
Registration Statement at a future date.

    Very
    truly yours,

    Aegis
    Capital Corp.

    As
    representative of the underwriters

    By:
    /s/
    Robert Eide

    Name:
    Robert
    Eide

    Title:
    Chief
    Executive Officer

CORRESP
1
filename1.htm

December
13, 2024

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    Re:

    Youxin
    Technology Ltd

    Registration
    Statement on Form F-1

    File
    No. 333-274404

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned,
for itself and the other underwriters, hereby join in the request of Youxin Technology Ltd that the effective date of the above-referenced
registration statement be accelerated so as to permit it to become effective at 4:00 p.m., Eastern time, on Tuesday, December 17, 2024,
or as soon thereafter as practicable.

Pursuant
to 460 under the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated
October 11, 2024 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such
preliminary prospectus.

The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

    Very
    truly yours,

    Aegis
    Capital Corp.

    As
    representative of the underwriters

    By:
    /s/
    Robert Eide

    Name:
    Robert
    Eide

    Title:
    Chief
    Executive Officer

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe
District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
13, 2024

VIA
EDGAR

Mr.
Larry Spirgel

Ms.
Aliya Ishmukhamedova

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    RE:
    Youxin
    Technology Ltd (CIK: 0001964946)

    Registration
    Statement No. 333-274404 on Form F-1 (the “Registration Statement”)

Dear
Mr. Spirgel, Ms. Ishmukhamedova, Ms. Collins, and Ms. Chen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as
amended (the “Securities Act”), Youxin Technology Ltd hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:00 p.m. Eastern Time, December 17, 2024, or as soon thereafter as practicable.

Please
feel free to direct any questions or comments concerning this request to our U.S. legal counsel, Anthony W. Basch of Kaufman & Canoles,
P.C.

    By:
    Youxin
    Technology Ltd

    By:

    /s/
    Shaozhang Lin

    Name:

    Mr.
    Shaozhang Lin

    Title:

    Chief
    Executive Officer

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe
District, Guangzhou, Guangdong Province ♦ People’s Republic of China

September
30, 2024

Ms.
Aliya Ishmukhamedova

Mr.
Larry Spirgel

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

Amendment
No. 9 to Registration Statement on Form F-1

Filed
September 16, 2024

CIK
No. 0001964946

Dear
Ms. Ishmukhamedova, Mr. Spirgel, Ms. Collins, and Ms. Chen:

This
letter is in response to the letter dated September 23, 2024, from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly.

Amendment
No. 9 to Registration Statement on Form F-1

Management’s
Discussion and Analysis of Financial Condition and Results of Operations Overview

Factors
Affecting Our Performance

Lost
Customers, page 55

    1.
    We
    note your disclosures on page 1 and 54 where you state that you 22 lost customers during the six months ended March 31, 2023, which
    appears to suggest a churn rate of 67% for this period. However, the table on page 55 indicates that you lost 13 customers during
    the six months ended March 31, 2023, representing a churn rate of 39%. In addition, on page 54 you state that you had 17 customers
    at September 30, 2023 and lost 12 customers during the six months ended March 31, 2024, which would equate to a churn rate of 71%
    versus your disclosed rate of 75%. Please explain each of these apparent inconsistencies and revise as necessary.

Response:
We have revised the disclosure to consistently disclose our lost customers. For the six months ended March 31, 2023, we lost 13 of
our 33 customers at the beginning of the period, compared with 8 lost customers of the 25 customers at the
beginning for the fiscal year ended September 30, 2022. We have revised the disclosure in pages 1 and 54 accordingly.

For
the year ended September 30, 2023, the 17 customers represents a net loss between the number of customers at the beginning and the
end of fiscal 2023. We have revised the disclosure to further clarify that we had 16 customers using our professional and payment channel
services at the end of fiscal 2023.

Below
is a further illustration of the customer count and churn rate calculations contained in our disclosures:

    For the year ended

                                                                                September 30, 2022

    For the year ended

                                                                                September 30, 2023

    For the six months ended

                                                                                March 31, 2023

    For the six months ended

                                                                                March 31, 2024

    Customers at beginning of the period
                                       25
                                        33
      33
      16

    Lost Customers
      8
      22
      13
      12

    New Customers
      16
      5
      2
      1

    Net gain (loss) of customers
      8
      (17 )
      (11 )
      (11 )

    Customers at the end of the period
      33
      16
      22
      5

    Churn Rate (lost customers divided by total number of customers at beginning of period)
      32 %
      67 %
      39 %
      75 %

At
the start of fiscal year 2022, we began with 25 customers and lost 8 customers during the fiscal year, which resulted in
a churn rate of 32%. During fiscal year 2022, we gained 16 new customers for a net gain of 8 customers, ending the fiscal year with a
total of 33 customers.

At
the start of fiscal year 2023, we began with 33 customers and lost 22 customers during the fiscal year, which resulted
in a churn rate of 67%. During fiscal year 2023, we gained 5 new customers for a net loss of 17 customers, ending the fiscal year
with a total of 16  customers.

At
the start of the interim period for the six months ended March 31, 2023, we began with 33 customers and lost 13 customers during the
interim period, which resulted in a churn rate of 39%. During the same interim period in 2023, we gained 2 new customers for
a net loss of 11 customers, ending the interim period in 2023 with a total of 22 customers.

At
the start of the interim period for the six months ended March 31, 2024, we began with 16 customers and lost 12 customers during the
interim period, which resulted in a churn rate of 75%. During the same interim period in 2024, we gained 1 new customer for
a net loss of 11 customers, ending the interim period in 2024 with a total of 5 customers.

Notes
to Unaudited Condensed Consolidated Financial Statements, page F-33

    2.
    Please
    revise the header on page F-33 to refer to the financial statements for the six months ended March 31, 2024 and 2023.

Response:
We have revised the disclosure on page F-33 accordingly.

Should
you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

September 23, 2024
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 9 to Registration Statement on Form F-1
Filed September 16, 2024
File No. 333-274404
Dear Shaozhang Lin:
            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 September 9, 2024 letter.
Amendment No. 9 to Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Factors Affecting Our Performance
Lost Customers, page 55
1.We note your disclosures on page 1 and 54 where you state that you 22 lost customers
during the six months ended March 31, 2023, which appears to suggest a churn rate of
67% for this period. However, the table on page 55 indicates that you lost 13 customers
during the six months ended March 31, 2023, representing a churn rate of 39%. In
addition, on page 54 you state that you had 17 customers at September 30, 2023 and lost
12 customers during the six months ended March 31, 2024, which would equate to a
churn rate of 71% versus your disclosed rate of 75%. Please explain each of these
apparent inconsistencies and revise as necessary.

September 23, 2024
Page 2
Notes to Unaudited Condensed Consolidated Financial Statements, page F-33
2.Please revise the header on page F-33 to refer to the financial statements for the six
months ended March 31, 2024 and 2023.
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Larry Spirgel at 202-551-3815 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Anthony Basch

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
1005, 1006, 1007, No. 122 Huangpu Avenue West,

Tianhe
District, Guangzhou, Guangdong Province ♦ People’s Republic of China

September
16, 2024

Ms.
Aliya Ishmukhamedova

Mr.
Larry Spirgel

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

Amendment
No. 8 to Registration Statement on Form F-1

Filed
August 23, 2024

CIK
No. 0001964946

Dear
Ms. Ishmukhamedova, Mr. Spirgel, Ms. Collins, and Ms. Chen:

This
letter is in response to the letter dated September 9, 2024, from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly.

Amendment
No. 8 to Registration Statement on Form F-1

Management’s
Discussion and Analysis of Financial Condition and Results of Operations Overview, page 54

    1.
    Please
    revise your disclosure on page 54, where you discuss lost customers, to also disclose the actual customer count at both March 31,
    2023 and 2024. Similar revisions to disclose the actual customer count at March 31, 2024 should also be made on page 1.

Response:
We have revised the disclosure on page 1 and throughout the disclosure where appropriate.

    2.
    You
    disclose on page 54 that you anticipate revenue growth as new distributors and customers purchase licenses and professional services
    for the third-generation PaaS platform. Please explain the basis for this statement considering the consistent decline in revenue
    and customers for all periods presented and revise your disclosures as necessary.

Response:
We have revised disclosure on page 54. As of March 31, 2024, the Company focused on implementing the third-generation PaaS platform into
trial for potential customers and distributors. Through the trials, the Company will collect feedback and continue to optimize
the platform.

Factors
Affecting Our Performance

Customer
Churn Rate, page 55

    3.
    Based
    on the 16 customers at September 30, 2023 and 13 customers lost during the six months ended March 31, 2024, it appears that your
    churn rate should be 81% for the first half of fiscal 2024. Please provide the calculations to support the 71% churn rate disclosed
    for the six months ended March 31, 2024 or revise as necessary.

Response:
We have revised the number of lost customers for the year ended September 30, 2023 and for the six months ended March 31, 2024. One lost
customer during the year ended September 30, 2023 was incorrectly recorded as a lost customer during the six months ended March 31, 2024.
Based on 12 lost customer during the six months ended March 31, 2024, the churn rate should be 75%.

Net
Expansion Rate, page 56

    4.
    Your
    narrative disclosure states that the net dollar expansion rate for the six months ended March 31, 2024 and 2023 were 73% and 75%,
    respectively. However, the table presented below such disclosure appears to suggest the net expansion rate was 75% and 73% for the
    respective periods. Please revise.

Response:
We have revised the disclosure accordingly.

Should
you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

September 9, 2024
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 8 to Registration Statement on Form F-1
Filed August 23, 2024
File No. 333-274404
Dear Shaozhang Lin:
            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.
Amendment No. 8 to Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 54
1.Please revise your disclosure on page 54, where you discuss lost customers, to also
disclose the actual customer count at both March 31, 2023 and 2024. Similar revisions to
disclose the actual customer count at March 31, 2024 should also be made on page 1.
2.You disclose on page 54 that you anticipate revenue growth as new distributors and
customers purchase licenses and professional services for the third-generation PaaS
platform. Please explain the basis for this statement considering the consistent decline in
revenue and customers for all periods presented and revise your disclosures as necessary.

September 9, 2024
Page 2
Factors Affecting Our Performance
Customer Churn Rate, page 55
3.Based on the 16 customers at September 30, 2023 and 13 customers lost during the six
months ended March 31, 2024, it appears that your churn rate should be 81% for the first
half of fiscal 2024. Please provide the calculations to support the 71% churn rate
disclosed for the six months ended March 31, 2024 or revise as necessary.
Net Expansion Rate, page 56
4.Your narrative disclosure states that the net dollar expansion rate for the six months ended
March 31, 2024 and 2023 were 73% and 75%, respectively. However, the table presented
below such disclosure appears to suggest the net expansion rate was 75% and 73% for the
respective periods. Please revise.
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Larry Spirgel at 202-551-3815 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Anthony Basch

United States securities and exchange commission logo
February 12, 2024
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 5 to Registration Statement on Form F-1
Filed February 2, 2024
File No. 333-274404
Dear Shaozhang Lin:
            We have reviewed your amended registration statement and have the following comment.
            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 January 26, 2024 letter.
Amendment No.5 to Registration Statement on Form F-1
Note 3. Summary of Significant Accounting Policies
bb. Revision of previously issued Consolidated Statements of Balance Sheets, Operations and
Comprehensive Loss..., page F-17
1.We note your response to prior comment 2, however, it remains unclear how you
determined that the qualitative factors overcome the quantitative significance of the error.
In this regard, while you refer to the dollar impact of this error, on a percentage basis, this
error impacted earnings per share by approximately 15% as a percentage of the as-
corrected balance. Please explain or as previously requested, revise to label the
appropriate columns of the financial statements as restated and have your auditor revise its
report to reference the restatement consistent with paragraph 18e of PCAOB Accounting
Standard 3101.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 February 12, 2024 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
February 12, 2024
Page 2
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Larry Spirgel at 202-551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

CORRESP
1
filename1.htm

Youxin Technology Ltd

Room 802, 803

No. 13 Hai’an Road, Tianhe District, Guangzhou,
Guangdong Province ♦ People’s Republic of China

February 21, 2024

Ms. Alexandra Barone

Mr. Larry Spirgel

Ms. Kathleen Collins

Ms. Chen Chen

Office of Technology

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4631

100 F Street, N.E.

Washington, D.C. 20549-4631

    Re:
    Youxin Technology Ltd

Amendment No. 5 to Registration
Statement on Form F-1

Filed February 2, 2024

CIK No. 0001964946

Dear Ms. Barone, Mr. Spirgel, Ms. Collins, and Ms.
Chen:

This letter is in response to the letter dated February
12, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Youxin Technology Ltd (the “Company,” “we,” and “our”). For ease of reference, we have recited
the Staff’s comments in this response and numbered them accordingly.

Amendment No. 5 to Registration Statement on
Form F-1

Note 3. Summary of Significant Accounting Policies

bb. Revision of previously issued Consolidated
Statements of Balance Sheets, Operations and Comprehensive Loss..., page F-17

    1.
    We note your response to prior comment 2, however, it remains unclear how you determined that the qualitative factors overcome the quantitative significance of the error. In this regard, while you refer to the dollar impact of this error, on a percentage basis, this error impacted earnings per share by approximately 15% as a percentage of the as corrected balance. Please explain or as previously requested, revise to label the appropriate columns of the financial statements as restated and have your auditor revise its report to reference the restatement consistent with paragraph 18e of PCAOB Accounting Standard 3101.

Response: In response to Staff’s comment, the
Company has restated its previously reported consolidated balance sheets on page F-3, consolidated statements of operations and comprehensive
loss on page F-4, and consolidated statements of changes in shareholders’ deficit on page F-5, as well as the disclosures for Note
12 - basic and diluted loss per share on page F-23 and Note 19 - financial information of the parent company on page F-28, and added disclosures
for the details restatement on Note 17 – RESTATEMENT OF CONSOLIDATED FINANCIAL STATEMENTS.

Should you have any questions with respect to the
above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/ Shaozhang Lin

    Shaozhang Lin

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
802, 803

No.
13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦ People’s Republic of China

February
2, 2024

Ms.
Alexandra Barone

Mr.
Larry Spirgel

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

Amendment
No. 4 to Registration Statement on Form F-1

Filed
January 19, 2024

CIK
No. 0001964946

Dear
Ms. Barone, Mr. Spirgel, Ms. Collins, and Ms. Chen:

This
letter is in response to the letter dated January 26, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly.

Amendment
No. 4 to Registration Statement on Form F-1

Risk
Factors

As
more of our sales efforts are targeted at larger enterprise clients..., page 18

    1.
    Please
    revise to disclose the number of clients that accounted for 76% and 45% of your revenue in fiscal 2023 and 2022, respectively to
    add context to this disclosure. In addition, revise the risk factor header to address the fact that you rely on a limited number
    of clients for a significant portion of your revenue.

Response:
We have revised the risk factor header and disclosure on page 18 accordingly.

Note
3. Summary of Significant Accounting Policies

bb.
Revision of previously issued Consolidated Statements of Balance Sheets, Operations and Comprehensive Loss..., page F-17

    2.
    We
    note you made “revisions” to your September 30, 2022 financial statements. Please explain to us how you considered the
    guidance in ASC 250-10-45-22 to 45-28 as well as SAB 99 in concluding that the changes should not be reported as an error in previously
    issued financial statements. Otherwise, revise to comply with that guidance by providing all the information required by ASC 250-10-50-7,
    label the appropriate columns of the financial statements as “Restated” and have your auditor revise its report to reference
    the restatement consistent with paragraph 18e of PCAOB Auditing Standard 3101.

Response:
The Company respectfully advises Staff that revisions previously made in Amendment No. 4 to Registration Statement on Form
F-1 were immaterial under the guidance in ASC 250-10-45-22 to 45-28 as well as SAB 99 in concluding that the changes should not be reported
as an error in previously issued financial statements.

As
disclosed in Amendment No. 4 to Registration Statement on Form F-1, the
Company revised the number and the amount of Class A ordinary shares and share subscription receivables as of September
30, 2022 on pages F-3 and F-5, and also loss per share and weighted average number of ordinary shares outstanding in page
F-4, added a revision note under Note 3 on page F-17 since the issuance of the 5,318,548 shares to former Mezzanine Equity
Holders in April 2023 was erroneously presented retroactively as of September 30, 2022 and 2021.

The
Company considered ASC 250-10-45-22 to 45-28 and Staff Accounting Bulletin (“SAB”) Topic 1.M/SAB 99 (“Materiality.”)
As SAB 99 states, in relevant part: “The omission or misstatement of an item in a financial report is material if, in the light
of surrounding circumstances, the magnitude of the item is such that it is probable that the judgment of a reasonable person relying
upon the report would have been changed or influenced by the inclusion or correction of the item.”

For the
reasons set forth below, the Company determined that the revisions were immaterial under the following analysis:

Quantitative
Assessment of the Revision

The
following table presents the assessment of the quantitative impact of the revisions on the Company’s Consolidated Financial Statements.

    Consolidated
    Balance Sheets
    The
    revision has no impact on total assets, total liabilities and mezzanine equity and shareholders’ deficit on the
    Balance Sheets as of September 30, 2022, but impact ordinary
    share number, the amount of Class A ordinary shares and share subscription receivable

    Consolidated
    Statements of Operations and Comprehensive Loss
    The
    revision decreased the basic and diluted loss per share by $0.04 and weighted average share number by 5,318,548 on the Statements
    of Operations and Comprehensive Loss for the fiscal year ended September 30, 2022

    Consolidated
    Statements of Changes in Shareholders’ Deficit
    The
    revision on the Statement of Changes in Shareholders’ Deficit for the year ended September 30, 2022 decreased the number of Class A ordinary shares by 5,318,548, decreased the amount of Class A ordinary shares by
$531 and increased share subscription receivable by $531 as of September 30, 2022 and 2021, respectively

    Consolidated
    Statements of Cash Flows
    This
    revision had no effect on Consolidated Statements of Cash Flows for the fiscal year ended September 30, 2022

Qualitative
Assessment of the Revision

The
Company also considered the qualitative impacts noted in SAB 99 as follows:

    Qualitative
    factor

    Analysis

    Whether
    the misstatement arises from an item capable of precise measurement or whether it arises from an estimate and, if so, the degree
    of imprecision inherent in the estimate.

    The
    amount of the prior year revisions is a factual difference and does not arise from an estimate.

    Whether
    the misstatement masks a change in earnings or other trends.

    No.

    Whether
    the misstatement hides a failure to meet analysts’ consensus expectations for the enterprise.

    The
    adjustments did not hide a failure of the Company to meet analysts’ estimates.

    Whether
    the misstatement changes a loss into income or vice versa.

    The
    misstatements did not change a loss into income or vice versa.

    Whether
    the misstatement concerns a segment or other portion identified as playing a significant role in operations or profitability.

    No.

    Whether
    the misstatement affects the registrant’s compliance with regulatory requirements.

    There
    are no governmental regulatory requirements impacted.

    Whether
    the misstatement affects the registrant’s compliance with loan covenants or other contractual requirements.

    There
    is no impact on covenants.

    Whether
    the misstatement has the effect of increasing management’s compensation - for example, by satisfying requirements for the award
    of bonuses or other forms of incentive compensation.

    No.

    Whether
    the misstatement involves concealment of an unlawful transaction.

    The
    misstatement does not conceal an unlawful transaction.

In
addition to the quantitative and qualitative assessments of the revision in SAB 99, the Company believes the revision is immaterial because:

    1.

    the
    revision does not have any effect on revenues, retained earnings, equity, total assets or current assets, total liabilities or current
    liabilities, total cash flows, in the consolidated financial statements of financial position for the year presented and the Company
    did not omit any disclosure;

    2.

    the
    revision is not meaningful to an investor’s decision and it would not have changed or influenced his/her decision by the inclusion
    or correction of the item; and

    3.

    although
    this revision decreased the amount of Class A ordinary share by $531, increased share subscription receivable by $531, decreased
    weighted average share number and the number of Class A ordinary share by 5,318,548, and increased the basic and diluted loss
    per share by $0.04 per share, we do not expect investors will make their investment decision purely relying on the amount of Class
    A ordinary shares, share subscription receivable, weighted average share number, and basic and diluted loss per share only.
    In addition, because this revision has no impact on the total assets and shareholders’ deficit, we believe it will
    not significantly impact their investment decision.

Based
on the foregoing analysis, the Company believes that the judgment of a reasonable person relying upon the previously filed consolidated
financial statements would not be changed or influenced by the revision relating to the number of Class A ordinary shares and share subscription
receivables and the impact of this error is not material to the Company’s previously issued fiscal year ended September 30,
2022 consolidated financial statements.

Should
you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

United States securities and exchange commission logo
January 26, 2024
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Youxin Technology Ltd
Re:Youxin Technology Ltd
Amendment No. 4 to Registration Statement on Form F-1
Filed January 19, 2023
File No. 333-274404
Dear Shaozhang Lin:
            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.
Amendment No. 4 to Registration Statement on Form F-1
Risk Factors
As more of our sales efforts are targeted at larger enterprise clients..., page 18
1.Please revise to disclose the number of clients that accounted for 76% and 45% of your
revenue in fiscal 2023 and 2022, respectively to add context to this disclosure. In addition,
revise the risk factor header to address the fact that you rely on a limited number of clients
for a significant portion of your revenue.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 January 26, 2024 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
January 26, 2024
Page 2
Note 3. Summary of Significant Accounting Policies
bb. Revision of previously issued Consolidated Statements of Balance Sheets, Operations and
Comprehensive Loss..., page F-17
2.We note you made "revisions" to your September 30, 2022 financial statements. Please
explain to us how you considered the guidance in ASC 250-10-45-22 to 45-28 as well
as SAB 99 in concluding that the changes should not be reported as an error in previously
issued financial statements. Otherwise, revise to comply with that guidance by providing
all the information required by ASC 250-10-50-7, label the appropriate columns of the
financial statements as "Restated" and have your auditor revise its report to reference the
restatement consistent with paragraph 18e of PCAOB Auditing Standard 3101.
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Larry Spirgel at 202-551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
802, 803

No.
13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
21, 2023

Ms.
Alexandra Barone

Mr.
Larry Spirgel

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

    Amendment
    No. 3 to Registration Statement on Form F-1

    Submitted
    December 18, 2023

    CIK
    No. 0001964946

Dear
Mr. Derby, Ms. Barone, Ms. Collins, and Ms. Chen:

This
letter is in response to the letter dated December 20, 2023, from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly.

Amendment
No. 3 to Registration Statement on Form F-1

General

    1.
    You
    are requesting effectiveness of your F-1 registration statement before completing the CSRC process. Please confirm in writing that
    you will notify us promptly of any changes to your disclosure regarding or requested by the CSRC.

Response:
We confirm that we will notify Staff promptly of any changes to our disclosure regarding or requested by the CSRC.

Should
you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

United States securities and exchange commission logo
December 20, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 3 to Registration Statement on Form F-1
Filed December 19, 2023
File No. 333-274404
Dear Shaozhang Lin:
            We have reviewed your amended registration statement and have the following comment.
            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.
Amendment No. 3 to Registration Statement on Form F-1
General
1.You are requesting effectiveness of your F-1 registration statement before completing the
CSRC process. Please confirm in writing that you will notify us promptly of any changes
to your disclosure regarding or requested by the CSRC.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 December 20, 2023 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
December 20, 2023
Page 2
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Larry Spirgel at 202-551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
802, 803

No.
13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
19, 2023

Mr.
Matthew Derby

Ms.
Alexandra Barone

Ms.
Kathleen Collins

Ms.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

    Amendment No. 3
    to Registration Statement on Form F-1

    Submitted
    December 19, 2023

    CIK No. 0001964946

Dear
Mr. Derby, Ms. Barone, Ms. Collins, and Ms. Chen:

This
letter is in response to the letter dated December 14, 2023, from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly. An Amendment No. 3
to Registration Statement on Form F-1 (the “F-1/A”) is being filed to accompany this letter.

Amendment
No. 2 to Registration Statement on Form F-1

Factors
Affecting Our Performance, page 54

    1.
    We
    note from your response to prior comment 3 that the customer renewal rate calculation excludes customers with existing contracts
    whose terms do not expire during the period. It appears from your disclosures on page F-13 that your contract terms are typically
    one year. Therefore, please clarify for us which customers are not subject to renewal such that they would be excluded from this
    calculation. To the extent contract terms extend beyond one year, either initially or upon renewal, revise to disclose as such.

Response:
All of our contract terms are one-year with the option to renew for additional one-year terms prior to the expiration of the contract
term. Our CRM systems display online prompts to customers about renewing services to continue access 30 days prior to the expiration
of the contract term. Additionally, our customer service staff proactively communicates with customers about renewals prior to contract
expiration. No contract terms, either initially or upon renewal, extend beyond one year. We have revised the disclosure on page 54 accordingly.

New
customers are excluded from the customer renewal rate calculation for the fiscal year in which they initially begin service because these
customers do not need to be renewed during the initial fiscal year in which they begin service. These customers would be included
in the next fiscal year period’s calculation. For example, a customer who signs up for services in April 2021 with a one-year
contract term ending April 2022 would not be included for the customer renewal rate calculation for the fiscal year ended September 30,
2021. Instead, this customer would be reflected in the customer renewal rate calculation for fiscal year ended September 30, 2022
because the customer would need to renew his contract prior to the expiration of the existing contract within the fiscal year ended
September 30, 2022. Whether a customer is included in the calculations for interim six month periods ending March 31 will depend on
whether the customer’s contract expires during the interim six month period being measured. For example, a customer
who signed up in December 2021 would not be included in the calculation for the interim six month period ending March 31, 2022 because
the customer’s initial contract would not have expired during the six month period ending March 31, 2022, but the customer would
be included in calculation for the interim six month period ending March 31, 2023.

General

    2.
    We
                                            note your response to prior comment 5; however, we continue to note changes you made to your
                                            disclosure appearing on the cover page, Summary and Risk Factor sections relating to legal
                                            and operational risks associated with operating in China and PRC regulations and it continues
                                            to be unclear to us that there have been changes in the regulatory environment in the PRC
                                            since the amendment that was filed on July 17, 2023 warranting revised disclosure to mitigate
                                            the challenges you face and related disclosures. For example, on the cover page, you no longer
                                            disclose that the interpretation and implementation of the New Administrative Rules Regarding
                                            Overseas Listings “involve uncertainties.” Please tell us the reasons for these
                                            changes or revise your disclosure

    throughout
    the registration statement as applicable.

Response:
We have revised the cover page and throughout the disclosure where appropriate.

Thank
you in advance for your assistance in reviewing this response and the F-1/A. Should you have any questions with respect to the above
responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

United States securities and exchange commission logo
December 14, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed December 8, 2023
File No. 333-274404
Dear Shaozhang Lin:
            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 November 28, 2023 letter.
Amendment No. 2 to Registration Statement on Form F-1
Factors Affecting Our Performance, page 54
1.We note from your response to prior comment 3 that the customer renewal rate calculation
excludes customers with existing contracts whose terms do not expire during the period. It
appears from your disclosures on page F-13 that your contract terms are typically one
year. Therefore, please clarify for us which customers are not subject to renewal such that
they would be excluded from this calculation. To the extent contract terms extend beyond
one year, either initially or upon renewal, revise to disclose as such.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 December 14, 2023 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
December 14, 2023
Page 2
General
2.We note your response to prior comment 5; however, we continue to note changes you
made to your disclosure appearing on the cover page, Summary and Risk Factor sections
relating to legal and operational risks associated with operating in China and PRC
regulations and it continues to be unclear to us that there have been changes in the
regulatory environment in the PRC since the amendment that was filed on July 17, 2023
warranting revised disclosure to mitigate the challenges you face and related disclosures.
For example, on the cover page, you no longer disclose that the interpretation and
implementation of the New Administrative Rules Regarding Overseas Listings “involve
uncertainties.” Please tell us the reasons for these changes or revise your disclosure
throughout the registration statement as applicable.
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
802, 803

No.
13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December
8, 2023

Mr.
Matthew Derby

Ms.
Alexandra Barone

Ms.
Kathleen Collins

Mr.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

Amendment
No. 2 to Registration Statement on Form F-1

Submitted
December 8, 2023

CIK
No. 0001964946

Dear
Mr. Derby, Ms. Barone, Ms. Collins, and Mr. Chen:

This
letter is in response to the letter dated November 28, 2023, from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly. An Amendment No. 2
to Registration Statement on Form F-1 (the “F-1/A”) is being filed to accompany this letter.

Amendment
No. 1 to Registration Statement on Form F-1

Summary
Consolidated Financial Data, page 13

    1.
    Please
    revise to include pro forma per share information for fiscal year ended September 30, 2022. In this regard, we acknowledge that our
    prior comment 2 inadvertently referred to fiscal year 2022 instead of fiscal 2021. Refer to Item 11-02(12)(c)(2) of Regulation S-X.

Response:
We have revised page 13 to remove pro forma per share information for the fiscal year ended September 30, 2021, and to include the pro
forma per share information for the fiscal year ended September 30, 2022.

Factors
Affecting Our Performance, page 54

    2.
    Please
    address the following as it relates to your revised disclosures in response to prior comment 5:

    ●
    Clarify
    whether, for each periods presented, all of your professional services customers are also payment channel customers. If so,
    revise throughout to clearly explain the overlapping nature of these customer bases.

    Response:
    We respectfully advise Staff for all periods presented all of our professional service customers have also been payment channel
    customers. Typically, our customers first execute one-year contracts for professional services. Under the professional services contract,
    we would develop the customized CRM system for the customer’s use. Our customers have the option to use other service providers
    for the payment channel services. To date, all of our customers have selected us as the service provider for the payment channel
    services. As a result, the same customers purchased our payment channel services. We have revised our disclosure throughout the
    F-1/A accordingly.

    ●
    If
    true, ensure it is clear from any revised disclosures that your total customer count refer to 22 customers using your professional
    services and 22 customers for your payment channel services for the six months ended March 31, 2023, which implies a total
    customer base of 44 customers.

    Response:
    We have revised throughout our disclosures to clearly reflect that our total customer count is 22 customers and that, in all periods
    presented, all of our customers purchased both professional services and payment channel services.

    ●
    Clarify
    whether the number of lost customers represent customers that purchased both professional services and payment channel.

    Response:
    Customers who terminate our professional services would cease using our CRM system and thus do not retain our payment channel services.
    We have revised to clarify that lost customers represent customers that purchased both professional services and payment channel
    services.

    3.
    We
    note that you revised your calculation of customer renewal rate to now refer to customers who chose to renew their contracts divided
    by customers who need to renew their contracts as defined by your revenue recognition from professional services. Please revise to
    explain what is meant by customers who “need to renew.” Also, clarify what customer base is included in this calculation.
    In this regard, tell us and revise to disclose whether customer renewal rate includes all professional service customers (i.e.,
    customized CRM system development, additional functional development and subscription service customers) and whether payment channel
    service customers are factored into this calculation. To the extent only a portion of your customer base is reflected in this measure,
    explain why, and revise to disclose the percentage of revenue recognized for each period presented from the customer base reflected
    in this measure.

Response:
Customers who “need to renew” are customers who purchased our customized CRM development services and who must renew their
contracts during the period being measured to maintain access to our CRM system during the period being measured. We have revised our
disclosure throughout the F-1/A accordingly.

The
customer base included in the customer renewal rate calculation includes all professional service customers and payment channel
service customers. We do not include in our customer renewal calculations the customers with existing contracts whose terms do not expire
during the period being measured because it is unnecessary for them to renew their contracts during the period to continue using our
CRM system.

Our
formula to calculate our customer renewal rate is expressed as follows:

Please
see below for a sample calculation for fiscal year ended September 30, 2022 which supports our disclosures:

    Customer Renewal Rate for the Year Ended September 30, 2022

    Number of renewing customers in the fiscal year ended September 30, 2022
      15

    Number of customers who must renew in the fiscal year ended September
    30, 2022
      18

    Total (including calculation)
      15/18 = 83 %

As
explained above, our customized CRM development services come with a one-year access upon delivery. Customers who engaged our services
to develop a customized CRM must renew their subscriptions upon expiration to continue accessing our CRM system. Similarly, all
customized CRM development service customers use our payment channel services, and when they renew their subscriptions for the CRM system,
they must renew contracts for our payment channel services. We have revised our disclosure throughout the F-1/A accordingly.

    4.
    We
    note from your revised disclosures that net dollar expansion rate is calculated by taking revenue generated from renewing customers
    during the stated fiscal year divided by renewing customers from the previous fiscal year end. Please address the following:

    ●
    Tell
    us whether this calculation starts with the base of renewing customers at the end of the prior period and compares such revenue to
    the same set of customers  at the end of the current fiscal period.

    Response:
    We respectfully advise Staff that the denominator used to calculate the net dollar expansion rate is the revenue generated
    by all customers during the prior fiscal period (which includes revenue from both professional and payment channel services). The
    numerator is the revenue generated in the subsequent fiscal period by the same set of customers included in the denominator that
    renewed their contracts. For example, if the company received revenue in fiscal year ended September 30, 2021 from Customer A
    and the Company also received revenue from Customer A in fiscal year ended September 30, 2022, Customer A would
    be included in both the numerator and the denominator; whereas if, for Customer B, the Company only received revenue in fiscal
    year ended September 30, 2021 and did not receive revenue in fiscal year ended September 30, 2022, Customer B would be included
    in the denominator but not the numerator. If the Company only received revenue from the Customer C in fiscal year 2022
    and no revenue in fiscal year 2021, then the Customer C would not be included in the  denominator or the numerator.

     Our
    formula to calculate our net dollar expansion rate is expressed as follows:

    ●
    Clarify
    whether lost customers are included in this calculation.

    Response:
    We respectfully advise Staff that the denominator of our net dollar expansion rate calculation is the revenue generated by
    all customers in the previous year, which includes lost customers. We have revised the disclosure accordingly.

    ●
    Explain
    what is meant by “renewing customer” and specifically address whether all  professional service customers
    (i.e., customized CRM system development, additional function development and subscription service customers) and payment channel
    services customers are included in this calculation.

    Response:
    We respectfully advise Staff that “renewing customers” are customers who have renewed their contracts during
    the period being measured and include all professional service (including customized CRM system development, additional function
    development and subscription service customers) and payment channel customers.

    ●
    To
    the extent this metric is based on a subset of your customer base, explain why, and revise to disclose the percentage of revenue
    generated from the customer base represented in this measure.

    Response:
    We respectfully advise Staff that our metric is based on all customers and is not based on a subset of our customer base. We have
    revised our disclosure on pages 54 and 55 of the F-1/A to clarify this point.

    ●
    Provide
    us with a sample calculation for fiscal 2022 that supports your disclosures.

    Response:
    Please see below for a sample calculation for fiscal year ended September 30, 2022 which supports our disclosures:

    Net Dollar Expansion Rate for the Year Ended September 30, 2022

    Revenue from renewing customers in the fiscal year ended September 30, 2022
    $ 679,339

    Revenue generated by customers in the fiscal year ended September 30, 2021
    $ 1,106,860

    Total (including calculation)
    $ (679,399)/($1,106,860) = 61 %

For
ease of reference, below is an updated Net Dollar Expansion Rate table for our latest F-1/A submission:

    Rate
    For the year ended

 September 30, 2021

    For the year ended

 September 30, 2022

    For the six months ended

 March 31, 2022

    For the six months ended

 March 31, 2023

    Net Dollar Expansion Rate
      64
    %
      61
    %
      84
    %
      73
    %

General

    5.
    We
    note your responses to prior comments 1 and 3; however, we continue to note changes you made to your disclosure appearing on the
    cover page, Summary and Risk Factor sections relating to legal and operational risks associated with operating in China and PRC regulations
    and it continues to be unclear to us that there have been changes in the regulatory environment in the PRC since the amendment that
    was filed on July 17, 2023 warranting revised disclosure to mitigate the challenges you face and related disclosures. As a nonexclusive
    example, on page 23, you no longer address the validity, enforceability and scope of protection of intellectual property rights within
    China. Please tell us the reasons for these changes or revise your disclosure throughout the registration statement as applicable.

Response:
We have revised the disclosure on the cover page, the Summary of Risk Factors on page 6, and on the Risks Related to Doing Business in China beginning on page 26 to
the original language prior to the amendment that was filed on July 17, 2023.

Thank
you in advance for your assistance in reviewing this response and the F-1/A. Should you have any questions with respect to the above
responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

United States securities and exchange commission logo
November 28, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed November 16, 2023
File No. 333-274404
Dear Shaozhang Lin:
            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 October 17, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-1
Summary Consolidated Financial Data, page 13
1.Please revise to include pro forma per share information for fiscal year ended September
30, 2022. In this regard, we acknowledge that our prior comment 2 inadvertently referred
to fiscal year 2022 instead of fiscal 2021. Refer to Item 11-02(12)(c)(2) of Regulation S-
X.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 November 28, 2023 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
November 28, 2023
Page 2
Factors Affecting Our Performance, page 54
2.Please address the following as it relates to your revised disclosures in response to prior
comment 5:
•Clarify whether, for each periods presented,  all of your professional services
customers are also payment channel customers. If so, revise throughout to clearly
explain the overlapping nature of these customer bases.
•If true, ensure it is clear from any revised disclosures that your total customer count
includes both professional services and payment channel services. In this regard, you
refer to 22 customers using your professional services and 22 customers for your
payment channel services for the six months ended March 31, 2023, which implies a
total customer base of 44 customers.
•Clarify whether the number of lost customers represent customers that purchased
both professional services and payment channel.
3.We note that you revised your calculation of customer renewal rate to now refer to
customers who chose to renew their contracts divided by customers who need to renew
their contracts as defined by your revenue recognition from professional services. Please
revise to explain what is meant by customers who "need to renew." Also, clarify what
customer base is included in this calculation. In this regard, tell us and revise to
disclose whether customer renewal rate includes all professional service customers (i.e.,
customized CRM system development, additional functional development and
subscription service customers) and whether payment channel service customers are
factored into this calculation. To the extent only a portion of your customer base is
reflected in this measure, explain why, and revise to disclose the percentage of revenue
recognized for each period presented from the customer base reflected in this measure.
4.We note from your revised disclosures that net dollar expansion rate is calculated by
taking revenue generated from renewing customers during the stated fiscal year divided
by renewing customers from the previous fiscal year end. Please address the following:
•Tell us whether this calculation starts with the base of renewing customers at the end
of the prior period and compares such revenue to the same set of customers  at the end
of the current fiscal period.
•Clarify whether lost customers are included in this calculation.
•Explain what is meant by "renewing customer" and specifically address whether all
professional service customers (i.e., customized CRM system development,
additional function development and subscription service customer) and payment
channel services customers are included in this calculation.
•To the extent this metric is based on a subset of your customer base, explain why, and
revise to disclose the percentage of revenue generated from the customer base
represented in this measure.
•Provide us with a sample calculation for fiscal 2022 that supports your disclosures.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 November 28, 2023 Page 3
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
November 28, 2023
Page 3
General
5.We note your responses to prior comments 1 and 3; however, we continue to note changes
you made to your disclosure appearing on the cover page, Summary and Risk Factor
sections relating to legal and operational risks associated with operating in China and PRC
regulations and it continues to be unclear to us that there have been changes in the
regulatory environment in the PRC since the amendment that was filed on July 17,
2023 warranting revised disclosure to mitigate the challenges you face and related
disclosures. As a nonexclusive example, on page 23, you no longer address the validity,
enforceability and scope of protection of intellectual property rights within China. Please
tell us the reasons for these changes or revise your disclosure throughout the registration
statement as applicable.
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
802, 803

No.
13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦ People’s Republic of China

November
16, 2023

Mr.
Matthew Derby

Ms.
Alexandra Barone

Ms.
Kathleen Collins

Mr.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

Amendment
to Registration Statement on Form F-1

Submitted
November 16, 2023

CIK
No. 0001964946

Dear
Mr. Derby, Ms. Barone, Ms. Collins, and Mr. Chen:

This
letter is in response to the letter dated October 17, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly. An Amendment to Registration
Statement on Form F-1 (the “F-1/A”) is being filed to accompany this letter.

Amendment
No. 3 to Draft Registration Statement on Form F-1

Cover
Page

    1.
    Please
    revise your cover page to specifically discuss risks arising from the legal system in China, including that rules and regulations
    in China can change quickly with little advance notice and the risk that the Chinese government may intervene or influence your operations.

Response:
We have revised the cover page to specifically discuss risks arising from the legal system in China, including that rules and regulations
in China can change quickly with little advance notice and the risk that the Chinese government may intervene or influence our operations.

Summary
Consolidated Financial Data, page 13

    2.
    We
    note your revised disclosures in response to prior comment 2. Please revise to remove pro forma per share information for fiscal
    2022 and the six months ended March 31, 2022. Refer to Item 11-02(12)(c)(2) of Regulation S-X.

Response:
We have revised page 13 to remove pro forma per share information for the fiscal year ended 2022 and the six months ended March 31, 2022.

Risk
Factors

Risks
Related to Doing Business in China, page 26

    3.
    Please
    revise your risk factor disclosure to discuss the risk that the Chinese government may intervene or influence the company’s
    operations at any time or provide a detailed explanation as to how your current risk factor disclosure captures this same risk.

Response:
We have revised our risk factors on page 26 to discuss the risk that the Chinese government may intervene or influence the company’s
operations at any time.

Management’s
Discussion and Analysis of Financial Conditions and Results of Operations Overview

Overview,
page 53

    4.
    We
    note your revised disclosures in response to prior comments 3 and 4. Please revise here to include a quantified discussion of the
    significant decrease in your customer count during the six months ended March 31, 2023 as a result of your shutdown. Also, include
    a discussion of how you plan to regain the large number of customers that were lost due to the shutdown, and whether you plan to
    increase the headcount that was reduced during the six months ended March 31, 2023. In addition, include quantified discussions of
    any known trends or uncertainties that are reasonably likely to have a material effect on your business or results of operations
    as a result of ceasing operations for three months and any intended efforts to rebuild your customer and employee base. Refer to
    Item 5(D) of Form 20-F.

Response:
We have revised throughout the disclosures on pages 53-54 to clarify that the Company did not cease operations entirely for the three
month period. Rather, the company transitioned to working remotely due to the COVID-19 lock down.

By
way of background, between November 13, 2022 and November 30, 2022, Guangzhou City was locked down due to a COVID-19 outbreak in another
part of China. During this period, the Company shifted its operations to remote work. After the PRC government loosened its earlier COVID-19
control policies, COVID-19 outbreaks spread and affected our personnel. A majority of the Company’s staff continued with remote
work until after Chinese New Year festivities through the end of January 2023. The Company’s operations resumed normally following
the second week of February 2023. There has not been a large loss of our customers during the six months period ended March 31, 2023
as further discussed in our response to Staff’s comment #5 herein.

Although
the number of customers did not materially change, the Company continued to see a decrease in revenue from the customized CRM system
development service and additional function development service for the six months ended March 31, 2023, as compared to the same period
for March 31, 2022, as previously disclosed. This may be attributed to our initial implementation of the new third-generation PaaS platform
and ongoing efforts to increase distributors and new customers to use the third-generation PaaS platform   . We anticipate
our revenue will grow as new distributors and customers purchase licenses and professional services for the third-generation PaaS platform.

Because
of the company’s shift to developing and marketing its third-generation PaaS platform during the lockdown period beginning November
2022, fewer personnel was required to implement its third-generation PaaS platform because PaaS products generally have embedded more
functionalities compared to the more hands-on personnel efforts for customized CRM development services. Accordingly, the number of employees
decreased over a one-year period from 143 for fiscal year ended September 30, 2021 to 84 for fiscal year ended September 30, 2022.

In
addition, for the third-generation PaaS platform, the company has sought to increase partnerships with distributors. Under the distribution
agreements, the company grants a license for its third-generation PaaS platform to the distributors who then handle customer acquisition,
sales, implementation, and delivery. Thus, the company anticipates gradual growth without substantially increasing costs or employee
headcount. Because of the business model for PaaS systems with less personnel requirement for the third-generation PaaS platform, the
company does not intend to increase the employee headcount to meet increasing customer demand and the company believes its current headcount
is sufficient to meet such demand for the near term.

Factors
Affecting Our Performance, page 54

    5.
    Please
    address the following as it relates to your revised disclosures in response to prior comment 3:

    ●
    You
                                            state that you “only had 21 customers using professional services” as of March
                                            31, 2023. Tell us whether this means that all 183 payment channel customers as of September
                                            30, 2022 were lost or revise to disclose the number of payment channel customers as of March
                                            31, 2023. In this regard, we note that you generated $146,358 in payment channel services
                                            revenue during the six months ended March 31, 2023.

    Response:
    The Company further wishes to clarify that there has not been a large loss of our customers. There were 22 customers and 33 customers
    using professional services during the six months period ending March 31, 2023 and during fiscal 2022, respectively. For the same
    periods, there were 22 and 33 payment channel customers, respectively. The 183 payment channel customer figure disclosed in the most
    recent filing represents the cumulative number of payment channel services customers from 2018 through September 2022, rather than
    the specific number of payment channel services customers as of September 30, 2022. We have revised this disclosure on page 54.

    ●
    You
                                            state that you had no customers with payment channel service as of September 30, 2021, however,
                                            you generated $227,321 from payment channel services during this period. Please explain and
                                            revise your disclosures as necessary.

    Response:
    We have revised the disclosure on page 55 and respectfully advise Staff that customers who purchased our professional services
    also purchased our payment channel services. Thus, for the fiscal year ended September 30, 2021, we had 25 customers that utilized
    our payment channel services which generated $227,321 in revenue.

  ●
  In
  your response, provide us with the number of lost customers during each period for both professional   and payment channel services.
  Response: We have revised the disclosure on page 54 and respectfully advise Staff of the number of lost customers during each period
  for both professional services and payment channel services as listed below.

    For the year ended September 30, 2021
    For the year ended September 30, 2022
    For the six months ended March 31, 2022
    For the six months ended March 31, 2023

    Lost Customers
      5
      8
      8
      13

    ●
    Provide
                                            us with the calculations that support your renewal and churn rates for each period presented
                                            and ensure your disclosures regarding customer count support such calculations.

    Response:
    We have revised the disclosure on page 54 to match the calculations provided below for the Company’s renewal and churn rates
    for each period. The churn rate is calculated by dividing the number of lost customers during a period by the total number of customers
    at the start of the time period. The renewal rate is calculated by dividing the number of customers who choose to renew their contracts
    by the customers who need to renew their contracts.

    Rate
      For
                                            the year ended

 September
                                            30, 2021

      For
                                            the year ended

 September
                                            30, 2022

      For
                                            the six months ended March 31, 2022
      For
                                            the six months ended March 31, 2023

    Renewal
    Rate
      (8/11)
                                            =73 %
      (15/18)
                                            =83 %
      (11/12)
                                            =92 %
      (14/16)
                                            =88 %

    Churn
    Rate
      (5/16)
=31 %
      (8/25)
                                            =32 %
      (8/25)
                                            =32 %
      (13/33)
                                            =39 %

    ●
    Your
                                            net dollar expansion rates appear to imply that revenue from existing customers decreased
                                            significantly from the start of the period to the end of the period such that revenue growth
                                            in fiscal 2022 compared to 2021 would appear to be from new customers. Please confirm or
                                            explain further how you determine net dollar expansion rates. Also, revise your results of
                                            operations disclosure to include a discussion of revenue from new versus existing customers
                                            for each period presented.

    Response:
    We have revised the disclosure on page 54 and respectfully advise Staff that the net dollar expansion rates are presently calculated
    by taking the revenue generated from renewing customers during the stated fiscal year end and dividing by revenue from renewing customers
    from the previous fiscal year end.

    Rate
    For
                                            the year ended

 September
                                            30, 2021

    For
                                            the year ended

 September
                                            30, 2022

    For
                                            the six months ended

 March
                                            31, 2022

    For
                                            the six months ended

 March
                                            31, 2023

    Net
    Dollar Expansion Rate
      4 %
      14 %
      12 %
      12 %

We
have also revised the results of operations disclosure on pages 57 and 62 to include a discussion of revenue from new versus existing
customers for each period presented.

Thank
you in advance for your assistance in reviewing this response and the F-1/A. Should you have any questions with respect to the above
responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

United States securities and exchange commission logo
October 17, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 3 to Registration Statement on Form F-1
Filed September 7, 2023
File No. 333-274404
Dear Shaozhang Lin:
            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 August 23, 2023 letter.
Registration Statement on Form F-1 Filed September 7, 2023
Cover Page
1.Please revise your cover page to specifically discuss risks arising from the legal system in
China, including that rules and regulations in China can change quickly with little advance
notice and the risk that the Chinese government may intervene or influence your
operations.
Summary Consolidated Financial Data, page 13
2.We note your revised disclosures in response to prior comment 2.  Please revise to remove
pro forma per share information for fiscal 2022 and the six months ended March 31,
2022.  Refer to Item 11-02(12)(c)(2) of Regulation S-X.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 October 17, 2023 Page 2
 FirstName LastNameShaozhang Lin
Youxin Technology Ltd
October 17, 2023
Page 2
Risk Factors
Risks Related to Doing Business in China, page 26
3.Please revise your risk factor disclosure to discuss the risk that the Chinese government
may intervene or influence the company’s operations at any time or provide a detailed
explanation as to how your current risk factor disclosure captures this same risk.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 53
4.We note your revised disclosures in response to prior comments 3 and 4.  Please revise
here to include a quantified discussion of the significant decrease in your customer count
during the six months ended March 31, 2023 as a result of your shutdown.  Also, include a
discussion of how you plan to regain the large number of customers that were lost due to
the shutdown, and whether you plan to increase the headcount that was reduced during the
six months ended March 31, 2023.  In addition, include quantified discussions of any
known trends or uncertainties that are reasonably likely to have a material effect on your
business or results of operations as a result of ceasing operations for three months and any
intended efforts to rebuild your customer and employee base. Refer to Item 5(D) of Form
20-F.
Factors Affecting Our Performance, page 54
5.Please address the following as it relates to your revised disclosures in response to prior
comment 3:
•You state that you "only had 21 customers using professional services" as of March
31, 2023.  Tell us whether this means that all 183 payment channel customers as of
September 30, 2022 were lost or revise to disclose the number of payment channel
customers as of March 31, 2023.  In this regard, we note that you generated $146,358
in payment channel services revenue during the six months ended March 31, 2023.
•You state that you had no customers with payment channel service as of September
30, 2021, however, you generated $227,321 from payment channel services during
this period.  Please explain and revise your disclosures as necessary.
•In your response, provide us with the number of lost customers during each period for
both professional services and payment channel services.
•Provide us with the calculations that support your renewal and churn rates for each
period presented and ensure your disclosures regarding customer count support such
calculations.
•Your net dollar expansion rates appear to imply that revenue from existing customers
decreased significantly from the start of the period to the end of the period such that
revenue growth in fiscal 2022 compared to 2021 would appear to be from new
customers.  Please confirm or explain further how you determine net dollar expansion
rates.  Also, revise your results of operations disclosure to include a discussion of
revenue from new versus existing customers for each period presented.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 October 17, 2023 Page 3
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
October 17, 2023
Page 3
            Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

CORRESP
1
filename1.htm

Youxin
Technology Ltd

Room
802, 803

No.
13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦  People’s Republic of China

September
7, 2023

Mr.
Matthew Derby

Ms.
Alexandra Barone

Ms.
Kathleen Collins

Mr.
Chen Chen

Office
of Technology

Division
of Corporate Finance

U.S.
Securities and Exchange Commission

Mail
Stop 4631

100
F Street, N.E.

Washington,
D.C. 20549-4631

    Re:
    Youxin
    Technology Ltd

Registration
Statement on Form F-1

Submitted
September 7, 2023

CIK
No. 0001964946

Dear
Mr. Derby, Ms. Barone, Ms. Collins, and Mr. Chen:

This
letter is in response to the letter dated August 23, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”).
For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly. A registration statement
on Form F-1 (the “F-1”) is being filed to accompany this letter.

Amendment
No. 2 to Draft Registration Statement on Form F-1

Cover
Page

    1.
    We
    note from your disclosure on page ii that you exclude Hong Kong and Macau from your definition of “PRC” or “China”
    for the purpose of your annual report. Please revise to remove the exclusion of Hong Kong and Macau from such definition. Clarify
    that all the legal and operational risks associated with having operations in the People’s Republic of China (PRC) also apply
    to operations in Hong Kong and Macau. In this regard, ensure that your disclosure does not narrow risks related to operating in the
    PRC to mainland China only. Where appropriate, you may describe PRC law and then explain how law in Hong Kong and Macau differs from
    PRC law and describe any risks and consequences to the company associated with those laws.

Response:
We respectfully advise Staff that the definition of “China” or “PRC” disclosed on page ii refers to the People’s
Republic of China which includes Macau and Hong Kong. We have further revised throughout the disclosure to clarify that various legal
and operational risks associated with operating in the Mainland China also apply to operations in Macau and Hong Kong to the extent
applicable. As currently disclosed in the F-1, we respectfully advise Staff that the Company conducts all business operations in
Mainland China. In cases where the distinction between Mainland China and the Hong Kong and Macau Special Administrative Regions of the
People’s Republic of China remain legally or economically relevant, references to “Mainland China” have been retained.

Capitalization,
page 51

    2.
    It
    appears from your disclosures on page F-53 that on April 28, 2023 the Mezzanine Equity Holders redeemed their preferred equities
    in Guangzhou Youxin and held ordinary shares issued by Youxin Cayman. Please revise here to give effect to such redemption or explain
    why you believe pro forma effect to such transaction is not necessary. Also, revise the Summary Consolidated Financial Data on page
    13 and provide pro forma EPS for the latest year and interim period reflecting the impact of such redemption. Refer to Rule 11-01(a)(8)
    of Regulation S-X.

Response:
We have revised the disclosure on page 51 to give effect to the redemption referenced on page F-53. Additionally, we have further revised
page 13 to provide the pro forma EPS for the latest year and interim period reflecting the impact of such redemption in compliance
with Rule 11-01(a)(8) of Regulation S-X.

Management’s
Discussion and Analysis of Financial Conditions and Results of Operations Overview

Factors
Affecting Our Performance, page 54

    3.
    Please address the following as it relates to your response to prior comment 6:

    ●
    Revise
    to describe how you calculate customer renewal rate.

    ●
    Clarify
    how your measure of net dollar expansion rate supports your discussion of new customer acquisitions. In this regard, based on how
    you define the calculation, this measure appears to reflect revenue from existing customers that you retained and/or grew during
    the period. If true, consider moving the discussion of this measure to your “expanding usage by existing customer” discussion
    or explain how such measure supports new customer growth.

    ●
    Disclose
    the total number of customers as of each period included in the filing rather than stating you had “over 50 customers.”

    ●
    Tell
    us, and consider disclosing, the number of customers you have lost as a result of reducing operating Customized CRM system development
    service and the related additional function development service.

Response:
We have revised our disclosure on pages 54 and 55 to further clarify that:

    ●
    The
    customer renewal rate is calculated by dividing the number of customers who renew their contracts by the total number of customers;

    ●
    The
    net dollar expansion rate is measured by comparing revenue from customers at the start of a period with the revenue generated by
    those same customers at the end of a period. Per Staff’s suggestion, we have moved the disclosure to our “Expanding Usage
    by Existing Customer” discussion;

    ●
    We
    have revised throughout the disclosure to further clarify that we had 25 customers using professional services and 183 customers
    using our payment channel services in fiscal year 2022;

    ●
    We
    have added to our disclosure on page 55 relative to the number of customers we have lost as a result of certain reduced development
    services.

Results
of Operations

Comparison
of Results of Operations for the Six Months Ended March 31, 2023 and 2022, page 62

    4.
    We
    note the significant decline in your Customized CRM system development service revenue and additional function development service
    revenue from the six months ended March 31, 2022 compared to the same period in fiscal 2023, which you attribute to “the Company
    gradually reducing operating its Customized CRM system development service and the related additional function development service.”
    Please revise to clarify what is meant by “reducing operating” efforts. Also, revise your Overview section to include
    a discussion of any known trends or uncertainties that are reasonably likely to have a material effect on your business or results
    of operations as a result of such effort. Refer to Item 5(D) of Form 20-F.

Response:
We have revised the disclosure on page 62 to remove reference to “reducing operating” efforts in order to clarify that “the
decrease was mainly due to the PRC government’s gradual removal of COVID-19 prevention and control policies, and all of our
company’s employees were infected with COVID-19 and our company ceased operations for nearly three months.

 General

    5.
    We
    note the changes you made to your disclosure appearing on the cover page, Summary and Risk Factor sections relating to legal and
    operational risks associated with operating in China and PRC regulations. It is unclear to us that there have been changes in the
    regulatory environment in the PRC since the amendment that was filed on July 17, 2023 warranting revised disclosure to mitigate the
    challenges you face and related disclosures. The Sample Letters to China-Based Companies sought specific disclosure relating to the
    risk that the PRC government may intervene in or influence your operations at any time, or may exert control over operations of your
    business, which could result in a material change in your operations and/or the value of the securities you are registering for sale.
    The Sample Letters also sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules
    and regulations in China can change quickly with little advance notice. We do not believe that your revised disclosure referencing
    the PRC government’s intent to strengthen its regulatory oversight conveys the same risk. Please revise.

Response:
We have revised the disclosure on the cover page, Summary and Risk Factor sections relating to legal and operational risks associated
with operating in China and PRC regulations to bolster the risks posed by the PRC government’s intent to strengthen its regulatory
oversight.

Thank
you in advance for your assistance in reviewing this response and the DRS/A. Should you have any questions with respect to the above
responses, please contact me or our U.S. legal counsel, Anthony W. Basch.

    Sincerely,

    /s/
    Shaozhang Lin

    Shaozhang
    Lin

United States securities and exchange commission logo
August 23, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted August 15, 2023
CIK No. 0001964946
Dear Shaozhang Lin:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 31, 2023 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
Cover Page
1.We note from your disclosure on page ii that you exclude Hong Kong and Macau from
your definition of “PRC” or “China” for the purpose of your annual report. Please revise
to remove the exclusion of Hong Kong and Macau from such definition. Clarify that all
the legal and operational risks associated with having operations in the People’s Republic
of China (PRC) also apply to operations in Hong Kong and Macau. In this regard, ensure
that your disclosure does not narrow risks related to operating in the PRC to mainland

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 August 23, 2023 Page 2
 FirstName LastNameShaozhang Lin
Youxin Technology Ltd
August 23, 2023
Page 2
China only. Where appropriate, you may describe PRC law and then explain how law in
Hong Kong and Macau differs from PRC law and describe any risks and consequences to
the company associated with those laws.
Capitalization, page 51
2.It appears from your disclosures on page F-53 that on April 28, 2023 the Mezzanine
Equity Holders redeemed their preferred equities in Guangzhou Youxin and held ordinary
shares issued by Youxin Cayman.  Please revise here to give effect to such redemption or
explain why you believe pro forma effect to such transaction is not necessary.  Also,
revise the Summary Consolidated Financial Data on page 13 and provide pro forma EPS
for the latest year and interim period reflecting the impact of such redemption.  Refer to
Rule 11-01(a)(8) of Regulation S-X.
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Overview
Factors Affecting Our Performance, page 54
3.Please address the following as it relates to your response to prior comment 6:
•Revise to describe how you calculate customer renewal rate.
•Clarify how your measure of net dollar expansion rate supports your discussion of
new customer acquisitions.  In this regard, based on how you define the calculation,
this measure appears to reflect revenue from existing customers that you retained
and/or grew during the period.  If true, consider moving the discussion of this
measure to your "expanding usage by existing customer" discussion or explain how
such measure supports new customer growth.
•Disclose the total number of customers as of each period included in the filing rather
than stating you had "over 50 customers."
•Tell us, and consider disclosing, the number of customers you have lost as a result of
reducing operating Customized CRM system development service and the related
additional function development service.
Results of Operations
Comparison of Results of Operations for the Six Months Ended March 31, 2023 and 2022, page
62
4.We note the significant decline in your Customized CRM system development service
revenue and additional function development service revenue from the six months ended
March 31, 2022 compared to the same period in fiscal 2023, which you attribute to "the
Company gradually reducing operating its Customized CRM system development service
and the related additional function development service."  Please revise to clarify what is
meant by "reducing operating" efforts.  Also, revise your Overview section to include a
discussion of any known trends or uncertainties that are reasonably likely to have a
material effect on your business or results of operations as a result of such effort.  Refer to
Item 5(D) of Form 20-F.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 August 23, 2023 Page 3
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
August 23, 2023
Page 3
General
5.We note the changes you made to your disclosure appearing on the cover page, Summary
and Risk Factor sections relating to legal and operational risks associated with operating
in China and PRC regulations.  It is unclear to us that there have been changes in the
regulatory environment in the PRC since the amendment that was filed on July 17, 2023
warranting revised disclosure to mitigate the challenges you face and related disclosures.
The Sample Letters to China-Based Companies sought specific disclosure relating to the
risk that the PRC government may intervene in or influence your operations at any time,
or may exert control over operations of your business, which could result in a material
change in your operations and/or the value of the securities you are registering for sale.
The Sample Letters also sought specific disclosures relating to uncertainties regarding the
enforcement of laws and that the rules and regulations in China can change quickly with
little advance notice.  We do not believe that your revised disclosure referencing the PRC
government’s intent to strengthen its regulatory oversight conveys the same risk.  Please
revise.
            You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the
financial statements and related matters. Please contact Alexandra Barone, Staff Attorney, at
(202) 551-8816 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

United States securities and exchange commission logo
July 31, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 1 to
Draft Registration Statement on Form F-1
Submitted July 17, 2023
CIK No. 0001964946
Dear Shaozhang Lin:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
June 29, 2023 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Cover Page
1.Please revise your discussion about how cash is transferred through your organization to
provide cross-references to the consolidated financial statements.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 July 31, 2023 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
July 31, 2023
Page 2
2.We note your response to prior comment 3. Even though the company conducts its
operations in China only, please clarify that the legal and operational risks associated with
operating in China also apply to operations in Hong Kong. In this regard, we note the
company has a subsidiary in Hong Kong. In addition, to the extent material, discuss the
applicable laws and regulations in Hong Kong as well as the related risks and
consequences. Also consider making conforming changes in your Regulations section on
page 86 to address regulations in Hong Kong that may affect your business operations.
Prospectus Summary, page 1
3.Please expand your discussion about the permissions and approvals required to be
obtained from Chinese authorities to operate your business to also discuss any permissions
and approvals required to be obtained from Chinese authorities to offer securities to
foreign investors. If you determine no permissions are required, provide an explanation as
to whether you consulted counsel and, if not, why you did not consult counsel and why
you do not need any permissions or approvals to operate your business or offer securities
to foreign investors.
Risk Factors
As more of our sales efforts are targeted at larger enterprise clients..., page 18
4.We note your response to prior comment 12. Please file any material agreements as
exhibits or tell us why it is not required.  Refer to Item 601(b)(10) of Regulation S-K for
guidance.
Capitalization, page 51
5.You state that the issuance of Class A shares and Class B shares were effected on April
11, 2023 and April 21, 2023.  However, various places in your financial statements (e.g.,
"*"footnote reference on the face of financial statements, Note 13 related to Subscription
Receivable, etc.) appear to indicate that such issuance occurred on April 12, 2023.  Please
revise the inconsistencies throughout the filing or explain.
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Overview, page 53
6.We note your revised disclosures in response to prior comment 13, however, it remains
unclear what financial and/or non-financial measures management uses to monitor the
retention and acquisition of customers as well as expansion of existing customers.  For
example, clarify whether you use measures such as churn rate, retention rate, net dollar
expansion rate, etc., or specify the measures you do use and revise to include a quantified
discussion of such measures.  Refer to SEC Release 33-10751.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 July 31, 2023 Page 3
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
July 31, 2023
Page 3
General
7.Please update your financial statements pursuant to Item 8.A.5 of Form 20-F or explain.
            You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the
financial statements and related matters. Please contact Alexandra Barone, Staff Attorney, at
(202) 551-8816 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch

United States securities and exchange commission logo
June 29, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Draft Registration Statement on Form F-1
Submitted June 2, 2023
CIK No. 0001964946
Dear Shaozhang Lin:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1
Cover Page
1.Provide a description of how cash is transferred through your organization. State whether
any transfers, dividends, or distributions have been made to date between the holding
company, its subsidiaries, or to investors, and quantify the amounts where applicable.
Provide cross-references to the consolidated financial statements. Also disclose whether
the company has written cash management policies and procedures that dictate how funds
are transferred, and if so, describe these policies and procedures.

 FirstName LastNameShaozhang Lin
 Comapany NameYouxin Technology Ltd
 June 29, 2023 Page 2
 FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
June 29, 2023
Page 2
2.We note your discussion of the CSRC trial measures on page 24, including your statement
that you have to file with the CSRC with respect to this offering. Please revise your cover
page to briefly explain whether and how you qualify as a direct overseas listing, an
indirect overseas listing, or neither. Include similar disclosures in your prospectus
summary and risk factors sections.
3.We note the disclosure that your reference to China or the PRC excludes Taiwan, Hong
Kong, and Macau. Please clarify that the “legal and operational” risks associated with
operating in China also apply to operations in Hong Kong/Macau/Taiwan. In addition, to
the extent material, discuss the applicable laws and regulations in
Hong Kong/Macau/Taiwan, as applicable, as well as the related risks and consequences.
In addition, consider making conforming changes in your Regulations section on page 84
to address regulations in Hong Kong/Macau/Taiwan that may affect your business
operations.
Prospectus Summary, page 3
4.Please revise the diagram of the company's corporate structure to be easily legible. In your
diagram, identify clearly the entity in which investors are purchasing their interest and the
entities in which the company's operations are conducted.
5.In your summary of risk factors, specifically discuss risks arising from the legal system in
China, including risks and uncertainties regarding the enforcement of laws and that rules
and regulations in China can change quickly with little advance notice; and the risk that
the Chinese government may intervene or influence your operations at any time, or may
exert more control over offerings conducted overseas and/or foreign investment in China-
based issuers, which could result in a material change in your operations and/or the value
of the securities you are registering for sale. Acknowledge any risks that any actions by
the Chinese government to exert more oversight and control over offerings that are
conducted overseas and/or foreign investment in China-based issuers could significantly
limit or completely hinder your ability to offer or continue to offer securities to investors
and cause the value of such securities to significantly decline or be worthless. For each of
the risks related to doing business in China, provide a specific cross-reference to the more
detailed risk factor.
6.In the prospectus summary, disclose each permission or approval that you or your
subsidiaries are required to obtain from Chinese authorities to operate your business and
to offer the securities being registered to foreign investors. State whether you or your
subsidiaries are covered by permissions requirements from the China Securities
Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any
other governmental agency, and state affirmatively whether you have received all
requisite permissions or approvals and whether any permissions or approvals have been
denied. Please also describe the consequences to you and your investors if you or your
subsidiaries: (i) do not receive or maintain such permissions or approvals, (ii)
inadvertently conclude that such permissions or approvals are not required, or (iii)

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applicable laws, regulations, or interpretations change and you are required to obtain such
permissions or approvals in the future.
7.In the prospectus summary, provide a clear description of how cash is transferred through
your organization. Quantify any cash flows and transfers of other assets by type that have
occurred between the holding company and its subsidiaries and direction of transfer.
Quantify any dividends or distributions that a subsidiary has made to the holding company
and which entity made such transfer, and their tax consequences. Similarly quantify
dividends or distributions made to U.S. investors, the source, and their tax consequences.
Your disclosure should make clear if no transfers, dividends, or distributions have been
made to date. Describe any restrictions on foreign exchange and your ability to transfer
cash between entities, across borders, and to U.S. investors. Describe any restrictions and
limitations on your ability to distribute earnings from the company, including your
subsidiaries, to the parent company and U.S. investors.
8.We note your disclosure in the forefront of the registration statement related to the
increase in the company's revenues and gross profit in fiscal years 2021 and 2022.
Balance this disclosure with equally prominent disclosure of the company's net loss for
the same periods.
Implications of Being and Emerging Growth Company, page 8
9.Please note that your election to take advantage of the extended transition period for
complying with new or revised accounting standards is not irrevocable.  Please revise
your disclosures as necessary.  Refer to Question 37 of the FAQ on Title 1 of the JOBS
Act.
Risk Factors, page 12
10.Please add a risk factor discussing any risks related to your dual class capital structure,
such as the risks that your dual class structure may render your shares ineligible for
inclusion in certain stock market indices, and thus adversely affect share price and
liquidity.
11.Please revise your risk factor disclosure to indicate you have a history of losses and
highlight the explanatory paragraph in your audit opinion raising substantial doubt about
your ability to continue as a going concern. Additionally, disclose the potential effect
the going concern opinion may have on your ability to raise additional funds through
equity or debt financing.
As more of our sales efforts are targeted at larger enterprise clients..., page 16
12.We note your disclosure that your ability to maintain close relationships with your major
clients is essential to the success of your business. To the extent material, revise to discuss
the material terms of any agreements with your major clients, including termination
provisions, and file those agreements as exhibits or tell us why it is not required.

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June 29, 2023
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Management's Discussion and Analysis of Financial Conditions and Results of Operations
Overview, page 51
13.Please revise the MD&A Overview section to discuss management's plans to scale your
operations.  Address any milestones you intend to reach, the steps you will take to achieve
each milestone, and the anticipated timing.  Also, revise your liquidity discussion to
address and quantify any material cash requirements needed to reach such milestones.
Refer to Item 5 of Form 20-F.
14.You state that new customer acquisition and expanding usage by existing customers are
factors affecting your results of operations.  Please tell us what measure(s) you use to
monitor the retention and acquisition of customers as well as expansion of existing
customers and revise to include a quantified discussion of such measures.  Refer to SEC
Release 33-10751.
15.We note that "as of September 30, 2022, three suppliers accounted for 87% of [y]our
accounts payable" and that "as of September 30, 2021, one supplier accounted for 83% of
[y]our accounts payable." Please revise your disclosure where appropriate to provide a
more complete discussion of your relationship with your suppliers and quantify the
percentage of accounts payable each of the top three suppliers accounted for.  In addition,
clarify whether you have material agreements with any of your suppliers upon which you
are substantially dependent, and file those agreements as exhibits. Refer to Item
601(b)(10) of Regulation S-K.
Liquidity and Capital Resources, page 58
16.Please clarify whether you are dependent on the proceeds of this offering to finance your
operations for the next 12 months, as well as the minimum dollar amount of funding
required to remain in business for at least the next 12 months. Refer to Item 5.B of
Form 20-F, and Section IV of SEC Release No. 33-8350.
Consolidated Financial Statements of Youxin Technology Ltd., page F-3
17.We note that your financial statements are giving retroactive effect to the issuance of
shares effected on April 12, 2023.  However, it is unclear from your disclosures in Note
13 whether such issuance is part of the reorganization described in Note 1.  Please explain
and revise your disclosures throughout the filing, as necessary.  In your response, tell us
your basis for presenting the issuance of such shares on a retrospective basis and provide
the specific accounting guidance you relied upon to support your conclusion.  Also,
explain why the information in your pro forma capitalization table differs from your
financial statements.

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June 29, 2023
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Notes to Consolidated Financial Statements
Note 3 - Summary of Significant Accounting Policies
f. Cash and cash equivalents, page F-10
18.Please provide us with a detailed breakdown of the items included in your total cash and
cash equivalents and ensure that, at a minimum, you separately provide the amounts held
in cash, time deposits and liquid investments. To the extent you hold any types of “highly
liquid investments,” tell us what they are and provide the amounts held in each.
l. Revenue Recognition, page F-12
19.Please tell us, and revise to disclose, the cancellation terms and refund policy for each of
your revenue streams.
Note 15. Concentrations and Risks
Concentrations, page F-27
20.Please revise to provide a breakdown of revenue from each customer that accounted for
more than 10% of your revenue for each period presented.  In this regard, identify and
distinguish each customer by reference to customer A, customer B, customer C, as an
example.  Similar disclosures should be provided for your concentration of accounts
receivable. Refer to ASC 280-10-50-42 and ASC 275-10-50-18(a).
General
21.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communication.
            You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments on the
financial statements and related matters.  Please contact Alexandra Barone, Staff Attorney, at
(202) 551-8816 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Anthony Basch