SecProbe.io

CORRESP
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 YSX Tech. Co., Ltd

 March 3, 2026

 Via EDGAR

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:
 Nicholas Nalbantian

 Re:
 YSX Tech. Co., Ltd

 Registration Statement on Form F-3, as amended

 Initially filed on February 13, 2026

 File No. 333-293464

 Ladies and Gentlemen:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, YSX Tech. Co., Ltd hereby requests that the effectiveness
of the above-referenced Registration Statement on Form F-3, be accelerated to and that the Registration Statement become effective
at 4:30 p.m., Eastern Time, on March 5, 2026, or as soon thereafter as practicable.

 Very truly yours,

 YSX Tech. Co., Ltd

 By:
 /s/ Jie Xiao

 Name:
 Jie Xiao

 Title:
 Chief Executive Director

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 23, 2026

Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
Room 102, Building 1
No. 22, Huazhou Road
Haizhu District, Guangzhou, Guangdong
China

 Re: YSX Tech Co., Ltd
 Registration Statement on Form F-3
 Filed February 13, 2026
 File No. 333-293464
Dear Jie Xiao:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Nicholas Nalbantian at 202-551-7470 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Ying Li
</TEXT>
</DOCUMENT>

CORRESP
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YSX TECH. CO., LTD

401, 4 / F, Building 12, 1601 South Guangzhou Avenue,
Haizhu District,

Guangzhou, Guangdong, PRC

VIA EDGAR

December 16, 2024

Mr. Brian Fetterolf

U.S. Securities and Exchange Commission

Division of Corporation Finance

Trade & Services

Washington, D.C. 20549

Re: YSX TECH CO., LTD

Registration Statement on Form F-1, as amended

File No. 333-280312

Dear Mr. Fetterolf:

In accordance with Rule 461
of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended,
YSX TECH CO., LTD hereby requests acceleration of effectiveness of the above referenced Registration Statement so that it will become
effective at 4:00 pm, Eastern Time, on December 17, 2024, or as soon thereafter as practicable.

    Very truly yours,

    YSX TECH CO., LTD

    By:
    /s/ Jie Xiao

    Name:
    Jie Xiao

    Title:
    Chief Executive Officer

cc. Ying Li, Esq., Hunter Taubman Fischer &
Li LLC

CORRESP
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Kingswood Capital Partners, LLC

Tower 56

126 E, 56th Street, Suite 22S

New York, NY 10022

VIA EDGAR

December 16, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

Attention:
      Brian Fetterolf

Lilyanna Peyser

    Re:

    YSX Tech Co., Ltd (CIK No. 1993463)

    Registration Statement on Form F-1,
as amended (File No. 333-280312)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the “Act”), the undersigned hereby joins YSX Tech Co., Ltd (the “Company”) in connection
with its request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 4:00 p.m., Eastern Time,
on December 17, 2024, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and
Regulations under the Act, the undersigned wishes to advise you that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advise that the underwriters have
complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature page follows]

    Very truly yours,

    Kingswood Capital Partners, LLC

    By:
    /s/ Tony Tian

    Name:
    Tony Tian

    Title:
    Senior Managing Director

CORRESP
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September 5, 2024

Via Edgar

Mr. Brian Fetterolf

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

  Re:
  YSX Tech Co., Ltd

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

  File No. 333-280312

Dear Mr. Fetterolf,

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

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

Risk Factors, page 23

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

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

Exhibit 99.7

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

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

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

    Very truly yours,

    /s/ Jie Xiao

    Name:
    Jie Xiao

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

August 29, 2024
Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
401, 4 / F, Building 12
1601 South Guangzhou Avenue
Haizhu District, Guangzhou, Guangdong, PRC
Re:YSX Tech Co., Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed August 9, 2024
File No. 333-280312
Dear  Jie Xiao:
            We have reviewed your amended registration statement and have the following
comment(s).
            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 July 8, 2024 letter.
Amendment No. 1 to Registration Statement on Form F-1 filed August 9, 2024
Risk Factors, page 23
1.We note your revised disclosure in response to comment 1. Please further revise the
second risk factor to restore the language in the body of the risk factor, as you did in the
title of the risk factor, that "PRC laws and regulations...can change quickly with little
advance notice." Also restore the language that "it may be more difficult to evaluate the
outcome of administrative and court proceedings and the level of legal protection we
enjoy in the mainland China legal system than in more developed legal systems."
Exhibit 99.7
We re-issue comment 6. Please revise section 1.2.1 of the opinion to exclude the PRC
Companies. We also note that you revised section 1.2.2 of the opinion to delete the 2.

August 29, 2024
Page 2
exclusion of the PRC Companies; please revise to restore the original language excluding
the PRC Companies from each of (a) and (b).
            Please contact Patrick Kuhn at 202-551-3308 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Linda Ni

CORRESP
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August 9, 2024

Via Edgar

Mr. Brian Fetterolf

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: YSX Tech Co., Ltd

Registration Statement on Form F-1

Filed June 18, 2024

File
No. 333-280312

Dear Mr. Fetterolf,

This letter is in response to the letter
dated July 8, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to YSX Tech Co., Ltd (the “Company”, “we”, or “our”). For ease of reference, we have recited
the Commission’s comments in this response. An amendment to the registration statement on Form F-1 is being filed to accompany this
letter (the “Amendment”).

Registration Statement on Form F-1 filed June
18, 2024 Risk Factors, page 23

1. We note the changes you made to your disclosure, including on the cover page,
on pages 9-10 and 14, in the first, second and third risk factors of this section, in the risk factor at the bottom of page 35 and in
the risk factor "We rely on contractual arrangements with the VIEs" on page 40, and we further note that you deleted the fifth
risk factor and the discussion of the UFLPA on page 29. It is unclear to us that there have been changes in the regulatory environment
in the PRC since the amendment to your draft registration statement that was submitted on February 27, 2024, warranting revised disclosure
that mitigates 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. We remind you that, pursuant to federal securities rules, the term “control” (including the terms “controlling,”
 “controlled by,” and “under common control with”) as defined in Securities Act Rule 405 means “the possession,
direct or indirect, of the power to direct or cause the direction of the management and policies of a person, whether through the ownership
of voting securities, by contract, or otherwise.” 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 conveys the same risks. Please restore your disclosures in these areas to the disclosures as they
existed in the registration statement as of February 27, 2024. Please also refer to prior comment 1 in our letter dated January 16, 2024.

Response: We acknowledge Staff’s
comment and have restored our disclosures in the aforementioned areas to the disclosures as they existed in the registration statement
as of February 27, 2024 in the Amendment.

Capitalization, page 54

2. Please revise the amounts presented in the total capitalization line item to exclude
the amounts presented in the cash and cash equivalents line item. Refer to Item 3.B of Form 20-F for guidance.

Response: We acknowledge Staff’s
comment and have revised the amounts presented in the total capitalization line item in the Amendment to exclude the amounts presented
in the cash and cash equivalents line item.

Dilution, page 55

3. Please revise your historical and pro forma tangible book value amounts to exclude
deferred initial public listing costs.

Response: We acknowledge Staff’s
comment and revised the historical and pro forma tangible book value amounts to exclude deferred initial public listing costs.

Consolidated Financial Statements,
page F-1

 4. Please update your financial statements in accordance with
Item 8.A.4 of Form 20-F.

Response: We acknowledge Staff’s
comment and revised the historical and pro forma tangible book value amounts in the Amendment to exclude deferred initial public listing
costs.

Exhibit Index, page II-5

5. We note counsel's opinion in Exhibit 5.1 that "[t]he statements contained
in the Registration Statement in the section headed "Cayman Islands Taxation", insofar as they purport to summarise the laws
or regulations of the Cayman Islands, are accurate in all material respects and that such statements constitute our opinion." Please
revise the exhibit index to also file this opinion as Exhibit 8, revise your disclosure in the corresponding "Cayman Islands Taxation"
section to state that the disclosure is the opinion of Ogier, and have counsel delete the reference in the opinion to the disclosure being
a summary of tax consequences ("insofar as they purport to summarise the laws or regulations of the Cayman Islands").

Response: We acknowledge Staff’s
comment and made the following revisions in the Amendment : (i) revised the exhibit index to also file the referenced opinion as Exhibit
8.2; (ii) revised the disclosure in the corresponding "Cayman Islands Taxation" section to state that the disclosure is the
opinion of Ogier; and (iii) deleted the reference in the opinion to the disclosure being a summary of tax consequences ("insofar
as they purport to summarise the laws or regulations of the Cayman Islands").

6. Please revise Section 1.2.1 of Exhibit 99.7 to exclude the PRC Companies. Please
revise your disclosure in the corresponding "People's Republic of China Enterprise Taxation" section to state that the disclosure
is the opinion of Beijing Jingsh Law firm Shenzhen Office.

Response: We acknowledge Staff’s
comment and have made the following revisions in the Amendment:(i) revised Section 1.2.2 of Exhibit 99.7 to exclude the PRC Companies;
and (ii) revised the disclosure in the corresponding "People's Republic of China Enterprise Taxation" section to state that
the disclosure is the opinion of Beijing Jingsh Law firm Shenzhen Office.

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

    Very truly yours,

    /s/ Jie Xiao

    Name:
    Jie Xiao

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

July 8, 2024
Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
401, 4 / F, Building 12
1601 South Guangzhou Avenue
Haizhu District, Guangzhou, Guangdong, PRC
Re:YSX Tech Co., Ltd
Registration Statement on Form F-1
Filed June 18, 2024
File No. 333-280312
Dear  Jie Xiao:
            We have reviewed your registration statement and have the following comment(s).
            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.
Registration Statement on Form F-1 filed June 18, 2024
Risk Factors, page 23
We note the changes you made to your disclosure, including on the cover page, on pages
9-10 and 14, in the first, second and third risk factors of this section, in the risk factor at
the bottom of page 35 and in the risk factor "We rely on contractual arrangements with the
VIEs" on page 40, and we further note that you deleted the fifth risk factor and the
discussion of the UFLPA on page 29. It is unclear to us that there have been changes in
the regulatory environment in the PRC since the amendment to your draft registration
statement that was submitted on February 27, 2024, warranting revised disclosure
that mitigates 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. We remind you 1.

July 8, 2024
Page 2
that, pursuant to federal securities rules, the term “control” (including the terms
“controlling,” “controlled by,” and “under common control with”) as defined in Securities
Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the
direction of the management and policies of a person, whether through the ownership of
voting securities, by contract, or otherwise.” 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 conveys the same risks. Please restore your disclosures in
these areas to the disclosures as they existed in the registration statement as of February
27, 2024. Please also refer to prior comment 1 in our letter dated January 16, 2024.
Capitalization, page 54
2.Please revise the amounts presented in the total capitalization line item to exclude the
amounts presented in the cash and cash equivalents line item. Refer to Item 3.B of Form
20-F for guidance.
Dilution, page 55
3.Please revise your historical and pro forma tangible book value amounts to exclude
deferred initial public listing costs.
Consolidated Financial Statements, page F-1
4.Please update your financial statements in accordance with Item 8.A.4 of Form 20-F.
Exhibit Index, page II-5
5.We note counsel's opinion in Exhibit 5.1 that "[t]he statements contained in the
Registration Statement in the section headed "Cayman Islands Taxation", insofar as they
purport to summarise the laws or regulations of the Cayman Islands, are accurate in all
material respects and that such statements constitute our opinion."  Please revise the
exhibit index to also file this opinion as Exhibit 8, revise your disclosure in the
corresponding "Cayman Islands Taxation" section to state that the disclosure is the
opinion of Ogier, and have counsel delete the reference in the opinion to the disclosure
being a summary of tax consequences ("insofar as they purport to summarise the laws or
regulations of the Cayman Islands").
6.Please revise Section 1.2.1 of Exhibit 99.7 to exclude the PRC Companies. Please revise
your disclosure in the corresponding "People's Republic of China Enterprise Taxation"
section to state that the disclosure is the opinion of Beijing Jingsh Law firm Shenzhen
Office.
            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.
            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.

July 8, 2024
Page 3
            Please contact Patrick Kuhn at 202-551-3308 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Linda Ni

CORRESP
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June 18, 2024

Via Edgar

Mr. Brian Fetterolf

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

    Re:
    YSX
    Tech Co., Ltd

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

    Submitted
    February 26, 2024

    File
    No. 377-06871

Dear Mr. Fetterolf,

This letter is in response to the letter
dated March 18, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to YSX Tech Co., Ltd (the “Company”, “we”, or “our”). For ease of reference, we have recited
the Commission’s comment in this response. A registration statement on Form F-1 (the “Registration Statement”) is being
filed to accompany this letter.

Amendment
No. 3 to Draft Registration Statement on Form F-1 submitted February 26, 2024

Capitalization, page 54

1. Please revise to include the long-term loans that are presented on your September 30, 2023
balance sheet on your table of capitalization. Refer to Item 3.B of Form 20-F for guidance.

  Response:
In response to the Staff’s comments, we revised our disclosure on page 54 of the Registration Statement to include the long-term
loans that are presented on our September 30, 2023 balance sheet on the table of capitalization.

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

    Very truly yours,

    /s/ Jie Xiao

    Name:
    Jie Xiao

    Title:
    Chief Executive Officer

Cc: Ying Li, Esq.

Hunter Taubman Fischer & Li LLC

United States securities and exchange commission logo
March 18, 2024
Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
401, 4 / F, Building 12
1601 South Guangzhou Avenue
Haizhu District, Guangzhou, Guangdong, PRC
Re:YSX Tech Co., Ltd
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted February 26, 2023
File No. 377-06871
Dear Jie Xiao:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
January 16, 2024 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1 submitted February 26, 2023
Capitalization, page 54
1.Please revise to include the long-term loans that are presented on your September 30,
2023 balance sheet on your table of capitalization. Refer to Item 3.B of Form 20-F for
guidance.

 FirstName LastName Jie Xiao
 Comapany NameYSX Tech Co., Ltd
 March 18, 2024 Page 2
 FirstName LastName
 Jie Xiao
YSX Tech Co., Ltd
March 18, 2024
Page 2
            Please contact Patrick Kuhn at 202-551-3308 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Linda Ni

United States securities and exchange commission logo
January 16, 2024
Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
401, 4 / F, Building 12
1601 South Guangzhou Avenue
Haizhu District, Guangzhou, Guangdong, PRC
Re:YSX Tech Co., Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted December 22, 2023
File No. 377-06871
Dear Jie Xiao:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted December 22, 2023
Risk Factors, page 20
1.We note the changes you made to your disclosure in the first, second, third and fifth risk
factors of this section 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 November 17,
2023, warranting revised disclosure that mitigates 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. We remind you that, pursuant to federal securities rules, the term “control”

 FirstName LastName Jie Xiao
 Comapany NameYSX Tech Co., Ltd
 January 16, 2024 Page 2
 FirstName LastName
 Jie Xiao
YSX Tech Co., Ltd
January 16, 2024
Page 2
(including the terms “controlling,” “controlled by,” and “under common control with”) as
defined in Securities Act Rule 405 means “the possession, direct or indirect, of the power
to direct or cause the direction of the management and policies of a person, whether
through the ownership of voting securities, by contract, or otherwise.” 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 conveys the same risks. Please restore your
disclosures in these areas to the disclosures as they existed in the registration statement as
of November 17, 2023.
            Please contact Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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

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

United States securities and exchange commission logo
October 16, 2023
Jie Xiao
Chief Executive Officer
YSX Tech Co., Ltd
401, 4 / F, Building 12
1601 South Guangzhou Avenue
Haizhu District, Guangzhou, Guangdong, PRC
Re:YSX Tech Co., Ltd
Draft Registration Statement on Form F-1
Submitted September 15, 2023
File No. 377-06871
Dear Jie Xiao:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1 submitted September 15, 2023
Cover Page
1.We note your disclosure that "[f]ollowing the completion of this offering, our largest
shareholder will beneficially own approximately [·]% of the aggregate voting power of
our issued and outstanding Class A Ordinary Shares and Class B Ordinary Share . . . ."
Please revise to identify such shareholder, which appears to be Jie Xiao, and also disclose
that Jie Xiao will have the ability to control the outcome of matters submitted to
stockholders for approval, including the election of directors, amendments to your
organizational documents and any merger, consolidation, sale of all or substantially all of
your assets or other major corporate transactions, as you discuss in your risk factor on
page 40.  Additionally, here and in such risk factor, please disclose the specific percentage
of outstanding Class B Ordinary Shares that Jie Xiao of Class B Common Stock must
keep to continue to control such matters submitted to stockholders for approval, pursuant

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Page 2
to which holders of shares of Class A and Class B common stock would vote together as a
class.  Please also include comparable disclosure in your prospectus summary.
2.Where you disclose that "the PRC government adopted a series of regulatory actions and
issued statements to regulate business operations in China with little advance notice . . . ,"
please also address how recent statements and regulatory actions by China’s government,
such as those related to the use of variable interest entities and data security or anti-
monopoly concerns, have or may impact the company’s ability to conduct its business,
accept foreign investments, or list on a U.S. or other foreign exchange.
3.We note your disclosure that "no cash transfer or transfer of other assets have occurred
among YSX Cayman, its subsidiaries, or the VIEs."  Please also disclose that "our
Company has not made any dividends or distributions to our shareholders," as you
disclose on page 13.
4.We note your disclosure that "[f]or accounting purposes, we are the primary beneficiary of
the VIEs, as we control and receive the economic benefits of the VIEs through certain
contractual arrangements (the “VIE Agreements”), which enable us to consolidate the
financial results of the VIEs in our consolidated financial statements under generally
accepted accounting principles in the U.S."  Please revise to state that you are the primary
beneficiary and receive the economic benefits of the VIEs to the extent that you
consolidate the financials results of the VIEs in your consolidated statements under U.S.
GAAP.  Make conforming changes on page 39 where you disclose that "we are
considered the primary beneficiary, enabling us to consolidate our financial results in our
consolidated financial statements," and also make changes as applicable to your disclosure
on page 1 that the "WFOE has the power to direct the activities of the VIEs that can
significantly impact the VIEs’ economic performance and has the right to receive
substantially all of the economic benefits of the VIEs."  In this regard, we note that any
references to control or benefits that accrue to you because of the VIEs should be limited
to a clear description of the conditions you have satisfied for consolidation of the VIE
under U.S. GAAP.  Last, and in connection therewith, please revise your references to
"our VIE" on pages 71 and 75 to refer to the VIE, so as to refrain from implying that you
control the VIEs.
Prospectus Summary
Approvals from the PRC Authorities to Issue Our Class A Ordinary Shares to Foreign Investors,
page 12
5.We note yur statement that, "except for the aforementioned filing with the CSRC, we are
not required by any currently effective PRC laws or regulations to obtain approval,
permission, or clearance from any other PRC authorities to issue our securities to foreign
investors" (emphasis added).  Please also make such statement, if true, with respect to
your ability to offer the secuities being registered.
Approvals from the PRC Authorities to Conduct Our Operations, page 13

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YSX Tech Co., Ltd
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Page 3
6.We note your disclosure that "we and the PRC operating entities have received from the
PRC authorities all requisite licenses, permissions, or approvals that are required for
conducting our operations in China, such as business licenses and value added tax permits
for general taxpayers."  Please disclose the material permissions or approvals that you
have received.  Additionally, with respect to such permissions or approvals, clarify
whether you are relying on counsel, and if not, explain why. Also state whether you have
been denied any such approvals or permissions.
Dividends or Distributions Made to our Company and U.S. Investors and Tax Consequences,
page 13
7.Please include a cross-reference here to the "Selected Condensed Consolidated Financial
Schedule of YSX Cayman and Its Subsidiaries and the VIEs" sub-section, as well as the
consolidated financial statements included in this registration statement, as you do on the
cover page.
8.Pleast state here, as you do on the prospectus cover page, that you do not have "any cash
management policies that dictate how funds are transferred among our Company, the
subsidiaries, or the VIEs."
Implications of Our Being an "Emerging Growth Company", page 14
9.Your disclosure indicates that you do not intend to take advantage of the provision for
emerging growth companies that allows longer phase-in periods for the adoption of new
or revised accounting standards.  As such, please indicate by check mark on the cover
page of your registration statement your election not to use the extended transition period
for complying with any new or revised financial accounting standards provided pursuant
to Section 7(a)(2)(B) of the Securities Act.
Risk Factors
"The Chinese government exerts....", page 21
10.We note your disclosure that "recent statements by the Chinese government indicate an
intent to exert more oversight and control over offerings that are conducted overseas."
Please also state that such action 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.
"You may experience difficulties in effecting service of legal process, enforcing foreign
judgments, or bringing actions....", page 21
11.We note your disclosure that "all of our directors and officers are nationals or residents of
the PRC."  Please revise to identify the relevant individuals and also clarify whether this
applies to your director nominees.  Please make conforming changes in your section
entitled "Enforceability of Civil Liabilities" on page 48.

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YSX Tech Co., Ltd
October 16, 2023
Page 4
"Recent greater oversight by the CAC over data security, particularly for companies seeking to
list on a foreign exchange....", page 22
12.We note your disclosure that "[a]s of the date of this prospectus, we are of the view that
we are in compliance with the applicable PRC cybersecurity and data security laws and
regulations that have been issued by the CAC in all material respects . . . ."  The disclosure
here should not be qualified by materiality. Please make appropriate revisions to your
disclosure.
"The dual-class structure of our ordinary shares may adversely affect the trading market for our
Class A Ordinary Shares....", page 41
13.Here or as a new risk factor, please disclose that you may be excluded from certain stock
indices as a result of your disparate voting stock structure, and the resulting risks to
shareholders.
Disclosure Regarding Forward-Looking Statements
Industry Data and Forecasts, page 47
14.We note reference that this prospectus contains data related to the bakery industry in the
PRC and the U.S. Please advise.
Management Discussion and Analysis of Financial Condition and Results of Operations
Key Financial Performance Indicators, page 60
15.We note your disclosure that "[o]ur total revenue increased by approximately $19.1
million, or 63.3%, when comparing fiscal year 2023 to fiscal year 2022, primarily due to
the YSX Operating Companies obtained more service contracts from various insurance
companies and brokerages."  Please revise to provide a more robust discussion of the
reasons attributed to such revenue increase.  In this regard, while we note that you
attribute such increase to an increase in service contracts and that you derived the majority
of your revenue from vehicle maintenance related services increased in 2023, we also note
that the revenue generated from vehicle safety inspection and check services appears to
have materially declined from 2022 to 2023.
Business, page 81
16.We note your disclosure here and in your risk factors that, in fiscal year 2023, "three
customers each accounted for more than 10% of our total revenue, at 16.0%, 14.4% and
13.3%, respectively," and "three vendors each accounted for more than 10% of YSX
Operating Companies' total outsource expenses, at 17.6%, 16.7% and 13.4%,
respectively."  We also note your disclosure on page 33 that your business is subject to
"concentration risks arising from dependence on a few large customers" as well as
"concentration risk with regard to the vendors whom the YSX Operating Companies
subcontract to provide services to customers."  To the extent that you substantially depend

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 FirstName LastName
 Jie Xiao
YSX Tech Co., Ltd
October 16, 2023
Page 5
on such customers or vendors, please identify the applicable customers or venders (e.g.,
PICC and Ping An, as well as your related party customer Dayong) and file any associated
agreements as an exhibit to the registration statement.  Please also include a discussion of
the material terms of the agreements in the prospectus.  Refer to Item 8 of Form F-1 and
Item 601(b)(10)(ii)(B) of Regulation S-K.
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue recognition, page F-15
17.On pages 84 and 85, you disclose that the vendors under your auto insurance aftermarket
value-added services are responsible for any liabilities arising from the related service
renderings and some of these vendors were referred by insurance companies and
brokerages. Please tell us how you consider these factors in your determination that you
are principal in your transactions. Refer to ASC 606-10-55-36 through 40.
General
18.Please provide us with supplemental 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,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications. Please contact the staff member associated with the review of this filing
to discuss how to submit the materials, if any, to us for our review.
            Please contact Patrick Kuhn at 202-551-3308 or Suying Li at 202-551-3335 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brian Fetterolf at 202-551-6613 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services