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                                                            February 4, 2025

Xiaobo Shao
Chief Financial Officer
TCTM Kids IT Education Inc.
6/F, No. 1 Andingmenwai Street, Litchi Tower
Chaoyang District , Beijing 100011
People's Republic of China

       Re: TCTM Kids IT Education Inc.
           Annual Report on Form 20-F for Fiscal Year Ended December 31, 2023
           Response dated September 30, 2024
           File No. 001-36363
Dear Xiaobo Shao:

        We have reviewed your September 30, 2024 response to our comment letter
and have
the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
September 19, 2024 letter.

Annual Report on Form 20-F for Fiscal Year Ended December 31, 2023
Item 3. Key Information, page 3

1.     We note your response to prior comment 3. Please further revise your
statement
       regarding the availability of cash or assets in your business here and
in the summary
       risk factors, risk factors, and Operating and Financial Review and
Prospects sections
       to reflect that to the extent cash or assets in the business is in the
PRC or Hong Kong
       or a PRC or Hong Kong entity, the funds or assets may not be available
to fund
       operations or for other use outside of the PRC or Hong Kong due to
interventions in
       or the imposition of restrictions and limitations on the ability of you,
your
       subsidiaries, or the consolidated VIEs by the PRC government to transfer
cash or
       assets. In this regard, we note that you have a Hong Kong intermediate
holding
       company in your organizational structure.
 February 4, 2025
Page 2

2.     We note your response to prior comment 5 and reissue in part.
Acknowledge in the
       summary risk factors 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.
       Please contact Tony Watson at 202-551-3318 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rebekah Reed at 202-551-5332 or Taylor Beech at 202-551-4515 with any
other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services
cc:   Haiping Li
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