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                                                            February 14, 2025

Yin Shenping
Chief Executive Officer
Recon Technology, Ltd
Room 601, No. 1 Shui   an South Street
Chaoyang District , Beijing 100012
People   s Republic of China

       Re: Recon Technology, Ltd
           Form 20-F for the Fiscal Year ended June 30, 2024
           Filed October 30, 2024
           File No. 001-34409
Dear Yin Shenping:

       We have reviewed your filing and have the following comment.

       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.

Form 20-F for the Fiscal Year ended June 30, 2024
Note 6 - Loans to Third Parties, page F-23

1.     We understand from your disclosure that your loans to third parties are
mainly used
       for short-term funding to support your external business partners, and
bear interest
       ranging from 6 to 15.6 percent. We note that you had 209 million RMB of
loans to
       third parties as of June 30, 2024, which appears to have required a
material
       deployment of capital, and we see that you had 23 million RMB of
interest income
       during 2024, which had a material impact on your statement of
operations.

       Please address the following points.

             Identify and describe your relationships with such external
business partners, to
           include clarifying whether these are suppliers, customers, or serve
in some other
           capacity, explain your reasons for providing the funding, and
clarify the extent to
           which the balance relates to each category of partners.
 February 14, 2025
Page 2


             With regard to any short-term funding provided to customers,
please explain to
           us how this arrangement has been considered in evaluating the
recoverability of
           accounts receivable and estimating the allowance for doubtful
accounts.


        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 Robert Babula at 202-551-3339 or John Cannarella at
202-551-3337 if
you have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Energy &
Transportation
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