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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.
 Shaozhang Lin
FirstName LastNameShaozhang   Lin
Youxin Technology  Ltd
Comapany14,
December  NameYouxin
              2023      Technology Ltd
December
Page 2    14, 2023 Page 2
FirstName LastName
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
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