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                              June 10, 2020

       Nan Shen
       Chief Financial Officer
       GSX Techedu Inc.
       2/F, Boyan Tech Building
       No. 10 East Xibeiwang Road
       Haidian District Beijing

                                                        Re: GSX Techedu Inc.
                                                            Form 20-F for
Fiscal Year Ended December 31, 2019
                                                            Filed April 3, 2020
                                                            File No. 1-38923

       Dear Mr. Shen:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for Fiscal Year Ended December 31, 2019

       Operating and Financial Review and Prospects
       Year ended December 31, 2019 compared to year ended December 31, 2018
       Revenues, page 72

   1.                                                   Given the significance
of the quarter to quarter and year to year increases in net revenues,
                                                        please expand on your
explanation of the increase in net revenues from period to period.
                                                        For example, we note
that net revenues from your K-12 courses increased RMB1,415.6
                                                        million in 2019
compared to 2018. Please disclose the dollar amount of that increase
                                                        attributable to higher
tuition fees versus growth in enrollments. In addition, please
                                                        elaborate on the
factors contributing to the significant volume/enrollment increases. For
                                                        example you might
discuss first time versus recurring customer enrollments or successful
                                                        marketing efforts in a
particular region. Or you might discuss the number of courses
                                                        offered in one period
versus the other and changes in average enrollment per course
 Nan Shen
GSX Techedu Inc.
June 10, 2020
Page 2
         including the reasons for those changes.
Consolidated Financial Statements
Consolidated Statements of Comprehensive (Loss) Income , page F-6

2.       Please explain to us why no income tax expense or benefit is allocated
to unrealized gains
         on available-for-sale investments, including reclassification
adjustments. Please refer to
         ASC 740-10-50-10 and ASC 220-10-45-12.
       In closing, 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.

       You may contact Robyn Manuel at 202-551-3823 or Bill Thompson at
202-551-3344
with any questions.



FirstName LastNameNan Shen                                    Sincerely,
Comapany NameGSX Techedu Inc.
                                                              Division of
Corporation Finance
June 10, 2020 Page 2                                          Office of Trade &
Services
FirstName LastName