August 5, 2024

Pun Leung Liu
Chief Financial Officer
YXT.COM Group Holding Limited
Floor 20, Building 2, No. 209, Zhuyuan Road
High-tech District, Suzhou,
Jiangsu, 215011, People   s Republic of China

       Re: YXT.COM Group Holding Limited
           Amendment No. 1 to Registration Statement on Form F-1
           Filed August 1, 2024
           File No. 333-280772
Dear Pun Leung Liu:

     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 July 29, 2024 letter.

Amendment No. 1 to Form F-1 filed August 1, 2024
Capitalization, page 91

1.     Please revise to remove the derivative liability from your calculation
of total
       capitalization, as this total should only reflect total indebtedness
plus equity. We refer you
       to prior comment 1 and the guidance in Item 3B of Form 20-F.
2.     Please tell us and revise to disclose how you determined the total
anti-dilution shares to be
       issued of 12,164,745 and the related price per share at which they will
be issued.
3.     We note the pro forma adjustment related to anti-dilution provision of
RMB86.8 million
       shown on pages 23 and 104. It appears this amount is reflected as an
increase in additional
       paid-in-capital in your pro forma as adjusted column here. Please tell
us where the
       offsetting amount is reflected or otherwise revise accordingly.
 August 5, 2024
Page 2

Dilution, page 94

4.     Please revise to disclose, either in a separate line item or a footnote
to the table on page
       95, the number of shares to be issued to existing shareholders related
to the anti-dilution
       provision, and the related average price per ordinary share and average
price per ADS.
       Please contact Brittany Ebbertt at 202-551-3572 or Chris Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Lauren Pierce at 202-551-3887 or Jan Woo at 202-551-3453 with any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:   Li He