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                            April 10, 2023

       Wanjun Yao
       Chief Executive Officer
       Tungray Technologies Inc.
       #02-01, 31 Mandai Estate,
       Innovation Place Tower 4,
       Singapore 729933

                                                        Re: Tungray
Technologies Inc.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed March 30,
2023
                                                            File No. 333-270434

       Dear Wanjun Yao:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
20. 2023 letter.

       Amendment No. 1 to Registration Statement on Form F-1

       Consolidated Financial Statements, page F-1

   1.                                                   Please update your
financial statements and corresponding financial information
                                                        throughout the filing
to comply with Item 8.A.4 of Form 20-F.
 Wanjun Yao
FirstName   LastNameWanjun
Tungray Technologies   Inc. Yao
Comapany
April       NameTungray Technologies Inc.
       10, 2023
April 210, 2023 Page 2
Page
FirstName LastName
Item 8. Exhibits and Financial Statement Schedules.
23.1 Consent of Friedman LLP, an independent registered public accounting firm,
page II-3

2.       We note Freidman's report is dated December 16, 2022 while in their
consent they said
         they were dismissed as auditors on December 06, 2022. Please have
Freidman LLP
         correct this date or have them tell us if they engaged in audit work
after the date of their
         dismissal.
General

3.       We note your response to prior comment 1 regarding recently published
Trial Measures
         by the CSCR in China. Please disclose whether you have submitted an
application for
         approval with the CSRC.
       You may contact Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have
questions regarding
comments on the financial statements and related matters. Please contact Kyle
Wiley, Staff
Attorney, at (202) 344-5791 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Technology
cc:      Anna Jinhua Wang