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                             May 25, 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. 3 to
Registration Statement on Form F-1
                                                            Filed May 19, 2023
                                                            File No. 333-270434

       Dear Wanjun Yao:

              We have reviewed your amended registration statement and have the
following
       comment. In our comment, 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 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 comment, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
4, 2023 letter.

       Amendment No. 3 to Registration Statement on Form F-1

       Consolidated Statements of Cash Flows, page F-7

   1.                                                   We note your response
to prior comment 1. Please clarify why you considered the
                                                        settlement of the
related party loan receivables that were presented as a reduction of
                                                        shareholders    equity
pursuant to SAB Topic 4:G for the year ended December 31, 2021 as
                                                        an investing activity.
We also note that the Financing activities include distributions to
                                                        owners, obtaining
resources from owners as well as borrowing money and repaying
                                                        amounts borrowed, or
otherwise settling the obligation. Refer to ASC 230-10-45-
                                                        15 and ASC 230-10-20.
 Wanjun Yao
Tungray Technologies Inc.
May 25, 2023
Page 2

       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,
FirstName LastNameWanjun Yao
                                                          Division of
Corporation Finance
Comapany NameTungray Technologies Inc.
                                                          Office of Technology
May 25, 2023 Page 2
cc:       Anna Jinhua Wang
FirstName LastName