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                          November 19, 2021

       Liu Jia
       Chief Financial Officer
       Recon Technology, Ltd
       Room 601, 1 Shui   an South Street
       Chaoyang District, Beijing, 100012
       People   s Republic of China

                                                        Re: Recon Technology,
Ltd
                                                            Amendment No. 1 to
Registration Statement on Form F-3
                                                            Filed October 1,
2021
                                                            File No. 333-257806

       Dear Ms. Jia:

             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
August 23, 2021 letter.

       Amendment No. 1 to Registration Statement on Form F-3 filed October 1,
2021

       Cover Page

   1.                                                   We note your response
to prior comment 3 and reissue in part. You defined    VIEs    here
                                                        to include your PRC
variable interest entities "Nanjing Recon Technology Co., Beijing
                                                        BHD Petroleum
Technology Co., and Future Gas Station (Beijing) Technology, Ltd., or
                                                        'Nanjing Recon,' 'BHD,'
and 'FGS,' respectively." However, you also state that
                                                        "[You] mainly conduct
[y]our business through [y]our VIEs, Nanjing Recon, BHD and
                                                        their respective
subsidiaries by means of Contractual Arrangements." Please revise to
                                                        clarify your
disclosure. Also revise to refrain from using terms such as    our    when
                                                        describing activities
or functions of a VIE.
 Liu Jia
FirstName LastNameLiu
Recon Technology,  Ltd Jia
Comapany 19,
November  NameRecon
              2021    Technology, Ltd
November
Page  2   19, 2021 Page 2
FirstName LastName
2.       We note your disclosure here and throughout your filing that you
control and receive
         economic benefits of Recon Technology's business operations through
the Contractual
         Arrangements. We also note the disclosure on page 5 that you are the
primary beneficiary
         of the VIEs. However, you or your investors do not have an equity
ownership in, direct
         foreign investment in, or control through such ownership/investment of
the VIEs. As
         such, when describing the design of the VIE agreements and related
outcome, please
         refrain from implying that the VIE agreement is equivalent to an
equity ownership in the
         business of the VIE. Any references to control or benefits that accrue
to you because of
         the VIE should be limited to and clearly describe the conditions you
met for consolidation
         of the VIE under U.S. GAAP and your disclosure should clarify that,
for accounting
         purposes, you will be the primary beneficiary. In addition, your
disclosure should note, if
         true, that the agreements have not been tested in a court of law.
3.       We note your disclosure that the VIE structure is used to replicate
foreign investment in
         China-based companies. We note, however, that the structure provides
contractual
         exposure to foreign investment in such companies rather than
replicating an investment.
         Please revise accordingly.
Prospectus Summary, page 4

4.       We note your response to prior comment 4 and reissue it in part. In
your prospectus
         summary, identify clearly the entity in which investors are purchasing
their interest. Also
         revise the disclosure on page 4 to clarify that you are not a Chinese
operating company
         but a Cayman Islands holding company with operations conducted by your
subsidiaries
         and through contractual arrangements.
5.       We note your response to prior comment 5 and reissue it in part. In
your risk factor
         summary, disclose the risk that the Chinese government may intervene
or influence your
         operations at any time.
6.       We note your response to prior comment 6. Please expand to disclose
the consequences
         to you and your investors if you do not receive or maintain the
approvals, inadvertently
         conclude that such approvals are not required, or applicable laws,
regulations, or
         interpretations change and you are required to obtain approval in the
future.
7.       We note your response to prior comment 7 and reissue it in part. In
your prospectus
         summary, describe any restrictions on foreign exchange and your
ability to transfer cash
         between entities, across borders, and to U.S. investors. Describe any
restrictions and
         limitations on your ability to distribute earnings from your
businesses, including
         subsidiaries and/or consolidated VIEs, to the parent company and U.S.
investors as well as
         the ability to settle amounts owed under the VIE agreements.
8.       We note that you have added various tabulations of consolidating
information on pages
         7 and 8 in response to prior comment 8. However, it is unclear how you
have segregated
         account balances and activity to distinctly report amounts pertaining
to the parent, non-
         VIE subsidiaries, and VIE subsidiaries; and it is unclear how amounts
depicted as
 Liu Jia
Recon Technology, Ltd
November 19, 2021
Page 3
         eliminations would represent the consolidating adjustments. Please
revise as necessary to
         limit the amounts reported in each column to the balances and activity
that pertain to the
         legal entities that are grouped within each column, prior to
consolidation, and to include
         line item details that are consistent with those utilized in preparing
your financial
         statements. Please also reconcile or address any inconsistencies with
the VIE information
         disclosed in Note 28 on page F-30 of your Form 20-F for the fiscal
year ended June 30,
         2020, and expand your accompanying narratives to describe the nature
of any assets,
         operations and cash flows that exist or which occur outside of the
VIEs.
9.       We note your new disclosures related to your contractual arrangements.
Please revise to
         include the dates of such material agreements and file or incorporate
by reference these
         agreements with your registration statement.
10.      We note your response to prior comment 9 and reissue in part. Revise
the disclosure on
         page 7 and elsewhere to also disclose that trading in your securities
may be prohibited
         under the Holding Foreign Companies Accountable Act if the PCAOB
determines that it
         cannot inspect or fully investigate your auditor, and that as a result
an exchange may
         determine to delist your securities.
Risks Related to Doing Business in China
Our shares may be delisted under the Holding Foreign Companies Accountable Act
if the
PCAOB is unable to inspect, page 13

11.      We note from the audit opinion and your risk factor that you have a
U.S. based auditor
         that is registered with the PCAOB and currently subject to PCAOB
inspection. Please
         disclose any material risks to the company and investors if it is
later determined that the
         PCAOB is unable to inspect or investigate completely your auditor
because of a position
         taken by an authority in a foreign jurisdiction. For example, disclose
the risk that lack of
         inspection could cause trading in your securities to be prohibited
under the Holding
         Foreign Companies Accountable Act and as a result an exchange may
determine to delist
         your securities.
12.      Please expand your risk factor disclosure to discuss that the United
States Senate passed
         the Accelerating Holding Foreign Companies Accountable Act, which, if
enacted, would
         decrease the number of non-inspection years from three years to two,
thus reducing the
         time period before your securities may be prohibited from trading or
delisted.
Information  Incorporated Jia
FirstName LastNameLiu      by Reference, page 20
Comapany
13.         NameRecon
       Please  update theTechnology,  Ltdthis section to include your annual
report on Form 20-F
                          information in
       for the
November    19,fiscal
                2021 year
                      Pageended
                           3    June 30, 2021 and any other subsequent filings.
FirstName LastName
 Liu Jia
FirstName LastNameLiu
Recon Technology,  Ltd Jia
Comapany 19,
November  NameRecon
              2021    Technology, Ltd
November
Page  4   19, 2021 Page 4
FirstName LastName
      You may contact Liz Packebusch, Staff Attorney, at (202) 551-8749 or Loan
Lauren
Nguyen, Legal Branch Chief, at (202) 551-3642 with any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Energy &
Transportation
cc:      Anthony W. Basch