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                              April 11, 2024

       Liu Jia
       Chief Financial Officer
       Recon Technology, Ltd
       Room 601, No. 1 Shui   an South Street
       Chaoyang District, Beijing 100012
       People   s Republic of China

                                                        Re: Recon Technology,
Ltd
                                                            Form 20-F for the
Fiscal Year ended June 30, 2023
                                                            Filed October 30,
2023
                                                            Response dated
March 22, 2024
                                                            File No. 001-34409

       Dear Liu Jia:

              We have reviewed your March 22, 2024 response to our comment
letter and have the
       following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our February 28, 2024
       letter.

       Form 20-F for the Fiscal Year Ended June 30, 2023

       Item 16C. Principal Accountant Fees and Services, page 101

   1.                                                   We have read your
response to prior comment 3, which includes various revisions to the
                                                        amounts previously
reported as audit and audit-related fees, and a description of the audit-
                                                        related fees indicating
these were paid to your auditors for reviews of your interim
                                                        financial information
and documents filed with the SEC. However, you have not provided
                                                        an explanation for the
numerical changes and the audit-related fees that you describe
                                                        would ordinarily need
to be reported in the category for audit fees.
 Liu Jia
FirstName   LastNameLiu
Recon Technology,   Ltd Jia
Comapany
April       NameRecon Technology, Ltd
       11, 2024
April 211, 2024 Page 2
Page
FirstName LastName
         We encourage you to read the guidance on categorization of fees that
resides in the
         seventh and eight paragraphs of Section II.H of SEC Release 33-8183,
issued January 28,
         2003. The following is a brief summary of that guidance.

                Audit Fees - fees for services normally provided in connection
with statutory and
              regulatory filings or engagements, including services necessary
to perform an audit or
              review in accordance with GAAS, and services that generally only
the independent
              accountant reasonably can provide, such as comfort letters,
statutory audits, attest
              services, consents and assistance with and review of documents
filed with the SEC.

                Audit Related Fees - fees for assurance and related services
traditionally performed
              by the independent accountant, such as employee benefit plan
audits, due diligence
              related to mergers and acquisitions, accounting consultations and
audits in connection
              with acquisitions, internal control reviews, attest services not
required by statue or
              regulation, and consultations on financial accounting and
reporting standards.

         Please revisit and revise your classification of fees consistent with
the guidance above and
         provide us with a description of the composition of the audit fees,
for each firm and
         period, as to the amounts pertaining to the annual audit, and
separately for interim
         reviews, specifying the particular interim periods, and other
services.

         Given your disclosures indicating you paid Friedman $285,000 for audit
and audit-related
         services pertaining to your 2022 fiscal year, and paid Friedman,
Marcum Asia, and
         Enrome combined, $450,000 for similar work pertaining to your 2023
fiscal year, tell us
         how your rationale of being concerned about costs, for the decision to
change auditors in
         the midst of the audit, reconciles with the approximate 58% increase
in fees. If there were
         incremental reasons for your decision to change auditors in the midst
of the audit, please
         include details of those circumstances along with your reply.

         As you indicate the fees paid to Marcum Asia were contractual and
based on the extent of
         audit progress until dismissal, please further clarify whether the
fees for the audit planning
         and three weeks of field work were based on rates and hours, a
percentage applied to
         a total contractual cost, or other factors. Tell us your expectation
for the total cost of the
         Marcum Asia audit, had the firm not been dismissed, based on the
engagement letter.
Item 19 Exhibits
Exhibit 15.1, page 106

2.       We note that in response to prior comment 6 you provided draft
consents from both
         Friedman and Enrome to be filed as exhibits to an amended Form 20-F.
However, while
         the draft consent from Friedman appears to generally conform to your
circumstances, the
         draft consent from Enrome states that the firm consents to the use of
its audit report dated
         October 27, 2023 by incorporation by reference "in this Registration
Statement on Form
         20-F" and consents to be named as experts in the same Registration
Statement.
 Liu Jia
Recon Technology, Ltd
April 11, 2024
Page 3
         We understand that your intention is to update with more current
financial information
         (using incorporation-by-reference) your previously filed Registration
Statement on Form
         F-1 (File No. 333-271547), rather than a registration statement on
Form 20-F, to include
         the consolidated financial statements that will be filed in your
Amendment No. 2 to Form
         20-F for the fiscal year ended June 30, 2023, accompanied by the
October 27, 2023 audit
         report from Enrome (and the October 28, 2022 audit report from
Friedman).

         Please coordinate with Enrome to obtain a consent that is consistent
with the requirements
         of your registration statement on Form F-1, and with regard to the
firms audit opinion that
         will be included in Amendment No. 2 to your Form 20-F, which you will
be filing soon.
       Please contact Yong Kim at 202-551-3323 or Jenifer Gallagher at
202-551-3706 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameLiu Jia                                     Sincerely,
Comapany NameRecon Technology, Ltd
                                                              Division of
Corporation Finance
April 11, 2024 Page 3                                         Office of Energy
& Transportation
FirstName LastName