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                             October 21, 2022

       Yanlai Shi
       Chief Executive Officer
       RYB Education, Inc.
       4/F, No. 29 Building, Fangguyuan Section 1, Fangzhuang
       Fengtai District, Beijing 100078
       People   s Republic of China

                                                        Re: RYB Education, Inc.
                                                            Form 20-F for
Fiscal Year Ended December 31, 2021
                                                            Response Dated
August 23, 2022
                                                            File No. 001-38203

       Dear Yanlai Shi:

              We have reviewed your August 23, 2022 response to our comment
letter 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in
       our July 26, 2022 letter.

       Response Dated August 23, 2022

       Item 3. Key Information, page 3

   1.                                                   We note your response
to comment 7 and re-issue in part. We note your proposed cross-
                                                        references to specific
risks, however, please include both the risk factor title and the
                                                        relevant page number,
not just the risk factor title.
   2.                                                   We note your response
to comment 8 and re-issue in part. While you propose to disclose
                                                        that you have relied on
an opinion of counsel to conclude that you have the necessary
                                                        approvals and
permissions to operate your business, please also include the name of your
                                                        mainland China counsel.
In addition, while we note the proposed additional disclosure in
                                                        the risk factor titled
"Our business generates and processes a large amount of data, and
 Yanlai Shi
RYB Education, Inc.
October 21, 2022
Page 2
      we are required to comply with PRC and other applicable laws relating to
privacy and
      cybersecurity. The improper use or disclosure of data could have a
material and adverse
      effect on our business and prospects" in response to comment 8, it does
not appear that
      this risk factor is cross-referenced, or the proposed additional
disclosure included, in your
      proposed revised disclosure to be added to the introduction of Item 3.
Please revise the
      proposed additional disclosure to be added to Item 3 to explain the basis
for your
      conclusions why you are not required to have a cybersecurity review by
the China
      Securities Regulatory Commission or the Cyberspace Administration of
China.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact James Giugliano at 202-551-3319 or Suying Li at
202-551-3335 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680
with any other
questions.



                                                             Sincerely,
FirstName LastNameYanlai Shi
                                                             Division of
Corporation Finance
Comapany NameRYB Education, Inc.
                                                             Office of Trade &
Services
October 21, 2022 Page 2
cc:       Yuting Wu
FirstName LastName