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                              August 22, 2023

       Zexiong Huang
       Chief Executive Officer
       Pintec Technology Holdings Ltd
       3rd Floor, No. 11 Building
       No. 109 Yard Tianjizhigu
       Jinghai 3rd Street, BDA, Beijing, 101111
       People   s Republic of China

                                                        Re: Pintec Technology
Holdings Ltd
                                                            Form 20-F for the
Year Ended December 31, 2022
                                                            Filed May 15, 2023
                                                            File No. 001-38712

       Dear Zexiong Huang:

              We have reviewed your August 11, 2023 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 28, 2023 letter.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 4. Information on the Company
       A. History and Development of the Company, page 69

   1.                                                   Please explain further
the following as it relates to the information provided in response to
                                                        prior comment 2. Also,
revise the proposed disclosures that you previously provided
                                                        in comment 4 to your
July 14, 2023 response letter to address the bullet points below and
                                                        include your newly
revised disclosures in either an amendment to your December 31,
                                                        2022 Form 20-F or a
Form 6-K filing:
                                                            Revise to clarify
that Mr. Dong   s detention was solely related to business disputes of
                                                             a separate private
company and the nature of such matter as indicated in the first
 Zexiong Huang
Pintec Technology Holdings Ltd
August 22, 2023
Page 2
           bullet point of your response.
             Revise to clarify when Mr. Dong   s detainment began and ended as
indicated in the
           second bullet point of your response, and clearly state whether Mr.
Dong was charged
           or indicted with any wrongdoing.
             Explain to us, and revise to clarify, why Mr. Xianofeng Cui voted
on certain matters
           on behalf of Mr. Dong in December 2022 when it appears he was
released from
           detainment in November 2022.
             You state in the third bullet point that Mr. Dong did not address
any other matters in
           his absences except for the aforementioned matters. Explain what
aforementioned
           matters you are referring to as it appears Mr. Cui addressed those
matters. Also, if
           no other matters were addressed, then revise your proposed
disclosures where you
           state    Mr. Jun Dong also fulfilled his duty as the Chairman of the
Board on other
           matters    or explain.
Note 2. Summary of significant accounting policies
(s) Revenue recognition
Technical service fees, page F-20

2.    We note your response to prior comment 3. Please further revise your
proposed
      disclosures as provided in comment 7 of your July 14, 2023 letter to
expand upon the
      terms of your technical service fee arrangements with financial partners.
In this regard,
      clarify that the output method used to measure progress toward completion
is the dollar
      volume of loans referred to your financial partner and collections of
loan principal and
      interest from customers on behalf of such financial partner each month,
and that the
      transaction price is determined based on a percentage of such loan
referrals and
      collections. Refer to ASC 606-10-50-18(a) and 50-20(a).
       You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.



                                                            Sincerely,
FirstName LastNameZexiong Huang
                                                            Division of
Corporation Finance
Comapany NamePintec Technology Holdings Ltd
                                                            Office of
Technology
August 22, 2023 Page 2
cc:       Yang Ge
FirstName LastName