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                     January 29, 2024

       Jian Zhang
       Chief Executive Officer
       Distoken Acquisition Corp
       Unit 1006, Block C, Jinshangjun Park
       No. 2 Xiaoba Road, Panlong District
       Kunming, Yunnan, China

                                                        Re: Distoken
Acquisition Corp
                                                            Form 10-K for the
year ended December 31, 2022
                                                            File No. 001-41622

       Dear Jian Zhang:

               We issued comments to you on the above captioned filing on
December 20, 2023. As of
       the date of this letter, these comments remain outstanding and
unresolved. We expect you to
       provide a complete, substantive response to these comments by February
12, 2024.

               If you do not respond, we will, consistent with our obligations
under the federal securities
       laws, decide how we will seek to resolve material outstanding comments
and complete our
       review of your filing and your disclosure. Among other things, we may
decide to release
       publicly, through the agency's EDGAR system, all correspondence,
including this letter, relating
       to the review of your filings, consistent with the staff's decision to
publicly release comment and
       response letters relating to disclosure filings it has reviewed.

              Please contact Paul Cline at 202-551-3851 or Jennifer Monick at
202-551-3295 with any
       questions.




                     Sincerely,


                     Division of Corporation Finance

                     Office of Real Estate & Construction