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                             May 10, 2023

       Mingfei Liu
       Chief Operating Officer
       U-BX Technology Ltd.
       Zhongguan Science and Technology Park
       No. 1 Linkong Er Road, Shunyi District, Beijing
       People   s Republic of China

                                                        Re: U-BX Technology
Ltd.
                                                            Amendment No. 12 to
Registration Statement on Form F-1
                                                            Filed April 26,
2023
                                                            File No. 333-262412

       Dear Mingfei Liu:

             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 April
14, 2023 letter.

       Amendment No. 12 to Registration Statement on Form F-1 Filed April 26,
2023

       General

   1.                                                   We note your response
to prior comment 1 and reissue our comment in part. You disclose
                                                        on your cover page and
elsewhere in your prospectus that "as of the date of this
                                                        prospectus, we have not
submitted our recording materials to the CSRC." Please further
                                                        revise to state whether
you and the relevant parties to this transaction have complied with
                                                        your obligations under
the Trial Measures.
 Mingfei Liu
FirstName  LastNameMingfei Liu
U-BX Technology  Ltd.
Comapany
May        NameU-BX Technology Ltd.
     10, 2023
May 10,
Page 2 2023 Page 2
FirstName LastName
2.       We note your response to prior comment 1 and your revised disclosure
stating that you
         must submit a "filing application with the CSRC" and "shall complete
the filing with the
         CSRC in accordance with the Trial Measures before this offering." Your
revised
         disclosure on pages 17 and 110 and prior disclosures on page 16 state
that "[w]e believe
         the CSRC   s approval is not required for the offering and trading of
our ordinary shares"
         and "[a]s of the date of this prospectus, no relevant laws or
regulations in the PRC
         explicitly require us to seek approval from the CSRC or any other PRC
governmental
         authorities for this offering." Please revise to clarify these
statements in light of your
         disclosure describing your obligation to submit and complete the
filing application
         requirement set forth in the Trial Measures or advise.
3.       You state on page 17 of your registration statement that "[a]s of the
date of this
         prospectus, the Draft Rules Regarding Overseas Listings have not been
promulgated, and
         we are not required to obtain permission or approval from the
government of China for
         any offering pursuant to this prospectus." On page 38 you explain that
the Draft Rules
         Regarding Overseas Listings "stipulate that the Chinese-based
companies, or the issuer,
         shall fulfill the filing procedures within three working days after
the issuer makes an
         application for initial public offering and listing in an overseas
market." Throughout your
         registration statement, please revise your discussions of the "Draft
Rules" to the extent
         that these rules have been superseded or replaced by the "Trial
Measures."
Exhibits

4.       Please obtain and file a revised legal opinion that clearly opines on
the legality of the
         shares of common stock underlying the underwriters' warrants, which
are being included
         in your registration statement. Refer to Section II.B.1.f of Staff
Legal Bulletin No. 19.
       You may contact Morgan Youngwood, Senior Staff Accountant, at (202)
551-3479 or
Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Patrick Faller, Staff
Attorney, at (202) 551-4438 or Matthew Crispino, Staff Attorney, at (202)
551-3456 with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      William S. Rosenstadt