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                             April 3, 2023

       Houqi Zhang
       Chief Executive Officer
       Autozi Internet Technology (Global) Ltd.
       Block A, Building No. 16
       Yonyou Software Park, No. 68 Beiqing Road
       Haidian District, Beijing, China

                                                        Re: Autozi Internet
Technology (Global) Ltd.
                                                            Amendment No.1 to
Draft Registration Statement on Form F-1
                                                            Submitted March 17,
2023
                                                            CIK No. 0001959726

       Dear Houqi Zhang:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1

       Cover page

   1.                                                   We note your response
to comment 3. Please revise to also discuss cash transfer
                                                        limitations applicable
to Hong Kong, given your Hong Kong subsidiary. Please make
                                                        consistent revisions in
your prospectus summary and throughout the prospectus.
   2.                                                   We note your response
to comment 5. Please revise to state the source of the cash
                                                        management policies you
describe, for example whether they are contractual in nature,
                                                        pursuant to
regulations, internal written policies established by the board, etc.
   3.                                                   We note your disclosure
here and throughout the prospectus that your auditor is subject to
 Houqi Zhang
Autozi Internet Technology (Global) Ltd.
April 3, 2023
Page 2
         inspection "at least every three years." Please tell us why that is
the case given the
         amendments made to the HFCAA, or revise to reflect that your auditor
is subject to
         inspection at last every two years.
Prospectus Summary, page 1

4.       We note your response to comment 12 and reissue. Please revise your
summary section to
         disclose each permission or approval that you and your subsidiaries
are required to obtain
         from Chinese authorities to operate your business and to offer the
securities being
         registered to foreign investors. State whether you or your
subsidiaries are covered by
         permissions requirements from CSRC, CAC or other governmental agencies
and the basis
         for your conclusions. If you did not use counsel in making such
determinations, please
         state why. State affirmatively whether you have received all requisite
permissions or
         approvals and whether any permissions or approvals have been denied.
Please also
         describe the consequences to you and your investors if you or your
subsidiaries: (i) do not
         receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such
         permissions or approvals are not required, or (iii) applicable laws,
regulations, or
         interpretations change and you are required to obtain such permissions
or approvals in the
         future. Please also revise to make conforming changes in your risk
factor disclosure, as
         applicable.
Recent Regulatory Developments
CSRC Filing Requirements for Overseas Listing, page 4

5.       We note your response to comment 8. Please revise your disclosure here
and throughout
         the prospectus where you discuss the Trial Measures to state whether
you believe you are
         required to comply with the Trial Measures and the basis for this
determination. If you did
         not use counsel to make this determination, please state why.
Additionally, expand your
         disclosure to discuss the risks to investors if there is a chance that
the company lists before
         receiving CSRC approval, and whether your offering is contingent upon
receipt of
         approval from the CSRC.
Conventions that Apply to this Prospectus, page 11

6.     We note your response to comment 4. Please revise to clarify your
definitions of "PRC
       subsidiaries" and "operating subsidiaries" by disclosing under which
category each of
       your subsidiaries fit. In this regard, we note your disclosure on the
cover page that you
       conduct your business through Autozi Internet Technology Co., Ltd., an
indirect
       substantially owned subsidiary of the Company, and 12 first-level
operating subsidiaries
FirstName LastNameHouqi Zhang
       owned by Autozi Internet Technology Co., Ltd, and that all of these 13
operating
Comapany     NameAutozi
       subsidiaries       Internet Technology
                    are established              (Global)
                                      under the laws of theLtd.
                                                            PRC. Please also
include definitions of
April 3,"the
         2023Group,"
               Page 2"our Company" and "Hong Kong subsidiaries."
FirstName LastName
 Houqi Zhang
FirstName   LastNameHouqi   Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
April       NameAutozi Internet Technology (Global) Ltd.
       3, 2023
April 33, 2023 Page 3
Page
FirstName LastName
Failure to obtain, renew, or retain licenses, permits or approvals may affect
our ability to conduct
or expand our business..., page 32

7.       Please revise this risk factor to clarify whether you believe you are
required to obtain each
         permission and approval discussed, and to state the basis upon which
you made
         such determination for each permission and approval discussed. Revise
to clarify the
         meaning of the following sentence: "In addition to complying with
applicable laws and
         regulations, including requirements of the CAC and any other Chinese
authorities, which
         remains uncertain as to whether we are required to obtain any such
consent." We note
         your statement that "other than those requisite for a domestic company
in China to engage
         in the businesses similar to ours and as disclosed in this prospectus,
[you] are not required
         to obtain any additional permission from Chinese governmental
authorities...to approve
         [y]our current business operations in China"; please revise to clarify
which permissions
         and approvals are requisite for you to operate your business in China.
Also expand this or
         another risk factor, as appropriate, to disclose each permission and
approval you are
         required to obtain to offer your securities to foreign investors, and
to state whether you
         have obtained all such required permissions/approvals.
Risk Factor
The approval of and the filing with the CSRC or other Chinese government
authorities may be
required, page 55

8.       Please revise to state the basis for your determinations regarding
whether or not you
         are required to obtain each of the permissions and approvals discussed
in this risk factor.
         Revise to explain why the 2021 Negative List, which has been in effect
for over a year, is
         "relatively new" and you are, therefore, unable to ascertain whether
you "will be subject to
         these new requirements."
We are subject to a variety of laws and regulations regarding cybersecurity and
data protection...,
page 57

9.       We note your response to comment 14. Please revise your disclosure on
page 57 to clarify
         whether you relied on the opinion of counsel for your reasoning about
why you believe
         that neither you nor any of our PRC subsidiaries are subject to the
cybersecurity review by
         the CAC under the 2022 Cybersecurity Review Measures with respect to
the offering of
         your securities or the business operations of your PRC subsidiaries.
If you did not, please
         state why and the basis for your determination. Here and elsewhere
where you state that
         you are "applying for cybersecurity review," please provide further
disclosure regarding
         why you are doing so when you do not believe you are required to and
how this
         application process may affect your ability to conduct/complete this
offering and the
         timing thereof.
 Houqi Zhang
FirstName   LastNameHouqi   Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
April       NameAutozi Internet Technology (Global) Ltd.
       3, 2023
April 43, 2023 Page 4
Page
FirstName LastName
Management Discussion and Analysis and Results of Operations
Going Concern, page 102

10.      We note your response to comment 22. Please revise to outline the
material terms of the
         agreements related to financing from third-party investors, related
parties and bank
         borrowings. Discuss the duration of the agreement including the status
of your
         negotiations to extend bank loans, convertible bonds and corresponding
interests payable
         as discussed on page 104, repayment arrangements and other material
         requirements. Please also file the agreements as exhibits to the
registration statement. See
         Item 601(b)(10) of Regulation S-K. Alternatively, please tell us why
you are not required
         to do so.
Financial Statements, page F-1

11.      Refer to your response to comment 29. Although retroactive application
of the
         Reorganization is appropriate as you state, the Reorganization is a
combined group of
         commonly controlled entities for which presentation of combined
financial statements is
         appropriate pursuant to the definition of "combined financial
statements" in ASC 810-10-
         20 and guidance in ASC 810-10-45-10 and 55-1B. Please revise your
presentation
         accordingly and obtain and file an audit report that references the
financial statements as
            combined.
Notes to Consolidated Financial Statements
Note 1. Organization and principal activities
(a) Principal activities, page F-7

12.      We note in your response to comment 33 you will vigorously develop new
energy vehicle
         sales pattern in the future. Though revenues from new energy vehicle
sales only account
         for a small amount at this time, please disclose your accounting
policy for new energy
         vehicle sales and related cost of revenue given your expected
increased focus on these
         sales. Your disclosure should include all details necessary for an
investor to fully and
         clearly understand how revenues from and associated costs of sales of
new energy
         vehicles are determined and accounted for.
13.      Refer to your response to comment 33 regarding MBS stores. Please:
         1. Clarify in your disclosure if your parts and accessories on site at
the stores are sold
              to the stores solely for their use in performing insurance
related services for you or if
              you additionally sell parts and accessories to the stores for use
in conducting their
              own services including walk in sales.
         2. Clarify for us the reason for only an immaterial quantity of
on-site products
              mentioned in (2), how such amount is sufficient for stores to
fully and timely
              perform services, and who determines the amount of inventory to
be located in
              stores and how the amount is determined.
         3. Clarify for us what    in bulk    means in (3) regarding the Group
generating revenue
 Houqi Zhang
FirstName   LastNameHouqi   Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
April       NameAutozi Internet Technology (Global) Ltd.
       3, 2023
April 53, 2023 Page 5
Page
FirstName LastName
               from providing services to insurance companies.
         4.    When you pay stores for the service cost of insurance services
the stores perform,
               clarify in your disclosure if the cost includes the value of
parts and accessories you
               sold to the stores for their use in performing the services and
is factored by you into
               the amount you bill insurance companies.
14.      On page 136 in regard to material terms in your MBS store agreements
you mention you
         are obligated to pay service fees to the stores for the conclusion of
automotive sales
         transactions. Please tell us where your accounting treatment of this
is addressed in the
         notes to the financial statements. You also mention you usually charge
a one-off initial
         fee to stores on an annual basis. Please explain to us and disclose
what this represents and
         how this is addressed in your revenue recognition policy.
(l) Revenue recognition
New car sales, page F-13

15.      Please address the following as they pertain to your parallel import
car transactions and
         revise your disclosures to incorporate your responses as appropriate.
         1. In the response to comment 35 you state you first receive
potential    orders from
              downstream customers. Explain why the orders are considered as
potential. Explain
              what your obligation is regarding potential orders. If orders are
tentative, explain
              how and when they become firm. If orders/sales contracts are
cancellable by either
              party, explain when this can occur and under what circumstances,
and the
              consequences to each of you and customers (e.g., deposits are
refundable, penalties,
              fees).
         2. Explain whether customer orders specify the desired vehicle. If
not, explain what
              orders represent and when specification of vehicles is made and
how.
         3. The point in time a contract is established with customers and what
evidences that a
              contract has been established. In this regard, you state in the
response to comment
              35 you enter into the contract and sell vehicle to end customers
when vehicles are
              available at port warehouse. If this is true, explain why this is
the case, and why a
              contract is not established when the specific vehicle is
identified and agreed to by
              the customer.
         4. The point in time when customers know the price of vehicles, and
what evidences
              this and customers    acceptance of the price. Explain how the
complete and full sale
              price is established. Explain how and when the amount of the full
deposit for the
              purchase price is determined and collected from customers.
         5. Which party specifies customizations of vehicles, when and where do
              customizations occur, and who performs the customizations. At
what point is
              vehicle pricing adjusted for customizations, when are customers
notified of the
              adjusted price and when do customers accept the final adjusted
price and how is this
              evidenced.
         6. Explain whether the full deposit for the purchase price you collect
from customers
              includes adjustments to the vehicle sale price for
customizations. If so, state when
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FirstName   LastNameHouqi   Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
April       NameAutozi Internet Technology (Global) Ltd.
       3, 2023
April 63, 2023 Page 6
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FirstName LastName
             this occurs.
         7.  In 6(1) of the response to comment 35 you state aspects of what
you believe denotes
             you obtain control and legal title of vehicles. Explain the point
in time you obtain
             title/ownership. Explain to us whether it is your name or the
customer   s name that is
             on each of the documents mentioned. If it is your name, explain
when the
             documents become in the name of customers. Explain the point in
time
             ownership/title transfers to customers and what evidences this.
         8. Explain how you are able to direct the use of vehicles as stated in
the response to
             comment 35(6) when you are fulfilling specific orders for specific
customers from
             whom you have collected full deposits for the purchase price of
the vehicles.
         9. Explain the circumstances if vehicles do not pass customs and
consequences to each
             of you, customers and suppliers.
         10. In the response to comment 35(6), you state you do not have
unconditional right to
             return vehicles to the upstream importer. Explain who the
upstream importer    is.
             State whether there are any cancellation/return provisions with
the upstream
             importer and/or suppliers and the consequences to each party when
there is a
             cancellation or return.
16.      In regard to your parallel import car transactions, you state in the
response to comment 35
         that you bear the risk of loss due to physical damage, decline in
value or obsolescence.
         Please address how you have the risk of loss concerning the following:
         1. A decline in value, obsolescence or other risk of loss when you are
fulfilling specific
               orders of specific customers and you collect full deposits for
the purchase price from
               the customers from which to pay the cost of the vehicles to
suppliers. Since you
               obtain vehicles to satisfy specific orders for them, it appears
you do not possess the
               vehicles any longer than necessary to perform the required steps
to complete the sale
               and transfer of the vehicles.
         2. Physical damage when you state in the response to comment 37 that
the end
               customers always purchase an insurance. It appears that the risk
of loss has been
               transferred to insurers and you are relieved of any risk of
liability under the
               regulations referred to in the response to comment 37. In this
regard, explain to us
               the point in time the customers purchase an insurance and when
it the insurance is
               effective.
17.      The graphic on page 124 refers to used car trading being conducted on
your platform.
         Please explain to us what your role is in these transactions and
whether you accept trade
         ins for any of the vehicle transactions you perform. If you are
involved with trade ins,
         expand your disclosures to discuss your accounting for them.
Auto parts and auto accessories sales, page F-13

18.      You state in your response to comment 33 you only provide parts and
accessories to MBS
         stores. Please revise your disclosure here to clarify that the
"customer" is solely MBS
         stores.
 Houqi Zhang
FirstName   LastNameHouqi   Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
April       NameAutozi Internet Technology (Global) Ltd.
       3, 2023
April 73, 2023 Page 7
Page
FirstName LastName
19.      In your response to comment 33 your state you place parts and
accessories in MBS stores
         and the stores are charged for them as they use them. Your disclosure
here indicates parts
         and accessories are located in MBS stores based on fulfilling orders
by the stores. Please
         clarify in your disclosure who is the responsible party for stocking
and determining the
         amount of inventory of parts and accessories in MBS stores. Further,
clarify in your
         disclosure the party (you or MBS stores) that owns the inventory of
parts and accessories
         in MBS stores and when ownership of items are transferred from you to
the stores.
         Additionally, clarify in your disclosure whether inventory of parts
and accessories are
         solely located in MBS stores or if inventory is also located in your
facilities.
20.      On page 138 you disclose you procure automotive products from
manufacturers and
         deliver those products to your regional contracted parts dealers.
Please reconcile this to
         your statement in the response to comment 35 that you provide
automotive products only
         to MBS stores. Explain to us and disclose what contracted parts
dealers are and how they
         relate to your business operations.
Automotive insurance related services, page F-13

21.      In your response to comment 33, please clarify and disclose what you
mean that you are
         "primarily" responsible for the service quality to the insurance
companies. Explain to us
         and disclose as appropriate the consequences and process if the
quality is not acceptable to
         the insurance companies. For example, tell us and disclose whether (i)
you would be
         responsible if any re-work is required, (ii) you would pay the MBS
stores for any re-work
         they perform, and (iii) if insurance companies may seek refunds. If
any amounts are
         refundable to insurance companies, disclose whether you seek any
restitution from MBS
         stores.
22.      On page 126 under "An ecosystem of expansive product ..." you mention
increase in "our
         insurance sales." Please clarify for us and in your disclosure what
you mean by your
         insurance sales.
23.      The disclosure on page 141 in regard to claim and repair service
platforms appears to
         indicate you only facilitate these transactions for the parties
involved through your
         platforms rather than you entering into contracts with insurance
companies and MBS
         stores for the performance of these services on your part as disclosed
in the revenue
         recognition accounting policy note to the financial statements. Please
clarify for us and in
         the appropriate disclosure your role for these services.
Note 4. Deconsolidation of subsidiaries, page F-21

24.      Please address the following as they relate to your response to
comment 32:
             Clarify what you mean by    deregistered    in reference to the
deconsolidation of your
             subsidiaries;
             Disclose your relationship to the party to whom you transferred
Beijing E-commerce;
             You show cash out flows for the disposal of subsidiaries on your
consolidated
             statements of cash flows, while not mentioning any cash
transaction in your
 Houqi Zhang
Autozi Internet Technology (Global) Ltd.
April 3, 2023
Page 8
           disclosure on page F-21. Disclose cash transactions that occurred as
a part of the
           disposals;
             Disclose the carrying amount of the former subsidiary   s assets,
liabilities, and the
           noncontrolling interest in the former subsidiaries that were
deconsolidated; and
             Explain how your write-off of the accumulated deficit of the
former subsidiaries
           complies with your accounting policy disclosed on page F-10.

       You may contact Keira Nakada at 202-551-3659 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jennie Beysolow at 202-551-8108 or Lilyanna Peyser at 202-551-3222 with
any other
questions.



                                                             Sincerely,
FirstName LastNameHouqi Zhang
                                                      Division of Corporation
Finance
Comapany NameAutozi Internet Technology (Global) Ltd.
                                                      Office of Trade &
Services
April 3, 2023 Page 8
cc:       Yang Ge, Esq.
FirstName LastName