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                              May 17, 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. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted April 25,
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.2 to Draft Registration Statement on Form F-1

       Cover page

   1.                                                   We note your response
to comment 3, however, your disclosure that    [y][o]ur Class A
                                                        ordinary shares may be
prohibited to trade on a national exchange or in the over-the-
                                                        counter trading market
in the United States under the HFCA Act, if the PCAOB
                                                        determines that it
cannot inspect or fully investigate [y]our auditors for three consecutive
                                                        years beginning in 2021
   continues to be inconsistent with the fact that your auditor is
                                                        subject to inspection
at least every two years. Please revise and make conforming changes
                                                        throughout the
document, including on page 57, to reflect accurate and consistent
                                                        disclosure.
 Houqi Zhang
FirstName  LastNameHouqi    Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
May        NameAutozi Internet Technology (Global) Ltd.
     17, 2023
May 17,
Page 2 2023 Page 2
FirstName LastName
Prospectus Summary
Permissions and Approvals for our Business Operation and Securities Offering,
page 6

2.       We note your response to comment 4 about obtaining all material
permissions and
         approvals. Please revise here and elsewhere as appropriate to remove
the materiality
         qualifier and 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. Disclose whether you
relied on counsel in
         determining whether you have obtained required permissions and
approvals other than
         with respect to the CAC and CSRC and, if not, state why not and the
basis for your
         determination. State affirmatively whether any permissions or
approvals have been
         denied.
Conventions that Apply to this Prospectus, page 13

3.       We note your response to comment 6. Please revise to ensure that the
subsidiaries named
         in the footnote are reflected in your company diagram on pages 7 and
97, or tell us why
         such disclosure is not necessary.
Risk Factor
The approval of and the filing with the CSRC or other Chinese government
authorities may be
required..., page 58

4.       We note your response to comment 8. Please revise to clearly state, if
true, that you have
         not engaged in the prohibited business stipulated in the 2021 Negative
List and therefore
         are not required to comply and provide the basis for your conclusion.
Principal Shareholders, page 185

5.       Please revise footnotes 4 and 5 to the table to identify the natural
persons with investment
         and/or voting control over CPEC Huakai Private Equity (Fujian) Co.,
LTD and Funde
         Sino Life Insurance Co., Ltd., respectively.
Related Party Transactions, page 187

6.       Please update this section to include relevant disclosure as of the
date of the prospectus.
         Refer to Item 7.B of Form 20-F.
Auto Parts and Auto Accessories Sales, page F-13

7.       We note your response to comment 13 that the sales of parts and
accessories to MBS
         stores through smart-cabinet is a very small portion of your total
auto parts and auto
         accessories sale and that the major customers of this revenue stream
are auto parts
         dealers. Given as such, please clarify the following in your
disclosure as it relates to sales
         to auto parts dealers:
             Describe the main terms that are set in the frame work contracts
(e.g. total quantity
 Houqi Zhang
FirstName  LastNameHouqi    Zhang Ltd.
Autozi Internet Technology (Global)
Comapany
May        NameAutozi Internet Technology (Global) Ltd.
     17, 2023
May 17,
Page 3 2023 Page 3
FirstName LastName
              that may or must be purchased, price, etc.);
                If the price varies based on purchase quantity, describe how
you determine the
              transaction price;
                Typical duration of the framework contracts; and
                Whether the customer is obligated to prepay the full amount of
the minimum
              purchase requirement under the contract, if any, or for each
order.
8.       Refer to your responses to comments 13, 18, 19 and 20. You state your
major customer
         are auto part dealers in terms of total auto parts and auto
accessories sales. We also note
         your statement on page 141 that you conduct your auto parts and auto
accessories business
         primarily through your MBS store network. Please reconcile these
statements and clarify
         the relationship to you between auto part dealers and MBS stores and
their roles in your
         sales of auto parts and accessories. Also, you state your sales of
parts and accessories to
         MBS stores through smart cabinets only accounts for a very small
portion of your total
         parts and accessories sales. In view of this and the preceding portion
of this comment,
         explain to us and disclose as appropriate how parts and accessories
are otherwise sold to
         MBS stores and the purpose of smart cabinets if they are not a
material sales source to
         MBS stores.
9.       In your revised disclosure here, you state the customer is auto
dealers, but it appears MBS
         stores are customers as well. In your responses to comments 13, 18 and
20, you state auto
         dealers are your major customers. Please revise your disclosure here
as appropriate, with
         consideration to the preceding comment.
Notes to Combined Financial Statements
3. Summary of Significant Accounting Policies
(l) Revenue Recognition
New Car Sales, page F-13

10.      You state in your response to comment 12 there is no difference of
revenue recognition
         policy between the parallel-import car sales and new energy car sales.
However, unlike
         parallel-import car sales, new energy cars are sold with an
involvement of MBS stores.
         Accordingly, please describe for us and disclose the new energy
vehicles    typical sales
         process, including the description of the MBS store involvement, fees
you incur for the
         MBS store involvement, whether MBS stores are exposed to the risk of
loss at any point
         in the process (e.g., while vehicles are at MBS stores), and any other
relevant factors to
         support your gross accounting.
11.      Refer to your response to comment 15. Please address the following:
         1. In point 8 you state the Group has the right to cancel the
potential order before the
              Group enters into a firm contract with customers. Clarify if the
Group can cancel
              the order even after the ordered vehicle has arrived in port in
China. Clarify if
              customers are aware of this right at the time they place
potential orders and how they
              are made aware of it.
         2. In point 8 you state the Group has the right to sell an ordered
vehicle that has arrived
 Houqi Zhang
Autozi Internet Technology (Global) Ltd.
May 17, 2023
Page 4
            in port to another customer that offers a higher price than the
ordering customer.
            Clarify if customers are aware of this right at the time they place
potential orders and
            how they are made aware of it. Clarify if the ordering customer has
any recourse
            other than a full refund of its deposit (for example, any penalty
to the Group).
       3.   In point 10 you state the customer can cancel its potential order
before entering into
            a formal contract. Clarify if the customer can cancel the order and
receive a full
            refund of its deposit even after the ordered vehicle has arrived in
port. Tell us if
            there are any penalties to customers for canceling orders after
vehicles arrive in port.
       4.   It appears the content of your response is meaningful information
to help investors
            understand your parallel-import transactions. Consider providing
disclosure
            consistent with the response in a suitable place in your filing, as
fulsome information
            as this does not appear to currently exist in the filing. Also
consider including
            additional information in connection with points 1, 2 and 3 of this
comment that is
            considered meaningful.
12.   On page 136 you discuss the cooperation of automotive sales or service
stores, including
      MBS stores, in regard to parallel import car sales. Disclosure in the
last two sentences of
      the last paragraph of that page appears to indicate parallel import sales
transactions are
      merely facilitated by your platform, suggesting you are an agent in
regard to these
      transactions. Please explain to us and disclose as appropriate how all of
the points made
      in your responses to prior comments 15 and 16 in supporting your
assertion that (i) you
      have the contracted performance obligation, (ii) you have control of
affected vehicles,
      particularly in regard to you having inventory risk for them, and (iii)
you are the principal
      in these sales transactions is consistent with this disclosure.
4. Deconsolidation of Subsidiaries, page F-21

13.   Please revise the disclosure you provided in response to comment 24 to
clarify whether
      you have been legally released from the liabilities previously held by
the deconsolidated
      subsidiaries. If not, tell us why it is reasonable to recognize gains for
liabilities you are
      still obligated to fulfill.
       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
May 17, 2023 Page 4
cc:       Yang Ge, Esq.
FirstName LastName