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                            June 29, 2023

       Shaozhang Lin
       Chief Executive Officer
       Youxin Technology Ltd
       Room 802, 803, No. 13 Hai   an Road
       Tianhe District, Guangzhou
       Guangdong Province, People's Republic of China

                                                        Re: Youxin Technology
Ltd
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted June 2,
2023
                                                            CIK No. 0001964946

       Dear Shaozhang Lin:

              We have reviewed your 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.

       Draft Registration Statement on Form F-1

       Cover Page

   1.                                                   Provide a description
of how cash is transferred through your organization. State whether
                                                        any transfers,
dividends, or distributions have been made to date between the holding
                                                        company, its
subsidiaries, or to investors, and quantify the amounts where applicable.
                                                        Provide
cross-references to the consolidated financial statements. Also disclose
whether
                                                        the company has written
cash management policies and procedures that dictate how funds
                                                        are transferred, and if
so, describe these policies and procedures.
 Shaozhang Lin
FirstName  LastNameShaozhang Lin
Youxin Technology Ltd
Comapany
June       NameYouxin Technology Ltd
     29, 2023
June 29,
Page 2 2023 Page 2
FirstName LastName
2.       We note your discussion of the CSRC trial measures on page 24,
including your statement
         that you have to file with the CSRC with respect to this offering.
Please revise your cover
         page to briefly explain whether and how you qualify as a direct
overseas listing, an
         indirect overseas listing, or neither. Include similar disclosures in
your prospectus
         summary and risk factors sections.
3.       We note the disclosure that your reference to China or the PRC
excludes Taiwan, Hong
         Kong, and Macau. Please clarify that the    legal and operational
risks associated with
         operating in China also apply to operations in Hong Kong/Macau/Taiwan.
In addition, to
         the extent material, discuss the applicable laws and regulations in
         Hong Kong/Macau/Taiwan, as applicable, as well as the related risks
and consequences.
         In addition, consider making conforming changes in your Regulations
section on page 84
         to address regulations in Hong Kong/Macau/Taiwan that may affect your
business
         operations.
Prospectus Summary, page 3

4.       Please revise the diagram of the company's corporate structure to be
easily legible. In your
         diagram, identify clearly the entity in which investors are purchasing
their interest and the
         entities in which the company's operations are conducted.
5.       In your summary of risk factors, specifically discuss risks arising
from the legal system in
         China, including risks and uncertainties regarding the enforcement of
laws and that rules
         and regulations in China can change quickly with little advance
notice; and the risk that
         the Chinese government may intervene or influence your operations at
any time, or may
         exert more control over offerings conducted overseas and/or foreign
investment in China-
         based issuers, which could result in a material change in your
operations and/or the value
         of the securities you are registering for sale. Acknowledge any risks
that any actions by
         the Chinese government to exert more oversight and control over
offerings that are
         conducted overseas and/or foreign investment in China-based issuers
could significantly
         limit or completely hinder your ability to offer or continue to offer
securities to investors
         and cause the value of such securities to significantly decline or be
worthless. For each of
         the risks related to doing business in China, provide a specific
cross-reference to the more
         detailed risk factor.
6.       In the prospectus summary, disclose each permission or approval that
you or 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 the China
Securities
         Regulatory Commission (CSRC), Cyberspace Administration of China (CAC)
or any
         other governmental agency, and 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)
 Shaozhang Lin
FirstName  LastNameShaozhang Lin
Youxin Technology Ltd
Comapany
June       NameYouxin Technology Ltd
     29, 2023
June 29,
Page 3 2023 Page 3
FirstName LastName
         applicable laws, regulations, or interpretations change and you are
required to obtain such
         permissions or approvals in the future.
7.       In the prospectus summary, provide a clear description of how cash is
transferred through
         your organization. Quantify any cash flows and transfers of other
assets by type that have
         occurred between the holding company and its subsidiaries and
direction of transfer.
         Quantify any dividends or distributions that a subsidiary has made to
the holding company
         and which entity made such transfer, and their tax consequences.
Similarly quantify
         dividends or distributions made to U.S. investors, the source, and
their tax consequences.
         Your disclosure should make clear if no transfers, dividends, or
distributions have been
         made to date. Describe any restrictions on foreign exchange and your
ability to transfer
         cash between entities, across borders, and to U.S. investors. Describe
any restrictions and
         limitations on your ability to distribute earnings from the company,
including your
         subsidiaries, to the parent company and U.S. investors.
8.       We note your disclosure in the forefront of the registration statement
related to the
         increase in the company's revenues and gross profit in fiscal years
2021 and 2022.
         Balance this disclosure with equally prominent disclosure of the
company's net loss for
         the same periods.
Implications of Being and Emerging Growth Company, page 8

9.       Please note that your election to take advantage of the extended
transition period for
         complying with new or revised accounting standards is not irrevocable.
Please revise
         your disclosures as necessary. Refer to Question 37 of the FAQ on
Title 1 of the JOBS
         Act.
Risk Factors, page 12

10.      Please add a risk factor discussing any risks related to your dual
class capital structure,
         such as the risks that your dual class structure may render your
shares ineligible for
         inclusion in certain stock market indices, and thus adversely affect
share price and
         liquidity.
11.      Please revise your risk factor disclosure to indicate you have a
history of losses and
         highlight the explanatory paragraph in your audit opinion raising
substantial doubt about
         your ability to continue as a going concern. Additionally, disclose
the potential effect
         the going concern opinion may have on your ability to raise additional
funds through
         equity or debt financing.
As more of our sales efforts are targeted at larger enterprise clients..., page
16

12.      We note your disclosure that your ability to maintain close
relationships with your major
         clients is essential to the success of your business. To the extent
material, revise to discuss
         the material terms of any agreements with your major clients,
including termination
         provisions, and file those agreements as exhibits or tell us why it is
not required.
 Shaozhang Lin
Youxin Technology Ltd
June 29, 2023
Page 4
Management's Discussion and Analysis of Financial Conditions and Results of
Operations
Overview, page 51

13.      Please revise the MD&A Overview section to discuss management's plans
to scale your
         operations. Address any milestones you intend to reach, the steps you
will take to achieve
         each milestone, and the anticipated timing. Also, revise your
liquidity discussion to
         address and quantify any material cash requirements needed to reach
such milestones.
         Refer to Item 5 of Form 20-F.
14.      You state that new customer acquisition and expanding usage by
existing customers are
         factors affecting your results of operations. Please tell us what
measure(s) you use to
         monitor the retention and acquisition of customers as well as
expansion of existing
         customers and revise to include a quantified discussion of such
measures. Refer to SEC
         Release 33-10751.
15.      We note that "as of September 30, 2022, three suppliers accounted for
87% of [y]our
         accounts payable" and that "as of September 30, 2021, one supplier
accounted for 83% of
         [y]our accounts payable." Please revise your disclosure where
appropriate to provide a
         more complete discussion of your relationship with your suppliers and
quantify the
         percentage of accounts payable each of the top three suppliers
accounted for. In addition,
         clarify whether you have material agreements with any of your
suppliers upon which you
         are substantially dependent, and file those agreements as exhibits.
Refer to Item
         601(b)(10) of Regulation S-K.
Liquidity and Capital Resources, page 58

16.      Please clarify whether you are dependent on the proceeds of this
offering to finance your
         operations for the next 12 months, as well as the minimum dollar
amount of funding
         required to remain in business for at least the next 12 months. Refer
to Item 5.B of
         Form 20-F, and Section IV of SEC Release No. 33-8350.
Consolidated Financial Statements of Youxin Technology Ltd., page F-3

17.    We note that your financial statements are giving retroactive effect to
the issuance of
       shares effected on April 12, 2023. However, it is unclear from your
disclosures in Note
       13 whether such issuance is part of the reorganization described in Note
1. Please explain
       and revise your disclosures throughout the filing, as necessary. In your
response, tell us
       your basis for presenting the issuance of such shares on a retrospective
basis and provide
FirstName LastNameShaozhang Lin
       the specific accounting guidance you relied upon to support your
conclusion. Also,
Comapany    NameYouxin
       explain            Technology
               why the information   in Ltd
                                        your pro forma capitalization table
differs from your
       financial
June 29,         statements.
         2023 Page   4
FirstName LastName
 Shaozhang Lin
FirstName  LastNameShaozhang Lin
Youxin Technology Ltd
Comapany
June       NameYouxin Technology Ltd
     29, 2023
June 29,
Page 5 2023 Page 5
FirstName LastName
Notes to Consolidated Financial Statements
Note 3 - Summary of Significant Accounting Policies
f. Cash and cash equivalents, page F-10

18.      Please provide us with a detailed breakdown of the items included in
your total cash and
         cash equivalents and ensure that, at a minimum, you separately provide
the amounts held
         in cash, time deposits and liquid investments. To the extent you hold
any types of    highly
         liquid investments,    tell us what they are and provide the amounts
held in each.
l. Revenue Recognition, page F-12

19.      Please tell us, and revise to disclose, the cancellation terms and
refund policy for each of
         your revenue streams.
Note 15. Concentrations and Risks
Concentrations, page F-27

20.      Please revise to provide a breakdown of revenue from each customer
that accounted for
         more than 10% of your revenue for each period presented. In this
regard, identify and
         distinguish each customer by reference to customer A, customer B,
customer C, as an
         example. Similar disclosures should be provided for your concentration
of accounts
         receivable. Refer to ASC 280-10-50-42 and ASC 275-10-50-18(a).
General

21.      Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communication.
        You may contact Chen Chen, Staff Accountant, at (202) 551-7351 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters. Please contact Alexandra Barone,
Staff Attorney, at
(202) 551-8816 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any
other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Technology
cc:      Anthony Basch