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                            July 31, 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
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted July 17,
2023
                                                            CIK No. 0001964946

       Dear Shaozhang Lin:

             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. Unless we note otherwise, our references to prior comments are
to comments in our
       June 29, 2023 letter.

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

       Cover Page

   1.                                                   Please revise your
discussion about how cash is transferred through your organization to
                                                        provide
cross-references to the consolidated financial statements.
 Shaozhang Lin
FirstName  LastNameShaozhang Lin
Youxin Technology  Ltd
Comapany
July       NameYouxin Technology Ltd
     31, 2023
July 31,
Page  2 2023 Page 2
FirstName LastName
2.       We note your response to prior comment 3. Even though the company
conducts its
         operations in China only, please clarify that the legal and
operational risks associated with
         operating in China also apply to operations in Hong Kong. In this
regard, we note the
         company has a subsidiary in Hong Kong. In addition, to the extent
material, discuss the
         applicable laws and regulations in Hong Kong as well as the related
risks and
         consequences. Also consider making conforming changes in your
Regulations section on
         page 86 to address regulations in Hong Kong that may affect your
business operations.
Prospectus Summary, page 1

3.       Please expand your discussion about the permissions and approvals
required to be
         obtained from Chinese authorities to operate your business to also
discuss any permissions
         and approvals required to be obtained from Chinese authorities to
offer securities to
         foreign investors. If you determine no permissions are required,
provide an explanation as
         to whether you consulted counsel and, if not, why you did not consult
counsel and why
         you do not need any permissions or approvals to operate your business
or offer securities
         to foreign investors.
Risk Factors
As more of our sales efforts are targeted at larger enterprise clients..., page
18

4.       We note your response to prior comment 12. Please file any material
agreements as
         exhibits or tell us why it is not required. Refer to Item 601(b)(10)
of Regulation S-K for
         guidance.
Capitalization, page 51

5.       You state that the issuance of Class A shares and Class B shares were
effected on April
         11, 2023 and April 21, 2023. However, various places in your financial
statements (e.g.,
         "*"footnote reference on the face of financial statements, Note 13
related to Subscription
         Receivable, etc.) appear to indicate that such issuance occurred on
April 12, 2023. Please
         revise the inconsistencies throughout the filing or explain.
Management's Discussion and Analysis of Financial Conditions and Results of
Operations
Overview, page 53

6.       We note your revised disclosures in response to prior comment 13,
however, it remains
         unclear what financial and/or non-financial measures management uses
to monitor the
         retention and acquisition of customers as well as expansion of
existing customers. For
         example, clarify whether you use measures such as churn rate,
retention rate, net dollar
         expansion rate, etc., or specify the measures you do use and revise to
include a quantified
         discussion of such measures. Refer to SEC Release 33-10751.
 Shaozhang Lin
FirstName  LastNameShaozhang Lin
Youxin Technology  Ltd
Comapany
July       NameYouxin Technology Ltd
     31, 2023
July 31,
Page  3 2023 Page 3
FirstName LastName
General

7.       Please update your financial statements pursuant to Item 8.A.5 of Form
20-F or explain.
        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