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                              April 11, 2024

       Jun Jiang
       Chief Operating Officer
       Jinxin Technology Holding Co
       Floor 8, Building D, Shengyin Building
       Shengxia Road 666
       Pudong District, Shanghai 201203
       People   s Republic of China

                                                        Re: Jinxin Technology
Holding Co
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed April 2, 2024
                                                            File No. 333-273884

       Dear Jun Jiang:

            We have reviewed your amended registration statement and have the
following
       comment(s).

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

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

       Notes to Consolidated Financial Statements
       Note 2. Summary of Significant Accounting Policies
       Revenue recognition
       Revenue from sales of digital educational hardware devices, page F-19

   1.                                                   Please revise the first
sentence to clarify its meaning. Please clarify whether the company
                                                        or the hardware
distributor who purchases your digital education hardware device installs
                                                        the digital educational
content to end users.
 Jun Jiang
FirstName   LastNameJun Jiang
Jinxin Technology  Holding Co
Comapany
April       NameJinxin Technology Holding Co
       11, 2024
April 211, 2024 Page 2
Page
FirstName LastName
       Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at
202-551-3380 with any
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services
cc:      Steve Lin