Youxin Technology Ltd

Room 802, 803

No. 13 Hai’an Road, Tianhe District, Guangzhou, Guangdong Province ♦ People’s Republic of China

December 19, 2023

Mr. Matthew Derby

Ms. Alexandra Barone

Ms. Kathleen Collins

Ms. Chen Chen

Office of Technology

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4631

100 F Street, N.E.

Washington, D.C. 20549-4631

Dear Mr. Derby, Ms. Barone, Ms. Collins, and Ms. Chen:

This letter is in response to the letter dated December 14, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”). For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly. An Amendment No. 3 to Registration Statement on Form F-1 (the “F-1/A”) is being filed to accompany this letter.

Amendment No. 2 to Registration Statement on Form F-1

Factors Affecting Our Performance, page 54

Response: All of our contract terms are one-year with the option to renew for additional one-year terms prior to the expiration of the contract term. Our CRM systems display online prompts to customers about renewing services to continue access 30 days prior to the expiration of the contract term. Additionally, our customer service staff proactively communicates with customers about renewals prior to contract expiration. No contract terms, either initially or upon renewal, extend beyond one year. We have revised the disclosure on page 54 accordingly.

New customers are excluded from the customer renewal rate calculation for the fiscal year in which they initially begin service because these customers do not need to be renewed during the initial fiscal year in which they begin service. These customers would be included in the next fiscal year period’s calculation. For example, a customer who signs up for services in April 2021 with a one-year contract term ending April 2022 would not be included for the customer renewal rate calculation for the fiscal year ended September 30, 2021. Instead, this customer would be reflected in the customer renewal rate calculation for fiscal year ended September 30, 2022 because the customer would need to renew his contract prior to the expiration of the existing contract within the fiscal year ended September 30, 2022. Whether a customer is included in the calculations for interim six month periods ending March 31 will depend on whether the customer’s contract expires during the interim six month period being measured. For example, a customer who signed up in December 2021 would not be included in the calculation for the interim six month period ending March 31, 2022 because the customer’s initial contract would not have expired during the six month period ending March 31, 2022, but the customer would be included in calculation for the interim six month period ending March 31, 2023.

General

Response: We have revised the cover page and throughout the disclosure where appropriate.

Thank you in advance for your assistance in reviewing this response and the F-1/A. Should you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.