TEXT-EXTRACT
2
filename2.txt

United States securities and exchange commission logo





                              August 31, 2023

       Yil   Chen
       Chief Financial Officer
       Jianpu Technology Inc.
       5F Times Cyber Building, 19 South Haidian Road
       Haidian District, Beijing
       People   s Republic of China

                                                        Re: Jianpu Technology
Inc.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            File No. 001-38278

       Dear Yil   Chen:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 158

   1.                                                   We note your statement
that you reviewed your register of members and public EDGAR
                                                        filings made by your
shareholders in connection with your required submission under
                                                        paragraph (a). Please
supplementally describe any additional materials that were reviewed
                                                        and tell us whether you
relied upon any legal opinions or third party certifications such as
                                                        affidavits as the basis
for your submission. In your response, please provide a similarly
                                                        detailed discussion of
the materials reviewed and legal opinions or third party
                                                        certifications relied
upon in connection with the required disclosures under paragraphs
                                                        (b)(2) and (3).
   2.                                                   In order to clarify the
scope of your review, please supplementally describe the steps you
                                                        have taken to confirm
that none of the members of your board or the boards of your
                                                        consolidated foreign
operating entities are officials of the Chinese Communist Party. For
                                                        instance, please tell
us how the board members    current or prior memberships on, or
                                                        affiliations with,
committees of the Chinese Communist Party factored into your
 Yil   Chen
Jianpu Technology Inc.
August 31, 2023
Page 2
      determination. In addition, please tell us whether you have relied upon
third party
      certifications such as affidavits as the basis for your disclosure.
3.    We note that your disclosures pursuant to Items 16I(b)(2), (b)(3) and
(b)(5) are provided
      for    Jianpu Technology Inc. or any of the VIEs or the VIEs
subsidiaries.    We also note
      that your disclosures on pages 6, 100 and F-10, along with the list of
principal subsidiaries
      in Exhibit 8.1, appear to indicate that you have consolidated foreign
operating entities in
      Hong Kong and countries outside China. Please note that Item 16I(b)
requires that you
      provide disclosures for yourself and your consolidated foreign operating
entities,
      including variable interest entities or similar structures.
          With respect to (b)(2), please supplementally clarify the
jurisdictions in which your
           consolidated foreign operating entities are organized or
incorporated and provide the
           percentage of your shares or the shares of your consolidated
operating entities owned
           by governmental entities in each foreign jurisdiction in which you
have consolidated
           operating entities in your supplemental response.
          With respect to (b)(3) and (b)(5), please provide the required
information for you and
           all of your consolidated foreign operating entities in your
supplemental response.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Tyler Howes at 202-551-3370 or Jennifer Gowetski at
202-551-3401 with
any questions.



                                                            Sincerely,
FirstName LastNameYil   Chen
                                                            Division of
Corporation Finance
Comapany NameJianpu Technology Inc.
                                                            Disclosure Review
Program
August 31, 2023 Page 2
cc:       Haiping Li, Esq.
FirstName LastName