October 16, 2019

Xiaofeng Gao
Chief Executive Officer
Skillful Craftsman Education Technology Ltd
Floor 4, Building 1, No. 311, Yanxin Road
Huishan District, Wuxi
Jiangsu Province, PRC 214000

       Re: Skillful Craftsman Education Technology Ltd
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted October 7, 2019
           CIK No. 0001782309

Dear Mr. Gao:

      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.

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

Use of Proceeds, page 47

1.     We note that you anticipate being able to use the net proceeds from this
offering in the
       form of RMB through loans or capital contributions to your PRC
subsidiary and VIE
       entity. Address the impact of PRC foreign exchange control restrictions
on your ability to
       convert the proceeds from U.S. dollars to RMB.
 Xiaofeng Gao
FirstName LastNameXiaofeng Gao
Skillful Craftsman Education Technology Ltd
Comapany NameSkillful Craftsman Education Technology Ltd
October 16, 2019
Page 2
October 16, 2019 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Performance Indicators, page 56

2.       Revise to clarify the intended meaning of management measuring key
performance
         indicators by "comparing to a pre-set percentage, absolute amount or
relative amount."
         Additionally, adjust the diagram of your key performance indicator
results to reflect the
         correct fiscal years being used for purposes of comparing the changes
year-over-year.
        You may contact Inessa Kessman, Senior Staff Accountant, at (202)
551-3371 or Robert
S. Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Joshua
Shainess,
Attorney-Adviser, at (202) 551-7951 or Celeste M. Murphy, Legal Branch Chief,
at (202) 551-
3257 with any other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services