United States securities and exchange commission logo July 24, 2023 Zaichang Ye Chief Executive Officer and Director SunCar Technology Group Inc. c/o Shanghai Feiyou Trading Co., Ltd. Suite 209, No. 656 Lingshi Road Jing an District, Shanghai, 200072 PRC Re: SunCar Technology Group Inc. Registration Statement on Form F-1 Filed July 17, 2023 File No. 333-273286 Dear Zaichang Ye: We have limited our review of your registration statement to those issues we have addressed in our 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Registration Statement on Form F-1 filed July 17, 2023 Cover Page 1. Please revise your cover page and Plan of Distribution to identify each of GEM Investor and GYBL as underwriters. In this regard, we note your disclosure on page 93 that "GEM Investor may be deemed an "underwriter" within the meaning of Section 2(a)(11) of the Securities Act." We also note that GYBL received a warrant in connection with execution of the Share Purchase Agreement, dated November 4, 2022, and you disclose on page F-6 that you granted such warrant "as consideration for GEM Investor s irrevocable commitment to purchase the GEM Shares." For guidance, refer to Securities Act Compliance and Disclosure Interpretation 139.13. Zaichang Ye SunCar Technology Group Inc. July 24, 2023 Page 2 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Brian Fetterolf at 202-551-6613 or Dietrich King at 202-551-8071 if you have any questions. Sincerely, FirstName LastNameZaichang Ye Division of Corporation Finance Comapany NameSunCar Technology Group Inc. Office of Trade & Services July 24, 2023 Page 2 cc: Elizabeth Fei Chen FirstName LastName