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                     January 25, 2023

       Handong Cheng
       Chief Executive Officer
       ZW Data Action Technologies Inc.
       Room 1106, Xinghuo Keji Plaza
       No. 2 Fufeng Road
       Fengtai District, Beijing
       China 100070

                                                        Re: ZW Data Action
Technologies Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            File No. 001-34647

       Dear Handong Cheng:

              We have completed our review of your filing. 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.




                     Sincerely,


                     Division of Corporation Finance

                     Office of Technology