July 27, 2018

Bin Yu
Chief Executive Officer
LingoChamp Inc.
3/F, Building B, No. 1687 Changyang Road, Yangpu District
Shanghai, 200090
People's Republic of China

       Re: LingoChamp Inc.
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted July 19, 2018
           CIK No. 0001742056

Dear Ms. Yu:

      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.

DRS Form S-1 Amendment No. 1 Filed July 19, 2018

Risk Factors
PRC regulation of loans to and direct investment in PRC entities by offshore
holding companies
and governmental control of currency..., page 39

1.     We note your response to our prior comment 2 and your revisions
throughout your
       registration statement. Please further revise your disclosures here and
on page 56 to state
       the approximate amount you currently may loan or contribute to your
subsidiaries.
 Bin Yu
LingoChamp Inc.
July 27, 2018
Page 2
Notes to the Consolidated Financial Statements
2. Principle Accounting Policies
(m) Revenue recognition, page F-17

2.       Tell us how you assessed the probability that you will collect
substantially all of the
         consideration to which you are entitled, in light of the "full
recourse" nature of your
         arrangements with financing companies upon default of your customers.
Refer to ASC
         606-10-25-1(e).
3.       With respect to prepaid multiple course packages, please disclose your
policy for
         developing a reasonable estimate of breakage for unconsumed courses.
Also, please tell
         us if you consider in your estimate circumstances where the Company
has been paid in
         full for a multiple course package but the customer has not paid the
financial institution in
         full.


4.       Consistent with your response to comment 8, please further disclose
here and on page 78
         the details regarding your policy for estimating a refund rate that
enables you to reliably
         conclude it is probable a significant revenue reversal will not occur.
That is, we note it is
         the Company's policy to review and supervise the refund rate on a
periodic basis. By
         adjusting the difficulty level of the exams in the packages, the
Company is able to
         maintain a stable refund rate, which constitutes a reasonable and
reliable basis for the
         Company to estimate and calculate the amount of the refund for
packages sold. Refer to
         ASC 606-10-32-11.
        You may contact Kathryn Jacobson, Staff Accountant, at 202-551-3365 or
Robert
Littlepage, Accountant Branch Chief, at 202-551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Courtney Lindsay, Staff
Attorney, at 202-551-7237 or Celeste Murphy, Legal Branch Chief, at
202-551-3257 with any
other questions.

FirstName LastNameBin Yu
Comapany NameLingoChamp Inc.
                                                                Division of
Corporation Finance
July 27, 2018 Page 2                                            Office of
Telecommunications
FirstName LastName