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                             October 21, 2020

       Jian Zhang
       Chairman and Chief Executive Officer
       Distoken Acquisition Corporation
       Unit 1006, Block C, Jinshangjun Park
       No. 2 Xiaoba Road, Panlong District
       Kunming, Yunnan, People's Republic of China

                                                        Re: Distoken
Acquisition Corporation
                                                            Pre-effective
Amendment 1 to Registration Statement on Form S-1
                                                            Filed October 9,
2020
                                                            File No. 333-248822

       Dear Mr. Zhang:

              We have reviewed your amended registration statement and have the
following
       comment. In our comment, we may ask you to provide information so that
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 that our comment applies to
your facts and
       circumstances or do not believe that an amendment is appropriate, please
tell us why in your
       response.

              After reviewing any amendment to your registration statement and
the information that
       you provide in response to the comment, we may have additional comments.

       Pre-effective Amendment 1 to Registration Statement on Form S-1 filed
October 9, 2020

       Exhibit 4.4
       Section 9.3, page 14

   1.                                                   Revise this exhibit to
conform with the disclosure on pages 28 and 99 in the prospectus by
                                                        stating that the
provision is applicable to claims under the Securities Act but is
                                                        inapplicable to claims
under the Exchange Act or any other claim for which the federal
                                                        district courts of the
United States are the sole and exclusive forum, or tell us how you
                                                        will make future
investors aware of the limited applicability of the provision. For
                                                        example, will you
include disclosure in your future applicable filings under the Exchange
                                                        Act?
 Jian Zhang
Distoken Acquisition Corporation
October 21, 2020
Page 2

        You may contact Effie Simpson, Staff Accountant, at (202) 551-3346 or
Jean C. Yu,
Assistant Chief Accountant, at (202) 551-3305 if you have questions regarding
comments on the
financial statements and related matters. Please contact Edward M. Kelly,
Senior Counsel, at
(202) 551-3728 or Geoffrey D. Kruczek, Senior Counsel, at (202) 551-3641 with
any other
questions.



                                                          Sincerely,
FirstName LastNameJian Zhang
                                                          Division of
Corporation Finance
Comapany NameDistoken Acquisition Corporation
                                                          Office of
Manufacturing
October 21, 2020 Page 2
cc:       Richard I. Anslow, Esq.
FirstName LastName