United States securities and exchange commission logo





                            February 8, 2023

       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
                                                            Amendment No. 8 to
Registration Statement on Form S-1
                                                            Filed February 3,
2023
                                                            File No. 333-248822

       Dear Jian Zhang:

             We have reviewed your amended 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 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.

       Amendment No. 8 to Registration Statement on Form S-1 filed February 3,
2023

       General

   1.                                                   We note your revisions
regarding a nine-month deadline to complete an initial business
                                                        combination, which
could be extended to 18 months. Please reconcile with the time
                                                        periods in Section 48.7
of Exhibit 3.3.
              You may contact Heather Clark at (202) 551-3624 or Jean Yu at
(202) 551-3305 if you
       have questions regarding comments on the financial statements and
related matters. Please
       contact Geoff Kruczek at (202) 551-3641 or Jay Ingram, Legal Branch
Chief, at (202) 551-3397
       with any other questions.
 Jian Zhang
Distoken Acquisition Corporation
February 8, 2023
Page 2

                                                Sincerely,
FirstName LastNameJian Zhang
                                                Division of Corporation Finance
Comapany NameDistoken Acquisition Corporation
                                                Office of Manufacturing
February 8, 2023 Page 2
cc:       Richard I. Anslow, Esq.
FirstName LastName