September 7,
2018

Xiaoping Chen
Chairman and Chief Executive Officer
Viomi Technology Co., Ltd
Wansheng Square, Rm 1302 Tower C
Xingang East Road, Haizhu District
Guangzhou, Guangdong, 510220, PRC

        Re: Viomi Technology Co., Ltd
            Registration Statement on Form F-1
            Filed on August 28, 2018
            File no. 333-227063

Dear Mr. Chen:

       We have reviewed your 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.

Form F-1 filed on August 28, 2018

Our dual class share structure with different voting rights will limit your
ability to influence
corporate matters..., page 51

1.     We note that you have adopted a dual-class share structure with
different voting rights that
       will become effective upon completion of the offering. Please discuss
why the Board
       determined to adopt this dual-class structure in connection with the
company's initial
       public offering.
2.     To provide further context regarding how your dual-class structure will
operate in
       practice, please discuss the following:
 Xiaoping Chen
FirstName LastNameXiaoping Chen
Viomi Technology Co., Ltd
Comapany 7, 2018
September NameViomi Technology Co., Ltd
September 7, 2018 Page 2
Page 2
FirstName LastName

             the percentage of outstanding shares that the Class B shareholders
must keep to
             continue to control the outcome of matters submitted to
shareholders for approval;
             whether the company may issue additional Class B ordinary shares
and how this may
             further dilute the holders of Class A ordinary shares and ADSs;
             the circumstances under which the Class B ordinary shareholders
may convert their
             shares to Class A ordinary shares or are required to convert their
Class B ordinary
             shares; and
             the resulting impact of the conversion of Class B ordinary shares
on holders of Class
             A ordinary shares and ADSs, including dilution and lowering of the
aggregate voting
             power of the Class B shareholders, but the increase of the
relative voting power of
             individual Class B ordinary shareholders who retain their shares.


3.       To the extent that Mr. Chen and/or the other Class B shareholders will
have complete
         control over the outcome of matters put to a vote of shareholders,
please make this clear in
         the risk factor heading and disclosure.
As an exempted company incorporated in the Cayman Islands, we are permitted to
adopt certain
home country practices..., page 58

4.       Please explain how, with your dual-class structure with different
voting rights, you
         will determine whether more than 50 percent of your outstanding voting
securities are
         owned of record by U.S. residents for purposes of satisfying the
foreign private issuer
         definition. Refer to Securities Act Rule 405, Exchange Act Rule 3b-4
and Securities Act
         Rules Compliance and Disclosure Interpretation 203.17.


        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.
 Xiaoping Chen
Viomi Technology Co., Ltd
September 7, 2018
Page 3

        You may contact Joseph Cascarano, Staff Accountant, at 202-551-3376, or
Robert S.
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Kathleen Krebs, Special Counsel, at 202-551-3350
with any other
questions.



FirstName LastNameXiaoping Chen                           Sincerely,
Comapany NameViomi Technology Co., Ltd
                                                          Division of
Corporation Finance
September 7, 2018 Page 3                                  Office of
Telecommunications
FirstName LastName