This paper discusses how Yuan dynasty scholar Zhu Gong-Qian uses Neo- Confucianism and function words to expand the theory of "implied comparison" in his Classic of Poetry with Annotations under the paradigm of Zhu Xi's Poetry with Collected Commentaries. He puts forward nine forming conditions of the "implied comparison" from aspects such as whether "relevance in meaning" or "correspondence in language" are used, whether parallels are drawn or contrasts are made, and whether the words used match the flow of the work. The "correspondence in language" refers to the correspondence of the function and auxiliary words, where they follow or contrast each other or one another. The "relevance in meaning" means the correlation between the body sentence and the responding sentence. Zhu Gong-Qian's Neo-Confucianist definition of the "implied comparison" and proposition of the cause-effect relationship between "relevance in meaning" and "correspondence in language" complement Zhu Xi's concept of "implied comparison accompanied by explicit comparison" and "implied comparison accompanied by straightforward narrative." He consciously goes back to the text of The Classic of Poetry and searches for corresponding examples of function and auxiliary words. By applying the logic of examining objects to the text, he opens a new possibility for researches on the part of The Classic of Poetry in Zhu Xi's studies