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| Davis Polk & Wardwell Hong Kong Solicitors The Hong Kong Club Building 3A Chater Road Hong Kong |
852 2533 3300 tel | Karen Chan † Yang Chu † James C. Lin* Gerhard Radtke* |
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Martin Rogers † Patrick S. Sinclair* Miranda So* James Wadham† |
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April 17, 2020
| Re: | Kingsoft Cloud Holdings Limited (CIK: 0001795589) |
| Registration Statement on Form F-1 |
Confidential
Mr. Bernard Nolan
Mr. Larry Spirgel
Ms. Inessa Kessman
Mr. Robert Littlepage
Office of Technology
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Dear Mr. Nolan, Mr. Spirgel, Ms. Kessman and Mr. Littlepage:
On behalf of Kingsoft Cloud Holdings Limited (the “Company”), a company incorporated under the laws of the Cayman Islands, we are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR with the Securities and Exchange Commission (the “Commission”).
To facilitate your review, we have separately delivered to you four courtesy copies of the Registration Statement, marked to show changes to the draft registration statement on Form F-1 confidentially submitted on March 30, 2020, and four copies of the submitted exhibits.
The Company is, concurrently with the Registration Statement, filing the Draft Registration Statement and all amendments thereto that were previously submitted for the non-public review of the staff of the Commission (the “Staff”), and plans to file an amendment to the Registration Statement containing the estimated price range and offering size and launch the road show as soon as legally permissible on or around May 5, 2020, subject to market conditions. As such, the Company would greatly appreciate the Staff’s continuing assistance and support in meeting its timetable.
If you have any questions regarding this submission, please contact Li He at +852 2533-3306 (li.he@davispolk.com) or Ran Li at +86 10 8567-5013 (ran.li@davispolk.com).
Thank you again for your time and attention.
| Yours sincerely, |
| /s/ Li He |
| Li He |
| cc: | Mr. Yulin Wang, Chief Executive Officer |
Kingsoft Cloud Holdings Limited
Mr. David T. Zhang, Esq., Partner
Mr. Steve Lin, Esq., Partner
Kirkland & Ellis International LLP
Mr. Raymond Wong, Partner
Ms. Grace Lim, Partner
Ernst & Young Hua Ming LLP
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