February 6, 2020

Yulin Wang
Chief Executive Officer
Kingsoft Cloud Holdings Limited
Kingsoft Tower, No. 33
Xiao Ying West Road, Haidian District
Beijing, 100085, the People's Republic of China

       Re: Kingsoft Cloud Holdings Limited
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted January 23, 2020
           CIK No. 0001795589

Dear Mr. Wang:

      We have reviewed your amended draft registration statement and have the
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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
January 15, 2020 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1

Risk Factors
Risk Relating to Our Relationships with Kingsoft Group and Xiaomi, page 44

1.     We note your response to prior comments 1 and 5 that Kingsoft Group and
Xiaomi are not
       under common control. Please, however, enhance the discussion of the
risks related to
       your dependence on Kingsoft and Xiaomi by disclosing that Mr. Jun Lei
       significant influence over Kingsoft Group. In this regard, we note that
in addition to
       serving as the chairman, he appears to be the largest shareholder of
Kingsoft Group.
 Yulin Wang
FirstName LastNameYulin Wang
Kingsoft Cloud Holdings Limited
Comapany NameKingsoft Cloud Holdings Limited
February 6, 2020
February 6, 2020 Page 2
Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page

2.       We note under Subsequent Events on page F-79 that on December 5, 2019,
the Company
         granted approximately 49 million shares to employees under the Share
Award Scheme.
         On January 20, 2020, the Company granted 54 million shares to an
employee under the
         Share Award Scheme. Please provide a forward-looking discussion of the
impact of these
         awards on your results of operations, including quantification of the
total amount of
         compensation expense recognized and the amount you anticipate
recognizing in future
Results of Operations
Nine Months Ended September 30, 2019 Compared to Nine Months Ended September
30, 2018,
page 101

3.       Your revised disclosure in response to prior comment 11 addresses the
amounts by which
         average revenues per Premium Customer and the number of Premium
Customers grew.
         Also, you continue to state that growth in public cloud services
revenues and enterprise
         cloud services revenues was "primarily" driven by these factors.
Please clarify the extent
         to which revenue growth has been attributable to generating additional
revenues from
         existing customers versus acquiring new customers. In this regard, it
appears that existing
         customers have been the primary driver of revenue growth. As part of
your response,
         please also explain these dynamics in your discussion of the key
factors that affect your
         results of operations.
Compensation of Directors and Executive Officers, page 161

4.       Please disclose compensation information for the fiscal year ended
December 31, 2019.
         Refer to Item 6.B of Form 20-F.
Financial Statements
1. Organization and Basis of Presentation, page F-10

5.       We note your response to our prior comment 17 and your modification of
your statement
         on page F-16 with the word "additional." However, given that the
contractually required
         amount is unlimited financial support, the two statements appear to
continue to
         contradict each other. Please revise accordingly.
6.       We note your response to prior comment 18 related to the application
of the related-party
         tiebreaker under ASC 810. Please explain to us how the Company does
not meet the
         criteria under ASC 810-10-25-38A on a standalone basis to be the
primary beneficiary,
         such that the related party tiebreaker would not have to be applied.
Include in your
         response your consideration of ASC 810-10-25-42 with respect to
indirect interests held
         through your related party affiliate.
 Yulin Wang
Kingsoft Cloud Holdings Limited
February 6, 2020
Page 3

        You may contact Inessa Kessman, Staff Accountant, at (202) 551-3371 or
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
comments on the financial statements and related matters. Please contact
Bernard Nolan,
Attorney-Adviser, at (202) 551-6515 or, in his absence, Larry Spirgel, Office
Chief, at (202)
551-3815 with any other questions.

FirstName LastNameYulin Wang
                                                            Division of
Corporation Finance
Comapany NameKingsoft Cloud Holdings Limited
                                                            Office of
February 6, 2020 Page 3
cc:       Li He, Esq.
FirstName LastName