March 23, 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. 3 to Draft Registration Statement on Form F-1
           Submitted March 10, 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

Amendment No. 3 to Draft Registration Statement on Form F-1

16. Loss Per Share, page F-52

1.     Please tell us in detail how you calculated your weighted average number
of ordinary
       shares outstanding.
21. Subsequent Events, page F-55

2.     We note your statement on page F-28 that "the Company will recognize a
one-time share-
       based compensation expense for share-based awards subject to accelerated
vesting upon
       the completion of an IPO." Please confirm if the effect of accelerated
vesting has been
 Yulin Wang
Kingsoft Cloud Holdings Limited
March 23, 2020
Page 2
       disclosed in your subsequent events footnote; otherwise, disclose the
effect both in your
       MD&A and subsequent events footnote.

3.     We note the artwork on the inside front cover page of the prospectus
includes a
       presentation of revenue, revenue growth, and net dollar retention rate
without an equally
       prominent presentation of operating loss or net loss. In this regard, we
note that your
       operating loss and net loss grew 26% and 25%, respectively, from 2017 to
2019 on a
       compound annual growth rate (CAGR) basis. Please revise. Refer to
Question 101.02 of
       our Securities Act Forms Compliance and Disclosure Interpretations.
        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
March 23, 2020 Page 2
cc:       Li He, Esq.
FirstName LastName