February 26, 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. 2 to Draft Registration Statement on Form F-1
           Submitted February 14, 2020
           CIK No. 0001795589

Dear Mr. Wang:

      We have reviewed your amended draft 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 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
February 6, 2020 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1

Risk Factors
Risks Relating to Our Business and Industry
Our business is subject to natural disasters, extreme weather conditions,
health epidemics . . .,
page 22

1.     We note you expect that the COVID-19 outbreak may have a negative impact
on demand
       for your products and solutions if it harms the Chinese or world economy
generally, or
       otherwise harms the business of your customers. Please expand the risk
factor to discuss
       the reasonably likely known effects of the outbreak on your business
operations as a result
 Yulin Wang
Kingsoft Cloud Holdings Limited
February 26, 2020
Page 2
       of most of your employees being located in China. To the extent
material, address the
       expected impact on your financial condition and results of operations
for fiscal year 2020.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Nine Months Ended September 30, 2019 Compared to Nine Months Ended September
30, 2018,
page 101

2.     We note your revised disclosure in response to prior comment 3 that:

           the increase in your public cloud services revenues was "primarily"
driven by
           increased average revenues per Public Cloud Service Premium Customer
and, "to a
           lesser extent," an increase in the number of Public Cloud Service
Premium
           Customers; and

           the increase in your enterprise cloud services revenues was
"primarily" driven by an
           increase in the number of Enterprise Cloud Service Premium Customers
and, "to a
           lesser extent," increased average revenues per Enterprise Cloud
Service Premium
           Customer.

       Please clarify the extent to which each factor contributed to growth in
revenues by
       quantifying such information. In this regard, it appears that the
increase in average
       revenues per Public Cloud Service Premium Customer represented the
substantial
       majority of the increase in public cloud services revenues for the nine
months ended
       September 30, 2019 and the fiscal year ended December 31, 2018. Refer to
Section III.D
       of SEC Release No. 33-6835.

        You may contact Inessa Kessman, Staff Accountant, at (202) 551-3371 or
Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
regarding
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.



                                                            Sincerely,
FirstName LastNameYulin Wang
                                                            Division of
Corporation Finance
Comapany NameKingsoft Cloud Holdings Limited
                                                            Office of
Technology
February 26, 2020 Page 2
cc:       Li He, Esq.
FirstName LastName