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United States securities and exchange commission logo
January 26, 2023
Haijian He
Chief Financial Officer
Kingsoft Cloud Holdings Limited
Building E, Xiaomi Science and Technology Park
No. 33 Xierqi Middle Road
Haidian District, Beijing, 100085
People s Republic of China
Re: Kingsoft Cloud
Holdings Limited
Form 20-F for the
Fiscal Year Ended December 31, 2021
Response dated
December 16, 2022
File No. 001-39278
Dear Haijian He:
We have reviewed your December 16, 2022 response to our comment
letter 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
November 9, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Item 3 Key Information
3.D. Risk Factors, page 1
1. We note your response
to prior comment 1. Please expand your disclosure here to state
that recent statements
by China s government, such as those related to the use of variable
interest entities
(VIEs) and data security or anti-monopoly concerns, have or may impact
the company s ability
to conduct its business, accept foreign investments, or list on a U.S.
or other foreign
exchange.
Haijian He
Kingsoft Cloud Holdings Limited
January 26, 2023
Page 2
2. We note your response to prior comment 4. Please clearly state in a
summary of risk
factors bullet point the risks related to obtaining any permissions or
approvals required to
be obtained from Chinese authorities to (i) operate your business and
(ii) offer the
securities being registered to foreign investors. Include a specific
cross-reference to a
more detailed risk factor discussion. Additionally, with a view toward
revised disclosure,
please clarify in your prospectus summary that you relied on the opinion
of counsel to
conclude that you have obtained all necessary permissions and approvals
to operate
your business and to offer the securities being registered to foreign
investors.
You may contact Inessa Kessman, Senior 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
Alexandra
Barone, Staff Attorney at 202-551-8816 or Mitchell Austin, Staff Attorney, at
at 202-551-
3574 with any other questions.
Sincerely,
FirstName LastNameHaijian He
Division of
Corporation Finance
Comapany NameKingsoft Cloud Holdings Limited
Office of
Technology
January 26, 2023 Page 2
cc: Ran Li, Esq.
FirstName LastName