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WRITER'S DIRECT DIAL

(852) 3551-8690

WRITER'S E-MAIL
ADDRESS

ning.zhang@morganlewis.com

September 15, 2023

VIA EDGAR

Mr. Kyle Wiley

Mr. Christopher Dunham

Disclosure Review Program

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 Re: ATA Creativity
                                            Global

                                            Form 20-F for the Fiscal Year Ended December 31, 2022

                                            File No. 001-33910

Ladies and Gentlemen:

On behalf of ATA Creativity
Global (the “Company”), set forth below are the Company’s responses to your comment letter dated August 31,
2023 (the “Letter”) with respect to the above-referenced Form 20-F (the “2022 Form 20-F”)
filed with the Securities and Exchange Commission (the “Commission”) on April 12, 2023. The Company also undertakes
to reflect the comments in the Letter as appropriate in its Form 20-F for the fiscal year ended December 31, 2023 (the “2023
Form 20-F”), subject to further comment(s) from the Commission’s staff (the “Staff”) and
the changes of facts or regulations by then, if any.

For your convenience, we
have reproduced the comments from the Staff in bold and italic in front of the related response. All references in the Company’s
responses to pages and captioned sections are to the 2022 Form 20-F. Capitalized terms used in this letter and not otherwise
defined herein have the meaning ascribed to them in the 2022 Form 20-F.

Partners:

Edwin Luk, June Chan, Connie Cheung, Keith Cheung*#,

William Ho, David
Liao, Charles Mo, Billy Wong, and Yan Zeng

Registered Foreign
Lawyers:

Eli Gao (New York),
Maurice Hoo (California),

Alice Huang (California),
Mathew Lewis (New York),

Louise Liu (New
York), Vivien Yu (New South Wales),

    and
    Ning Zhang (New York)
    Suites 1902-09, 19th Floor

    Edinburgh Tower, The Landmark

    *China-Appointed
    Attesting Officer
    15 Queen's Road Central
     +852.3551.8500

    #Notary
    Public of Hong Kong
    Hong Kong
     +852.3006.4346

September 15, 2023 - Page 2

Form 20-F for the Fiscal Year Ended
December 31, 2022

Item 16I. Disclosure Regarding Foreign
Jurisdictions that Prevent Inspections, page 121

 1. We note your statement
                                            that you reviewed your register of members and public filings made by your shareholders in
                                            connection with your required submission under paragraph (a). Please supplementally describe
                                            any additional materials that were reviewed and tell us whether you relied upon any legal
                                            opinions or third party certifications such as affidavits as the basis for your submission.
                                            In your response, please provide a similarly detailed discussion of the materials reviewed
                                            and legal opinions or third party certifications relied upon in connection with the required
                                            disclosures under paragraphs (b)(2) and (3).

The Company respectfully
advises the Staff that, the shareholders of the Company can be divided into two types in terms of the securities of the Company they
hold. The Company’s American Depositary Shares are listed and traded on the Nasdaq Global Market and thus some of the Company’s
shareholders are public shareholders who acquire and hold the Company’s American Depositary Shares with the underlying common shares
represented by such American Depositary Shares registered in the name of the depository bank of the Company on the Company’s register
of the members, while the other shareholders who hold the common shares of the Company directly were registered as shareholders on the
Company’s register of members. For the public shareholders, the Company has no way to learn their shareholding structure nor beneficial
owner other than through reviewing the public filings they made (if any), so the Company can only rely on the public filings made by
the public shareholders for its submission, particularly the Schedule 13Ds and Schedule 13Gs. For the direct shareholders registered
on the Company’s register of members, the Company has conducted due diligence on them when they first became shareholders of the
Company and has confirmed with them in writing to the extent reachable practically. As such, the Company made the submission under paragraph
(a) that the Company is not owned or controlled by any governmental entity in mainland China as of the date hereof to its best knowledge
and based on its examination of the Company’s register of members, public filings made by its shareholders and to the extent reachable
practically, written confirmations from its shareholders, and has not otherwise relied upon any legal opinions or other third party certifications
such as affidavits as the basis for its submission.

The Company respectfully
further advises the Staff that, with respect to its disclosures under paragraphs (b)(2) and (3), it is duly noted that Item 16I(b) requires
that the Company provide disclosures for itself and all of its consolidated foreign operating entities, including variable interest entities
or similar structures as per your comment below. In addition to the shareholders of the Company, which have been addressed as discussed
above, for the subsidiaries of the Company, they are all wholly owned by the Company without other third party shareholders; for the
VIE, the only two shareholders of the VIE are Xiaofeng Ma, our Chairman and Chief Executive Officer, and Jun Zhang, our President, both
of whom are not governmental entities based on written confirmations we obtained from each of them; the VIE also has a subsidiary not
wholly owned by the VIE and the other shareholder of such subsidiary of the VIE is a limited partnership, the only two partners of which
are also Xiaofeng Ma and Jun Zhang. As such, the Company made its disclosures under paragraphs (b)(2) and (3) that, as of the
date hereof, governmental entities in the jurisdictions in which the Company, subsidiaries of the Company and the VIE are incorporated
or otherwise organized, including the Cayman Islands, mainland China, Hong Kong and the British Virgin Islands, hold no shares in the
Company, subsidiaries of the Company or the VIE, and Chinese governmental entities have no controlling financial interest in the Company,
subsidiaries of the Company or the VIE, to its best knowledge and based on its examination of the register of members, register of shareholders
or other equivalent document(s) of each of the Company, subsidiaries of the Company and the VIE, public filings made by the Company’s
shareholders and to the extent reachable practically, written confirmations from the shareholders of the Company and the VIE, and has
not relied upon any legal opinions or other third party certifications such as affidavits as the basis for its disclosures under paragraphs
(b)(2) and (3).

September 15, 2023 - Page 3

 2. We note that your
                                            disclosures pursuant to Items 16I(b)(2), (b)(3), (b)(4), and (b)(5) are provided for
                                            “us or the VIE.” We also note that your list of subsidiaries in Exhibit 8.1
                                            appears to indicate that you have subsidiaries in Hong Kong and countries outside China that
                                            may not be included in your disclosure. Please note that Item 16I(b) requires that you
                                            provide disclosures for yourself and all of your consolidated foreign operating entities,
                                            including variable interest entities or similar structures.

 · With respect to (b)(2), please
                                            supplementally clarify the jurisdictions in which your consolidated foreign operating entities
                                            are organized or incorporated and provide the percentage of your shares or the shares of
                                            your consolidated operating entities owned by governmental entities in each foreign jurisdiction
                                            in which you have consolidated operating entities in your supplemental response.

 · With respect to (b)(3), (b)(4),
                                            and (b)(5), please provide the required information for you and all of your consolidated
                                            foreign operating entities in your supplemental response.

The Company respectfully
advises the Staff that it is duly noted that Item 16I(b) requires that the Company provide disclosures for itself and all of its
consolidated foreign operating entities, including variable interest entities or similar structures.

 · With respect to (b)(2), the Company
                                            respectfully advises the Staff that, the jurisdictions in which the Company’s consolidated
                                            foreign operating entities (i.e., its subsidiaries and the VIE) are organized or incorporated
                                            include mainland China, Hong Kong and the British Virgin Islands. The Company respectfully
                                            further advises the Staff that, to the Company’s best knowledge and based on its examination
                                            of the register of members, register of shareholders or other equivalent document(s) of
                                            each of the Company, subsidiaries of the Company and the VIE, public filings made by the
                                            Company’s shareholders, particularly the Schedule 13Ds and Schedule 13Gs, and to the
                                            extent reachable practically, written confirmations from the shareholders of the Company
                                            and the VIE, as of the date hereof, governmental entities in the jurisdictions in which the
                                            Company, subsidiaries of the Company and the VIE are incorporated or otherwise organized,
                                            including the Cayman Islands, mainland China, Hong Kong and the British Virgin Islands, hold
                                            no shares in the Company, subsidiaries of the Company or the VIE.

 · With respect to (b)(3), the Company
                                            respectfully advises the Staff that, to the Company’s best knowledge and based on its
                                            examination of the register of members, register of shareholders or other equivalent document(s) of
                                            each of the Company, subsidiaries of the Company and the VIE, public filings made by the
                                            Company's shareholders, particularly the Schedule 13Ds and Schedule 13Gs, and to the extent
                                            reachable practically, written confirmations from the shareholders of the Company and the
                                            VIE, as of the date hereof, Chinese governmental entities have no controlling financial interest
                                            in the Company, subsidiaries of the Company or the VIE.

September 15, 2023 - Page 4

 · With respect to (b)(4), the Company
                                            respectfully advises the Staff that, to the Company’s best knowledge and based on its
                                            examination of the register of directors or other equivalent document(s) of each of
                                            the Company, subsidiaries of the Company and the VIE and the written confirmation of each
                                            director of the Company, subsidiaries of the Company and the VIE, as of the date hereof,
                                            none of the directors of the Company, subsidiaries of the Company and the VIE are officials
                                            of the Chinese Communist Party, provided however that, for sake of complete disclosure, the
                                            Company would like to respectfully advises the Staff that Zhilei Tong, a director of the
                                            Company, is a member of the Chinese Communist Party.

 · With respect to (b)(5), the Company
                                            respectfully advises the Staff that, as of the date hereof, the memorandum and articles of
                                            association (or articles of association, as applicable) of each of the Company, subsidiaries
                                            of the Company and the VIE contain no charter of the Chinese Communist Party, including the
                                            text of any such charter.

 3. In order to clarify
                                            the scope of your review, please supplementally describe the steps you have taken to confirm
                                            that none of the members of your board or the boards of your consolidated foreign operating
                                            entities are officials of the Chinese Communist Party. For instance, please tell us how the
                                            board members’ current or prior memberships on, or affiliations with, committees of
                                            the Chinese Communist Party factored into your determination. In addition, please tell us
                                            whether you have relied upon third party certifications such as affidavits as the basis for
                                            your disclosure.

The Company respectfully
advises the Staff that, after the Company’s examination of the register of directors or other equivalent document(s) of each
of the Company, subsidiaries of the Company and the VIE, it has confirmed in writing with each director of the Company, subsidiaries
of the Company and the VIE whether, during their terms of office, they are, were or have been, or act as, acted as or have acted as,
an official of the Chinese Communist Party or a member of any committee or similar organization of the Chinese Communist Party, or an
officer of Chinese government. To the Company’s best knowledge and based on its examination of the register of directors or other
equivalent document(s) of each of the Company, subsidiaries of the Company and the VIE and the written confirmation of each director
of the Company, subsidiaries of the Company and the VIE, as of the date hereof, none of the directors of the Company, subsidiaries of
the Company and the VIE are officials of the Chinese Communist Party, provided however that, for sake of complete disclosure, the Company
would like to respectfully advises the Staff that, Zhilei Tong, a director of the Company, is a member of the Chinese Communist Party.
The Company has relied upon the written confirmation of each director of the Company, subsidiaries of the Company and the VIE and has
not relied upon other third party certifications such as affidavits as the basis for such response.

September 15, 2023 - Page 5

 4. With respect to your
                                            disclosure pursuant to Item 16I(b)(5), we note that you have included language that such
                                            disclosure is “to our best knowledge.” Please supplementally confirm without
                                            qualification, if true, that your articles and the art