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WRITER'S DIRECT DIAL

(852) 3551-8690

WRITER'S E-MAIL
ADDRESS

ning.zhang@morganlewis.com

October 17,
2023

VIA EDGAR

Mr. Kyle Wiley

Mr. Andrew Mew

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 is the Company’s response to your comment
letter dated September 22, 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 comment 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 comment from the Staff in bold and italic in front of the related response. All references in the Company’s
response 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

October 17,
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 response
                                            to prior comment to 3. We also note that you identified Zhilei Tong as a member of the CCP
                                            but determined that he is not a CCP official. We also note from Item 6 that Mr. Tong
                                            is the chairman and CEO of COL Digital Publishing Group Co., Ltd. and from COL Digital
                                            Publishing Group Co., Ltd. ’s company website he is currently listed as a Deputy
                                            to the People’s Congress in Beijing. Please explain to us his roles and responsibilities
                                            as a Deputy and how you consider them in your determination.

The Company respectfully
advises the Staff that, it understands that Zhilei Tong is currently a deputy to Beijing Municipal People’s Congress (i.e., the
people’s congress at municipal level), a member of the Education, Science, Culture and Health Committee of Beijing Municipal People’s
Congress, and a member of the Standing Committee of Dongcheng District People’s Congress of Beijing Municipality (i.e., the people’s
congress at district level, which is lower than municipal level), which positions we understand will not make Zhilei Tong an official
of the Chinese Communist Party.

According
to the Law of the People’s Republic of China on Deputies to the National People’s Congress and Local People’s
Congresses at All Levels, deputies to the local people’s congresses at all levels (including those at municipal level and district
level) are members of the state organs of power at the corresponding levels and shall be elected according to law, and shall represent
the interests and will of the people and participate in the exercise of state power based on the functions and powers vested in the people’s
congresses at the corresponding levels by the constitution and relevant laws. As a deputy, Zhilei Tong has the following rights, duties
and responsibilities:

Rights:

 ● attending
                                            sessions of the people’s congresses at the corresponding levels, participating in the
                                            deliberation of all bills and proposals, reports and other issues, and putting forward his
                                            opinions;

 ● jointly
                                            submitting bills and proposals, proposals for addressing inquiries, proposals of recall, etc.;

 ● putting
                                            forward proposals, criticisms and opinions concerning all aspects;

 ● participating
                                            in all elections held by the people’s congresses at the corresponding levels;

 ● participating
                                            in all votes held by the people’s congresses at the corresponding levels;

 ● obtaining
                                            the information and all kinds of assurances necessary for his performance of duties as a
                                            deputy; and

 ● other
                                            rights as prescribed by law.

Duties and responsibilities:

 ● playing
                                            an exemplary role in abiding by the constitution and the laws and in keeping state secrets
                                            and assisting the implementation of the constitution and the laws during the production,
                                            work or public activities which he takes part in;

October 17,
2023 - Page 3

 ● attending
                                            sessions of the people’s congresses at the corresponding levels on time, earnestly
                                            deliberating on all bills and proposals, reports and other issues, putting forward opinions
                                            and doing a good job in various work during the sessions;

 ● actively
                                            taking part in inspections, special surveys, law-enforcement inspections and other activities
                                            in relation to performance of his duties which are organized uniformly;

 ● strengthening
                                            the study, survey and research in relation to performance of his duties, and continuously
                                            enhancing his capacity of performing his duties as a deputy;

 ● maintaining
                                            close contact with the voters of the electoral districts or the electoral units that elected
                                            him and with the people, hearing and conveying their opinions and demands, and striving to
                                            serve the people;

 ● consciously
                                            abiding by social morality and being clean, self-disciplined, impartial, decent and diligent;
                                            and

 ● other
                                            duties as prescribed by law.

The Company respectfully
further advises the Staff that, the Company determined that the abovementioned positions will not make Zhilei Tong an official of the
Chinese Communist Party for the following reasons:

 ● according
                                            to the Constitution of the People's Republic of China, local people’s congresses
                                            at all levels (including those at municipal level and district level) are local state organs
                                            of power, which shall be created through democratic election and shall be responsible to
                                            the people and subject to their oversight, and thus local people’s congresses at all
                                            levels (including those at municipal level and district level) are not entities, organizations
                                            or organs of the Chinese Communist Party; and

 ● according
                                            to the Election Law of the People’s Republic of China for the National People’s
                                            Congress and the Local People’s Congresses at All Levels, all citizens of the People’s
                                            Republic of China who have reached the age of 18 shall have the right to vote and stand for
                                            election, regardless of ethnic status, race, sex, occupation, family background, religious
                                            belief, education, property status or length of residence, provided that those who have been
                                            deprived of political rights according to the laws shall not have the right to vote and stand
                                            for election, and thus Zhilei Tong’s election to the abovementioned positions was not
                                            based on nor has necessary connection with his membership in the Chinese Communist Party.

***

If you have any questions
or wish to discuss any matters with respect to this response letter, please do not hesitate to contact me at +852-3551-8690, or by email
at ning.zhang@morganlewis.com.

    Sincerely,

    /s/ Ning Zhang

    Mr. Ning Zhang

    of Morgan, Lewis & Bockius LLP

cc:
Mr. Ruobai Sima

ATA Creativity Global