SecProbe.io

August 12, 2024
Naijiang (Eric) Zhou
Chief Financial Officer
Xunlei Ltd
3709 Baishi Road, Nanshan District, Shenzhen, 518000
The People’s Republic of China
Re:Xunlei Ltd
Form 20-F for the fiscal year ended December 31, 2023
Response dated June 20, 2024
File No. 001-35224
Dear Naijiang (Eric) Zhou:
            We have reviewed your June 20, 2024 response to our comment letter and have the
following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless we
note otherwise, any references to prior comments are to comments in our June 5, 2024 letter.
Form 20-F for the fiscal year ended December 31, 2023
Note 2. Summary of significant accounting policies
(k) Goodwill, page F-19
1.We note your response to prior comment one. Please address the following as it relates to
the reconciliation from the business enterprise value to the fair value of the Xunlei RU:
•Explain in detail how you determined that the Net Cash adjustment was
appropriate. Also, describe how you determined the amount of operating cash and
why such amount was appropriate.
•Clarify whether some or all of the Net Cash amount will be used in operations over
the span of your discounted cash flow model.
•Clarify whether there are any obligations that are on the balance sheet but that are not
incorporated in your calculation of business enterprise value.
•Provide a break down of the components that comprise the non-operating
assets/liabilities (excluding short-term investments) adjustment.

August 12, 2024
Page 2
2.We note your reconciliation to market capitalization as of December 31, 2023 provided in
response to prior comment one. Please explain your basis for including the Net Cash
adjustment in this reconciliation and explain how you concluded that the market
capitalization does not already reflect some or all of the $236M Net Cash adjustment. In
this regard, tell us your consideration of whether a market participant would be aware of
the amount of Net Cash given that a majority of the components are reflected on the
balance sheet.
            Please contact Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Haiping Li