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June 27, 2023
Quan Long
Chief Executive Officer
Autohome Inc.
18th Floor Tower B, CEC Plaza
3 Dan Ling Street
Haidian District, Beijing 10080
The People's Republic of China
Re:Autohome Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 25, 2023
File No. 001-36222
Dear Quan Long:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 3. Key Information, page 5
1.Please revise to clarify that all the legal and operational risks associated with having
operations in the People’s Republic of China (“PRC”) also apply to operations in Hong
Kong. In this regard, please ensure that your disclosure throughout the filing does not
narrow risks related to operating in the PRC to mainland China only. Where appropriate,
you may describe PRC law and then explain how law in Hong Kong differs from PRC law
and describe any risks and consequences to the company associated with those laws.
Also, please remove your disclosure on page 16 that the legal risks associated with being
based in and having operations in mainland China do not apply to entities or businesses in
Hong Kong.

 FirstName LastNameQuan Long
 Comapany NameAutohome Inc.
 June 27, 2023 Page 2
 FirstName LastName
Quan Long
Autohome Inc.
June 27, 2023
Page 2
Financial Information Related to the VIEs, page 11
2.We note the “Share of loss of VIEs” and “Investment in VIE” line item titles and your
explanation in footnote (1) on page 14 implies the VIE arrangements are similar to an
equity method investment.  As you have no direct relationship with the VIE or its
subsidiaries please revise these line items and footnote (1) to more appropriately describe
the nature of the amounts.
Item 4. Information on the Company
C. Organizational Structure, page 99
3.Please revise to include the diagram of your corporate organizational structure in the
forepart of the filing.
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 164
4.We note your statement that you reviewed your register of members in the Cayman
Islands and publicly available documents 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).
5.We note that your disclosure pursuant to paragraph (b)(2) is limited to “governmental
entities in the Cayman Islands or in China.” 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 confirm, if true, that you have disclosed 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. Alternatively, please provide this information in your supplemental
response.
6.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.

 FirstName LastNameQuan Long
 Comapany NameAutohome Inc.
 June 27, 2023 Page 3
 FirstName LastName
Quan Long
Autohome Inc.
June 27, 2023
Page 3
7.With respect to your disclosure pursuant to Item 16I(b)(5), we note that you have included
language that such disclosure is “to our knowledge.” Please supplementally confirm
without qualification, if true, that your articles and the articles of your consolidated
foreign operating entities do not contain wording from any charter of the Chinese
Communist Party.
General
8.We note your statement that Autohome Inc. is a holding company and you conduct all of
your business through your subsidiaries and the VIEs. Please provide us with a legal
analysis of whether you currently meet the definition of “investment company” under
Section 3(a)(1)(C) of the Investment Company Act (the “Company Act”). Please include
in your analysis the relevant calculation(s) under Section 3(a)(1)(C) (including, where
required by the statute, on an unconsolidated basis), identifying each constituent part of
the numerator(s) and denominator(s). Your analysis should identify and explain which
assets held by the company are “investment securities” for purposes of Section 3(a)(2) of
the Company Act, and specifically address how you treat the securities issued by your
subsidiaries and variable interest entities. Please provide legal support for any substantive
determinations and/or characterizations of assets that are material to your calculations.
9.Please include a risk factor that: (1) explains in detail why the company believes that it is
not an investment company for purposes of Section 3(a) the Company Act, with reference
to key material facts and characteristics of the business and the specific provisions of the
Company Act relevant to your conclusion; and (2) describes the consequences to the
company and its investors were the Commission or its Staff to determine that the company
is an investment company.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Kyle Wiley at (202) 334-5791 or Christopher Dunham at (202) 551-
3783 if you have any questions about comments related to your status as a Commission-
Identified Issuer during your most recently completed fiscal year. You may contact Megan Akst,
Senior Staff Accountant, at (202) 551-3407 or Christine Dietz, Senior Staff Accountant at (202)
551-3408 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology