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August 29, 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 reviewed your July 25, 2023 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
June 27, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.Your response to prior comment 8 states that the Company is not an investment company
as defined in the Investment Company Act of 1940, as amended (the “Company Act”).
Please address the following in order to support your Company Act position:

•Please provide a legal analysis supporting your position that the Company’s variable
interest entities (“VIEs”) qualify as majority-owned subsidiaries for purposes of
sections 3(a)(2) and 3(a)(1)(C) of the Company Act, as such term is defined in
section 2(a)(24) of the Company Act.

 FirstName LastNameQuan Long
 Comapany NameAutohome Inc.
 August 29, 2023 Page 2
 FirstName LastNameQuan Long
Autohome Inc.
August 29, 2023
Page 2
•You state that the Company’s only investment securities are “long-term investment in
certain majority-owned subsidiaries and interests in VIEs that fall under the definition
of investment companies under the ICA.”  Please clarify how you treat the
Company’s short-term investments for purposes of your Company Act analysis,
including “adjustable-rate financial products with original maturities of less than 1
year”.
•Please provide additional legal analysis supporting your proposed treatment of “time
deposits” as “cash” for purposes of your Company Act analysis and explain the
difference between “time deposits” and “term deposits,” as referenced in your 2022
Form 20-F.
•Your response notes that the value of the Company’s investment or interests in
certain companies are “determined in accordance with U.S. GAAP…”  Please
confirm whether the assets are valued in accordance with Section 2(a)(41) of the
Company Act. If not, please update your analysis to reflect assets valued consistent
with Section 2(a)(41) of the Company Act.
•Please also confirm whether any of the Company’s majority-owned subsidiaries or
VIEs rely on an exception from the definition of investment in section 3(c)(1) or
section 3(c)(7) of the Company Act and whether this affects your Company Act
analysis.
•Please expand your legal analysis to substantiate your assertion that Beijing
Prbrownies Software Co., Ltd. (“Beijing Prbrownies”) is eligible for the exemption
provided by Rule 3a-8 under the Company Act.  In doing so, please specifically
discuss: (i) what comprises the Company’s “capital preservation investments” and
“research and development expenses”; (ii) whether Beijing Prbrownies has a board of
directors, and if yes, whether that board has adopted a written investment policy with
respect to Beijing Prbrownies’ capital preservation investments; and (iii) whether the
percentages are determined in accordance with the requirements in Rule 3a-8(b)(2).
•Please clarify the statement in your response that Beijing Prbrownies “did not engage
in the business of investing, reinvesting, owning, holding, or trading in securities.”

Please update your investment company status analysis to reflect the above comments as
necessary. Please confirm whether you still believe that the Company is not an investment
company as defined in the Company Act.
2.We note your proposed risk factor regarding the Company’s status under the Company
Act, provided in response to prior comment 9. If the Company’s status depends on the
ability of one of the Company’s subsidiaries (Beijing Prbrownies Software Co., Ltd.) to
rely on Rule 3a-8 under the Company Act, please update your risk factor to reflect this
material fact. Please also confirm that the Company will reevaluate the inclusion of the
risk factor periodically based on the Company’s assets and investment securities at the
time of any future filing.

 FirstName LastNameQuan Long
 Comapany NameAutohome Inc.
 August 29, 2023 Page 3
 FirstName LastName
Quan Long
Autohome Inc.
August 29, 2023
Page 3
            You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Christine
Dietz, Senior Staff Accountant at 202-551-3408 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology