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February 24, 2023
Daniel Yong Zhang
Chairman and Chief Executive Officer
Alibaba Group Holding Ltd
26/F Tower One, Times Square
1 Matheson Street, Causeway Bay
Hong Kong
Re:Alibaba Group Holding Ltd
Form 20-F for Fiscal Year Ended March 31, 2022
Response Dated January 11, 2023
File No. 001-36614
Dear Daniel Yong Zhang:
            We have reviewed your January 11, 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
December 12, 2022 letter.
Response Dated January 11, 2023
Risk Factors
Summary of Risk Factors, page 1
1.We note your response to comment 6 and reissue in part.  We note your revisions in
Annex B to include specific cross-references to the more detailed discussion of the risks in
the annual report for bullets one and two.  However, please revise to include specific
cross-references (titles and page numbers) for all the risk factors discussed in this portion
of the risk factor summary.

 FirstName LastNameDaniel Yong Zhang
 Comapany NameAlibaba Group Holding Ltd
 February 24, 2023 Page 2
 FirstName LastName
Daniel Yong Zhang
Alibaba Group Holding Ltd
February 24, 2023
Page 2
Our business is subject to complex and evolving domestic and international laws and regulations
regarding privacy and data protection, page 23
2.We note your response to comment 7 and reissue.  In light of recent events indicating
greater oversight by the Cyberspace Administration of China (CAC) over data security,
please revise your risk factor disclosure to explain in greater detail how you believe this
oversight impacts the company and its business and to what extent you believe that you
are compliant with the regulations or policies that have been issued by the CAC to date.
In this regard, we note that the revised risk factor continues to generally describe the new
or proposed laws and regulations but doesn't evaluate how the company will actually be
impacted by the new or proposed laws and regulations.  Please revise to clarify and
specifically address if you believe you will be subject to a cybersecurity review under
these new or proposed laws and regulations.  To the extent you do not believe you will be
subject to a cybersecurity review, discuss specifically how you came to that conclusion
including the specific underlying facts and circumstances which support that
determination.  For example, the third paragraph discusses operators of critical
information infrastructure, network platform operators and data processors but doesn't
provide any analysis regarding whether the company will be captured by these new or
proposed laws and regulations based upon the company's number of users or the type of
data that the company collects.  Please revise as applicable so investors can clearly
understand how these new or proposed laws and regulations will impact the company and
its business and any future offerings.
            Please contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Daniel Fertig