SecProbe.io

Mail Stop 4561
October 3, 2016

Ka Wai Andy Yeung
Chief Financial Officer
Cheetah Mobile Inc.
Hui Tong Times Square
No. 8, Yaojiayuan South Road
Chaoyang District, Beijing 100123

Re: Cheetah Mobile Inc.
 Form 20-F for the Fiscal Year Ended December 31, 2015
Filed April 22, 2016
File No. 001 -36427

Dear Mr. Yeung :

We have  reviewed your September 6, 2016  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 th e 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 August 23,
2016  letter.

Notes to the Consolidated Financial Statements

Note 14. Geographical Information, page F -47

1. Given the limitations yo u describe in your response to prior comment 1 in quantifying
revenue generated from countries outside of the PRC, tell us your consideration for
disclosing qualitative information about the non -PRC revenue.  In this regard, it appears
from your response t hat the majority of your non -PRC revenue was generated from
businesses that primarily operate in the United States.  Tell us you consideration for
disclosing this in an effort to meet the objectives in ASC 280 -10 regarding the different
economic environmen ts in which you operate.

Ka Wai Andy Yeung
Cheetah Mobile Inc.
October 3, 2016
Page 2

 Item 19.   Exhibits, page 147

2. It is unclear from the information provided in response to prior comment 2 how you
concluded that the master agreement setting forth the standard terms with Customer E is
not required to be filed as a material contract pursuant to Item 601(b)(10)(ii)(B) of
Regulation S -K, when your contracts with this customer made pursuant to the standard
terms accounted for 29% of your total revenues for fiscal 2015.   In this regard, we note
from your response that the standard terms set forth the “general calculation of fees,”
which would appear to relate to material obligations of the customer.   Based on the
amount of revenues derived from Customer E, it continues to appear that you may be
substantially dependent o n this agreement.   Please provide further support for the
contention that you are not substantially dependent on the master agreement, or confirm
that you will file a copy of the agreement with your next Form 20 -F.  In addition, in
future filings to the ex tent applicable, please consider clearly identifying Customer E and
any other customers that account for such a significant percentage of your revenues and
disclosing the amount of revenues attributable to each such customer.

You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551 -3587, or Melissa
Kindelan , Staff Accountant , at (202) 551 -3564 , if you have questions regarding comments on the
financial statements and related matters.  If you have any other questions, pl ease contact Gabriel
Eckstein , Attorney -Advisor, at (202) 551 -3286 or Katherine Wray, Attorney -Advisor, at (202)
551-3483 .  If you require further assistance, do not hesitate  to contact me at (202) 551 -3499 .

Sincerely,

 /s/  Kathleen Collins

Kathleen Collins
Accounting Branch Chief
Office of Information Technologies
and Services

cc: Julie Gao, Esq.
      Skadden, Arps, Slate, Meagher & Flom LLP