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CORRESP
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CORRESP

 Cheetah Mobile Inc.

Building No. 8, Hui Tong Times Square

Yaojiayuan South Road

 Beijing 100123

 People’s Republic of China

 December 5, 2019

VIA EDGAR

 Kathryn Jacobson, Senior Staff Accountant

 Christine Dietz, Senior Staff Accountant

 Division of
Corporation Finance

 Office of Technology

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

Re:

 Cheetah Mobile Inc. (the “Company”)

Form 20-F for Fiscal Year Ended December 31, 2018

Filed on April 26, 2019

File No. 001-36427

 Dear Ms. Jacobson and Ms. Dietz:

This letter sets forth the Company’s responses to the comments contained in the letter dated November 21, 2019 from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s Form 20-F for the fiscal year ended December 31, 2018 (the
“2018 Form 20-F”). The Staff’s comments are repeated below in bold and are followed by the Company’s responses thereto. All capitalized terms used but not defined in this letter
shall have the meaning ascribed to such terms in the 2018 Form 20-F.

 Form
20-F for the Fiscal Year Ended December 31, 2018

 Item 5. Operating and Financial Review and Prospects

 A. Operating Results

 Year Ended
December 31, 2018 Compared to Year Ended December 31, 2017, page 101

1.
 We note that revenues from utility products and related services have significantly declined since 2016 and
declines continue into 2019. Please expand your disclosure, qualitatively and quantitatively, to address the major factors that contributed to the contraction in your utility products business, including but not limited to the loss of customers, the
suspension or removal of certain popular apps as a result of certain third party allegations, and softening of advertising demand. Also, please disclose whether you expect these trends will continue to impact your results of operations. As part of
your response, please tell us what consideration was given to separately disclosing the advertising revenues included in utility products and related services and mobile entertainment revenue to provide more visibility to investors into advertising
revenue trends. Please refer to Section III.D of SEC Release 33-6835 and Section III.B. of SEC Release 33-8350.

 In response to the Staff’s comment, the Company undertakes to make qualitative and
quantitative disclosure in future filings of annual report on Form 20-F about the major factors contributing to the contraction in the Company’s utility products business. As an illustration, the Company
proposes to revise the Utility products and related services section in the Company’s 2019 Form 20-F as follows. The Company may update the disclosure in the actual filing to reflect the
then-current factual circumstance and expectation of the Company.

 Utility products and related services. Revenues from utility
products and related services decreased by 6.7% year over year to RMB3,119.5 million (US$453.7 million) in 2018. The decrease was primarily due to (i) a decline in PC-related revenues and (ii) a
decline in the Company’s mobile utility product business in the overseas market. In 2017 and 2018, approximately 93% of the Company’s revenues from the utility products and related services were generated from advertising, and the rest of
the revenues were generated from miscellaneous items such as the sale of anti-virus and office application software.

 As internet traffic
in China continues to migrate from PC to mobile devices, PC-related revenues decreased by 7.0% year over year to RMB580.0 million in 2018. Revenues from our mobile utility product business in the overseas
markets decreased by 30.5% year over year to RMB1,268.5 million in 2018. In the overseas markets, certain advertising formats, such as ads on mobile phone lock screens, had been discontinued by Facebook and Google in 2017 and 2018,
respectively. In December 2018, our collaborations with some third-party advertising platforms, such as Facebook, were suspended, which had a negative impact on our overseas advertising revenues in the following months. The Company has been in
discussion with some of these platforms to resume business relationship. In the domestic market, fluctuations in China’s online advertising market may also affect our revenues from the mobile utility products and related services business in
China, which in turn affect our revenue on utility products and related services. We expect the above factors to continue affecting our revenues from the utility products and related services.

In addition, the Company proposes to revise the Mobile Entertainment Business Section in the Company’s 2019 Form 20-F as follows:

 Mobile entertainment services. Revenues from mobile entertainment services
increased by 19.0% year over year to RMB1,778.9 million (US$258.7 million) in 2018, mostly driven by the growth of our mobile game operations. In 2017 and 2018, approximately 36% of the revenues from the mobile entertainment business were
generated from advertising on mobile game business and the remaining revenues were generated from in-game purchase from the mobile game business and virtual gifts from the LiveMe business.

The Company respectfully advises the Staff that none of the Company’s popular apps were suspended or removed from Google Play or App Store
in 2018 and the first nine months of 2019. There was only one app named File Manager that was removed by Google Play. File Manager’s revenue contribution to the Company’s total revenue was immaterial.

 2

 Critical Accounting Policy

Goodwill, page 108

2.
 Please tell us how you considered the qualitative factors outlined in ASC 350-20-35-3C when performing your goodwill impairment analysis and clarify whether you performed a qualitative or quantitative assessment, or both. Please tell us the
percentage by which the fair value exceeded the carrying value for your reporting units. To the extent any reporting unit is at risk of failing step one of the goodwill impairment test, please disclose the percentage by which the fair value exceeded
the carrying value as of the date of the most recent test and describe any potential events and/or changes in circumstances that could reasonably be expected to negatively affect any key assumptions. If you have determined that the estimated fair
value substantially exceeds the carrying value of your reporting units, please disclose such determination. Refer to Section V of SEC Release 33-8350.

The Company respectfully advises the Staff that the Company performed a qualitative assessment when performing the goodwill impairment
analysis, and determined that a quantitative assessment was not necessary. The Company respectfully advises the Staff that it has considered the following qualitative factors outlined in ASC 350-20-35-3C as of December 31, 2018 as below:

a. Macroeconomic condition such as a deterioration in general economic conditions, limitations on accessing capital, fluctuations in foreign
exchange rates, or other developments in equity and credit markets.

 For the Company’s domestic market, China’s National
Bureau of Statistics showed the Gross Domestic Products (“GDP”) increased by 6.6% in 2018 and was expected to see an increase of 6.2% for the year of 2019. For overseas market, World Economic Outlook showed that the GDP in the United
States increased by 2.9% in 2018, and was expected to see an increase of 2.5% in 2019, while the global economic growth for 2018 increased by 3.7% and was expected to increase by 3.2% in 2019. As of December 31, 2018, the macroeconomic
condition remained positive and there were no negative indicators such as a deterioration in general economic conditions, limitations on accessing capital, fluctuations in foreign exchange rates, or other developments in equity and credit markets,
etc.

 The Company also noticed the general negative impact from the ongoing trade tensions, but there were no specific regulations or
disputes resulting from the trade tensions in the industry that the Company operated in. As a result, the Company did not consider the ongoing trade tensions as a substantive negative macroeconomic indicator.

Overall, the Company believes that the macroeconomic conditions are conducive to the healthy development of the company’s businesses.

b. Industry and market considerations such as a deterioration in the environment in which an entity operates, an increased competitive
environment, a decline in market-dependent multiples or metrics (consider in both absolute terms and relative to peers), a change in the market for an entity’s products or services, or a regulatory or political development.

As of December 31, 2018, the Company primarily generates revenues from online advertising, mobile games and online live broadcasting.
Online advertising, particularly mobile advertising, has experienced an upward trend since 2015.

 3

 In 2018, the Company has seen softer than expected advertising demand and a more competitive
environment. As the Company’s major mobile products remain popular among users in the domestic market, the Company still expected its online advertising revenue to increase although such increase would be at a lower growth rate as compared with
the previous years. Moreover, the Company began cooperation with several domestic online advertising platforms and offline advertising agencies, to reach more users in the domestic market. As of December 31, 2018, the Company was confident to
repeat the success in both overseas and domestic markets. Moreover, the Company further expanded the scope of its mobile utility products beyond mission-critical utility apps, by adding personalized, AI-driven
and other new utility apps. The Company believes that its newly enriched product portfolio and robust user engagement has laid a solid foundation for our mobile utility product business in the domestic market and would offset China’s soft
online advertising market approaching the end of 2018.

 Mobile entertainment has been one of the industries that is thriving in recent
years. Consumer spending in mobile gaming exceeded other forms of gaming in the gaming industry in 2018, and was expected to represent 60% of the market share in 2019. Most notably, light casual games continued to gain popularity globally. Given the
nature of the light casual games, many non-game players became attracted and were converted to players. In addition, the market size of the live broadcasting overseas markets was expected to reach
US$10 billion in 2020 from US$1 billion in 2017, according to the industry report published by a 36kr, a well-known Chinese industry research institution.

The “General Data Protection Regulation” (“GDPR”) took effect in May 2018. Although stricter regulations brought
uncertainties to the business that the Company operated in and the Company would be required and committed in data protection, the management believed that the regulation would benefit the long term relationship between the application developer and
the users, and did not consider it a negative indicator.

 As of December 31, 2018, the Company was not aware of other negative
indicators such as a deterioration in the environment in which the Company operates, an increased competitive environment, a decline in market-dependent multiples or metrics, a change in the market for the Company’s products or services, or a
regulatory or political development.

 c. Cost factors such as increases in raw materials, labor, or other costs that have a negative
effect on earnings and cash flows.

 The Company did not identify any significant cost increases such as in raw materials, labor, or
other costs that would have a negative effect on its earnings and cash flows.

 d. Events affecting a reporting unit such as a change in
the composition or carrying amount of its net assets, a more-likely-than-not expectation of selling or disposing of all, or a portion, or a reporting unit, the testing for recoverability for a significant
asset group within a reporting unit, or recognition of a goodwill impairment loss in the financial statements of a subsidiary of a reporting unit.

As of December 31, 2018, there were no events affecting a reporting unit such as a change in the composition or carrying amount of its net
assets, a more-likely-than-not expectation of selling or disposing of all, or a portion, or a reporting unit, the testing for recoverability for a significant asset group within a reporting unit, or
recognition of a goodwill impairment loss in the financial statements of a subsidiary of a reporting unit, except for the allegations and class actions that had adversely impacted the utility products and related services reporting segment, which is
further discussed below.

 e. Overall financial performance such as negative or declining cash flows or a decline in actual or planned
revenue or earnings compared with actual and projected results of relevant prior periods.

 4

 The Company reported total revenues and operating income of RMB4,981.7 million and
RMB467.2 million, respectively, for the year ended December 31, 2018, slightly above the revenues and operating income of RMB4,974.8 million and RMB446.9 million, respectively, for the year ended December 31, 2017.
Therefore, the Company was in a steady upward trend in its financial performance. In addition, the Company generated RMB345.6 million of operating cash flows for the year ended December 31, 2018, as compared to the operating cash flows of
RMB625.6 million for the year ended December 2017. The difference in operating cash flows between 2017 and 2018 is mainly due to the timing of its working capital balance from its advertising agency business within its operating cycle, rather
than changes in the actual financial performance of the Company.

 f. Other relevant entity-specific events such
as changes in management, key personnel, strategy, or customers; contemplation of bankruptcy; or litigation.

 In November 2018, a third
party made certain allegations about some of the Company’s products. Although the Company has made a number of public statements to clarify the matter, these allegations did adversely impact the Company’s business, specifically, in the
overseas market of the utility products and related services reporting unit. In connection with these allegations, the Company and certain of its current and former officers have been named as defendants in a punitive securities class action filed
on November 30, 2018, which was purportedly brought on behalf of a class of persons who allegedly suffered damages as a result of their trading in the Company’s ADRs between April 21, 2015 and November 27, 2018. As of
December 31, 2018 and April 26, 2019, the date the Company filed its 2018 Form 20-F, the class action remained in its preliminary stages, and the Company was optimistic about the outcome.

In December 2018, one of the Company’s largest customers, Facebook, suspended its cooperation with us. As of December 31, 2018 and
April 26, 2019, the date the Company filed its 2018 Form 20-F, the Company believed that such suspension was temporary and its business relationships with Facebook would resume considering the ongoing
communications between the Company and Facebook, and the active remediating actions the Company has been taking as well as the Company’s historical cooperation experience with Facebook.

Despite of the uncertainty in the Company’s operations in the utility products and related services reporting unit in the overseas market,
the Company has been investing in the utility products and related services reporting unit in the China market, which has been showing a growing trend. As of December 31, 2018, the Company believed that the positive results in the domestic
market would mitigate the potential adverse impact on the operations in the overseas market.

 Other than the matters noted above, the
Co