SecProbe.io

Mail Room 4561
May 8, 2018

Rongjie Dong
Chief Executive Officer
HUYA , Inc.
Building B -1, North Block of Wanda Plaza,
No. 79 Wanbo 2nd Road,
Panyu District, Guangzhou 511442
The People’s Republic of China

Re: HUYA , Inc.
Amendment No. 1 to Registration Statement on Form F -1
Filed May 1,  2018
Amendment No. 2 to Registration Statement on Form F -1
Filed May 7, 2018
File No. 333-224202

Dear Mr. Dong:

We have reviewed your amended registration statement s 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 this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our April 24, 2018  letter .

Recent Developments, page 7

1. Please revise to provide an analysis of the statements of operations data  and key metrics
for the three months ended March 31, 2018, addressing how the trends compare to the
historical results in Management’s Discussion and Analysis of Financial Condition and
Results of Operations and the cause for material trend dissimilaritie s.  In this regard, you
indicate that these results may not be indicative of future results.  Ensure that you address
how the growth rates compare to your historical results.  In addition, disclose why only
partial information is provided.

Rongjie Dong
HUYA , Inc.
May 8, 2018
Page 2

 Summary Conso lidated Financial Data

Summary Consolidated Balance Sheet Data, page 13

2. In addition to the automatic conversion of such shares, it appears that the issuance and
sale of 64,488,235 series B -2 preferred shares to Linen Investment Limited in March
2018 is also included in the “Pro forma as adjusted” amounts.  Please revise to ind icate
that these amounts include the proceeds from such issuance and sale.  Please make
similar revisions throughout your filing to the explanation of the events reflected in pro
forma as adjusted amounts.

Risk Factors

We rely on contractual arrangement s with our PRC variable internet entity..., page 37

3. We note your response to our prior comment 2 .  Please revise your disclosure to  state that
the arbitration provisions relate to the claims arising out of the contractual relationship
created by the VIE agreements, rather than claims under the United States federal
securities laws and do not prevent shareholders of the Company from pursuing claims
under the United States federal securities laws.

Description of American Depositary Shares, page 179

4. We note your response to our prior comment 4 where you state that “the provisions
regarding arbitration only relate to claims arising out of or in connection with the
contractual relationship created by the deposit agreement.”   Please revise your disclosure
to clarify whether the waiver of the right to a jury trial applies to claims made under the
federal securities laws.   Additionally, please revise your disclosure here and in the risk
factor section on page 57  to clarify  that the deposit agreement does not relate to claims
under the federal securities laws.

Notes to the Consolidated Financial Statements

Note 23. Subsequent events, page F -53

5. You indicate in your discussion of recent developments on page 7 that net income for the
three months ended March 31, 2018  includes RMB11.9 million (US$1.9 million) in fair
value loss on derivative liabilities related to your preferred shares.  In your discussion of
the rights and privileges of your preferred shares upon the closing of the Tencent
Transaction, please revise to disclose the financial effect.  Refer to ASC 855 -10-50-2.

Rongjie Dong
HUYA , Inc.
May 8, 2018
Page 3

 You may contact Melissa Walsh, Staff Accountant, at (202) 551 -3224 or Craig Wilson,
Senior Assistant Chief Accountant at (202) 551 -3226 if you have questions regarding comments
on the  financial statements and related matters.  Please contact Folake Ayoola, Special Counsel,
at (202) 551 -3673 or me at (202) 551 -3735 with any other questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director, Office of
Information Technologies and
Services

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