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        March 14, 2018
Ms.Barbara C. Jacobs
Ms.Folake Ayoola Mr. Craig Wilson
Ms. Melissa Walsh
Division of Corporation Finance
Securities and Ex change Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: HUYA, Inc. (CIK No. 0001728190)
Response to the Staff’s Comments on the Draft
Registration Statement on Form F-1 Confidentially Submitted
Feb ruary 1, 2018
Dear Ms.Jacobs, Ms.Ayoola, Mr.Wilson and Ms.Walsh:
On behalf of our client, HUY A, Inc., a foreign private issuer organized under the laws of the Cayman Islands
(the “ Company ”), we submit to the staff (the “Staff”) of the Securities and Ex change Commission (the
“Commis s ion ”) this letter setting forth the Company’s responses to the comments contained in the Staff’s letter
dated February28, 2018 on the Company’s draft registration statement on Form F-1 confidentially submitted on
February 1, 2018 (the “ Draft Registration Statement ”).

Securities and Ex change Commission
March 14, 2018
Page 2
Concurrently with the submission of this letter, the Company is submitting a revised draft registration
statement on Form F-1 (the “ Revised Draft Registration Statement ”) and certain ex hibits via EDGAR to the
Commission for confidential non-public review pursuant to the Jumpstart Our Business Startups Act, as amended. I n
addition to adding ad revising disclosure in response to Staff’s comments, the Company has updated the Revised Draft Registration Statement to include its audited consolidated financial statements for the fiscal year ended
December 31, 2017 and related financial information.
To facilitate the Staff’s review, we have separately delivered to the Staff today five courtesy copies of the
Revised Draft Registration Statement, marked to show changes to the Draft Registration Statement and two copies
of the submitted ex hibits.
The Staff’s comments are repeated below in bold and are followed by the Company’s responses. We have
included page references in the Revised Draft Registration Statement where the language addressing a particular
comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Revised Draft Registration Statement.
AnnexA attached hereto includes an index that sets forth the relevant portions of the industry and market data
from the Frost & Sullivan Report and page numbers of the Revised Draft Registration Statement where such information appears, with cross-references to marked copy of the Frost & Sullivan Report, and a copy of the Frost &
Sullivan report with annotations marking the specific language that supports each relevant statement in the Revised
Draft Registration Statement.
Prospectus Summary, page 1
1. You state that the prospectus contains information from a report commissioned by you and prepared by
Frost & Sulliv an. Please rev ise to prov ide the date of the Frost& Sulliv an Report and prov ide us w ith a copy for our rev iew. Clearly mark the specific language in the supporting materials that supports each
statement in the prospectus.
In response to the Staff’s comment, the Company has revised the disclosure on page 1 of the Revised Draft
Registration Statement.
The Company also encloses as Annex  A which includes an index  that sets forth the relevant portions of the
industry and market data from the Frost & Sullivan Report and page numbers of the Revised Draft Registration Statement where such information appears, with cross-references to marked copy of the Frost &
Sullivan Report, and a copy of the Frost & Sullivan Report.
Securities and Ex change Commission March 14, 2018 Page 3
Our Business, page 1
2. You state that you are the No. 1 game liv e streaming platform in China and you hav e the largest and
most active game live streaming community in terms of average MAUs, average DAUs, and average daily
time spent per active user in the fourth quarter of 2017. Please revise to provide your ranking in the prior comparativ e period to prov ide context.
In response to the Staff’s comment, the Company has revised the disclosure on pages 1, 84, and 116 of the
Revised Draft Registration Statement.

3. You state that, as of December 31, 2017, your liv e streaming content cov ered ov er 2,600 different games,
including mobile, PC and console games. Please rev ise to prov ide the data for the same period in 2016.
In response to the Staff’s comment, the Company has revised the disclosure on pages 1, 84, 116, 118 and 121
of the Revised Draft Registration Statement.
Corporate History and Structure, page 4
4. Please rev ise to prov ide an organizational chart depicting your corporate structure before and after the
offering.
In response to the Staff’s comment, the Company has revised the disclosure on pages 5, 6, 77 and 78 of the
Revised Draft Registration Statement.
Risk F actors
As our patents may expire and may not be extended, page 25
5. You state on page 135 that a patent is valid for a twenty-year term for an invention and a ten-year term
for a utility model or design, starting from the application date. We note your disclosure on page 153 that
you obtained an exclusiv e and royalty-free license from Guangzhou Huaduo to use 39 patents through
the respectiv e terms of such patents. To the extent there are pending expiration of material patents, please rev ise this risk factor toso state. Refer to Part I, Item 3.D of Form 20-F.
The Company respectfully advises the Staff that the earliest ex piration date of the patents owned by the
Company or licensed from Y Y  is in year 2024 and there is no pending ex piration of material patents.
Securities and Ex change Commission March 14, 2018
Page 4
If w e fail to maintain an effectiv e system of internal control ov er financial reporting..., page 28
6. Please revise this risk factor to clarify that you will not be required to provide an assessment of the
effectiv eness of your internal control ov er financial reporting until your second annual report after your
initial public offering and that an auditor attestation of management’s evaluation of effectiveness of the
internal controls is not required as long as you are an emerging growth company.
In response to the Staff’s comment, the Company has revised the disclosure on pages 31 and 32 of the Revised
Draft Registration Statement.
Use of Proceeds, page 63
7. You state that you plan to use the net proceeds of the offering primarily to expand and enhance your
product and serv ice offerings and strengthen your technologies, and to use the balance of the proceeds
for w orking capital and other general corporate purpose, including possibly prov iding funding to your
wholly foreign-owned subsidiary in China only through loans or capital contributions and to your
variable interest entity only through loans. Please revise your disclosure to disclose the estimated net
amount of the proceeds broken down into each principal intended use.
In response to the Staff’s comment, the Company has revised the disclosure on page 67 of the Revised Draft
Registration Statement.
M anagement’s Discussion and Analysis of Financial Condition and
Results of Operations Specific Factors Affecting Our Results of
Operations, page 79

8. We note that you disclose the follow ing information or key factors throughout your filing: the av erage
monthly active user, total monthly active user, average daily active user, total daily active user, average
daily time spent per active user, average mobile monthly active user, average mobile daily active user,
average monthly active broadcasters, average daily live streaming time, average number of times applications are opened per user per day, total number of active broadcasters, and total daily time spent
per activ e user. These appear to be important measures of your operating performance. In this regard,
we note your reference on page 23 to some of the terms as “key operating metrics.” Please rev ise your
disclosure to define what comprises, and how you compute, each of your performance metrics and, where
applicable, provide an enhanced quantitative and qualitative discussion and analyses of the changes in these metrics for each period presented or explain to us why you do not believ e these metrics contribute
meaningfully to understanding and ev aluating your company. We refer you to Part I, Items 5.A and 5.D
of Form 20-F and Section III.B of SEC Release 33-8350.
Securities and Ex change Commission March 14, 2018 Page 5
The Company respectfully advises the Staff that the Company believes the average MAUs and the average
mobile MAUs are material factors directly affecting the Company’s financial performance and results of
operations and the Company tracks and reviews theseoperating metrics to evaluate the performance of the
Company. In response to the Staff’s comments, the Company has revised page 8 of the Revised Draft
Registration Statement to define these metrics and ex plain their calculation methods and page 85 of the
Revised Draft Registration Statement to include qualitative and quantitative discussion on these metrics and
compare them for each period presented.
With respect to the average monthly active broadcasters and total streaming hours of broadcasters, the
Company believes such data do not directly attribute to the Company’s live streaming revenues as there are
many other factors that may have an impact on users’ spending such as the variety and quality of the content
streamed on our platform, but none of those factors alone would materially affect the Company’s ability to
generate live streaming revenues. Accordingly, the Company does not view such metrics as material factors or/and key operating metrics. Accordingly, the Company has deleted the relevant numbers in the discussion of
key factors affecting the results of operation on page 85 of the Revised Draft Registration Statement.
Likewise, the Company believes such data help investors understand the size of the content offering, which is an important strength of the Company and thus, the Company has disclosed such metrics when describing the
Company’s business. The Company has revised page 8 of the Revised Draft Registration Statement to define
average monthly active broadcaster and ex plain its calculation method.
With respect to the average daily time spent on mobile app per active user, the Company believes that
although such data does not directly affect the Company’s operating results, it highlights the level of user
engagement from the mobile app, which is an important strength and strategic focus of the Company. The
Company discloses such operating metric to help investors understand the nature of the Company’s platform
and user activity level. The Company has revised page 8 of the Revised Draft Registration Statement to define
average daily time spent on mobile app per active user and ex plain its calculation method. In addition, while the average daily time spent per active user support the Company’s industry leading position, the Company
does not believe this number would provide additional meaningful information to the investors given the
Company has disclosed the number of the average daily time spent on mobile app per active user.
Securities and Ex change Commission March 14, 2018 Page 6
With respect to the total MAUs, the Company believes it has already disclosed the number of the average
MAUs, which could be used to compute the total MAU, and thus disclosing the number of the total MAUs
would not be providing additional meaningful information to the investors.
With respect to DAUs including both the average DAUs and total DAUs, the Company believes that the
MAUs is a better measure of the user base at this early stage of the Company’s business development as

MAUs tends to be relatively stable from month to month whereas DAU s can be volatile. The Company also
believes that disclosing the number of MAUs, and not DAUs, is consistent with industry practice in general.
Therefore, while the average DAUs support the Company’s industry position, the Company believes
disclosing the number of DAUs would not be providing additional meaningful information to the investors.
The Company has also provided information about the average daily live streaming time and average number
of times applications are opened per user per days from Frost & Sullivan, to support the disclosure on the
industry overview and these two operating metrics do not directly correlate with the Company’s performance.
In addition, in response to the Staff’s comment, the Company has also revised the disclosure on page 8 of the
Revised Draft Registration Statement to add the definition and calculation methods of the relevant operating
metrics .
9. You indicate that monetization is driven by your ability to convert more users to paying users, as well as
your ability to increase the spending of your paying users. To supplement your disclosure of the increase in the number paying users, please rev ise to also prov ide a measure of the spending per paying user, such
as av erage rev enue per user, for each period presented. Refer to Part I, Item 5.A.1 of Form 20-F and
S ection III.B.1 of S EC Releas e 33-8350.
The Company respectfully advises the Staff that, as the Company is still at a relatively early stage of its
business development, the historical data of spending per paying user may not be a meaningful indicator of the Company’s monetization capability. In addition, the Company has disclosed the number of paying users and
the amount of live streaming revenues for the years of 2016 and 2017 and the fourth quarters of 2016 and 2017, and the spending per paying user can be calculated by dividing the live streaming revenues by the
number of the paying users. The Company also believes that not to use spending per paying user as a metric to
evaluate the Company’s financial results at this development stage is consistent with industry practice in
general. In light of the above, the Company does not intend to make detailed disclosure of such measure,
which does not provide additional meaningful information.
Securities and Ex change Commission March 14, 2018 Page 7
Results of Operations, page 81
10. Please rev ise to ensure that you prov ide a qualitativ e and quantitativ e analysis of each of the contributing
or offsetting factors that caused material changes in your results of operations. For example, describe the
reasons for the 200.9% increase in liv e streaming rev enues, other than the 138.3% increase in the number of paying users. Also, quantify the impact that the increase in sales of v irtual items and the
increase in the number of broadcasters each had on the increase in rev enue sharing fees and content
costs.
Similarly, quantify each of the factors identified as contributing to, and partially offsetting, the increase
in bandw idth costs. In addition, identify the factor(s) offsetting the one-off expense of RM B20.0 million to explain the RM B12.1 million netin crease in general and administrativ e expenses. Refer to Part I,
Item 5 of Form 20-F and Section III.D of SEC Release 33-6835.
The Company respectfully advises the Staff that the increase in the number of paying users is the primary
contributing