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HUYA INC.

Building A3, E-Park

280 Hanxi Road

Panyu District, Guangzhou 511446

People’s Republic of China

January 17, 2024

VIA EDGAR

Mr. Stephen Krikorian

Mr. Morgan Youngwood

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 RE: HUYA Inc. (the “Company”)

Form 20-F for the Fiscal Year Ended December 31, 2022

Response dated September 28, 2023

File No. 001-38482

Dear Mr. Krikorian and Mr. Youngwood:

This letter sets forth the
Company’s responses to the comments contained in the letter dated November 3, 2023 from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission” or “SEC”) regarding the Company’s
annual report on Form 20-F for the fiscal year ended December 31, 2022 filed with the Commission on April 26, 2023 (the
 “2022 Form 20-F”) and the Company’s correspondence filed with the Commission on September 28, 2023
(the “Correspondence”). The Staff’s comments are repeated below in bold and 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 2022 Form 20-F
or the Correspondence.

Form 20-F for the Fiscal Year Ended
December 31, 2022

Consolidated Financial Statements

Notes to the Consolidated Financial Statements

Note 2. Principal Accounting Policies

(b) Short-term deposits and long-term
deposits, page F-22

 1. The staff notes the Company’s response to prior comment 10 regarding whether the Company and
its subsidiaries meet the definition of an “investment company” under Section 3(a)(1)(A) of the Investment Company
Act of 1940 (“Investment Company Act”).

 a. Please update the entire response to reflect factual and other information as of September 30, 2023 or the most recently available
fiscal quarter end.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

January 17, 2024

Page 2

 b. The response was not fully responsive to the staff’s question because it failed to discuss whether any of the Company’s
subsidiaries meets the definition of an “investment company” under Section 3(a)(1)(A). Please provide that analysis,
addressing, in detail, each of the factors outlined in Tonapah Mining Company of Nevada, 26 SEC 426 (1947) and providing legal and factual
support for your analysis of each such factor as they apply to each of the Company’s subsidiaries.

 c. We note your discussion under “Sources of Company’s Income” references percentages but does not indicate how
these percentages were calculated. Please provide the actual income amounts that support this calculation, along with any other relevant
factual information or assumptions.

 d. Please update the discussion of the “Nature of Present Assets” to reflect the Company’s assets on a consolidated
basis, and please provide detailed information supporting the manner in which the calculation is made.

Section 3(a)(1)(A) of the
Investment Company Act defines the term “investment company” to include any issuer which “is or holds itself out as
being engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, or trading in securities”
(emphasis added). The determination of an issuer’s primary business engagement requires a fact-specific inquiry. Over the years,
the SEC and the courts have developed a number of criteria to be used in determining whether a company is engaged primarily in a non-investment
business. The criteria applicable to nearly every situation are: (i) the company’s historical development; (ii) its public
representations of policy; (iii) the activities of its officers and directors; (iv) the sources of its present income; and (v) the
nature of its present assets (the “Tonopah Factors”).1

Although the SEC has not indicated how
much emphasis should be placed on any particular criterion, it has indicated that, in general, more significance should be placed on the
character of a company’s assets (as evidenced by the relative percentage of a company’s assets invested in operating businesses
(“operating assets”) versus investment instruments (“investment assets”)), and the sources of the
company’s present income (as evidenced by the relative percentage of the company’s income derived from operating assets versus
investment assets).2 However, other considerations may apply in the application of the foregoing factors, for example, a
company’s investment holdings may be based on such company’s need for cash for operations or acquisitions or other needs and
a desire to preserve the value of such cash. In general, SEC and court decisions indicate that if an applicant has demonstrated significant
activity in a non-investment business, a need for available capital, and the absence of public representations that it is in the investment
business, no registration is required.

 1 Tonopah Mining Co. of Nev., 26 S.E.C. 426, 427 (1947);
Certain Prima Facie Inv. Cos., Investment Company Act Release No. IC-10937, 18 S.E.C. Docket 948 (1979).

 2 Investment Company Act Release No. IC-10937, supra note
1; Tonopah, 26 S.E.C. at 427. But see SEC v. National Presto Industries, Inc. 486 F.D.A. 305 (7th Cir. 2007), in which
the Court rejected the assertion that the composition of a company’s assets is the most important of these five considerations;
rather, what is most important is whether the company’s “portfolio and activities [will] lead investors to treat a firm as
an investment vehicle or as an operating enterprise.”

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

January 17, 2024

Page 3

Because the Company does not hold itself
out to be an investment company, the relevant consideration is whether the Company is “primarily” engaged in the investment
business. For the Staff’s reference, the Company is submitting, under a separate cover and on a confidential, supplemental basis,
a detailed analysis of the application of the five Tonopah Factors to the Company and each of its subsidiaries as Appendix B
to the Company’s supplemental responses (the “Supplemental Submission”).

Based
on the analysis of the application of the five Tonopah Factors set forth in the Supplemental Submission, neither the Company nor
its subsidiaries, other than Happy Jungle Inc., Tiger Jungle Inc., HT Inc., Guangzhou Taige Investment Consulting Co., Ltd., Ningbo
Meishan Free Trade Port Area Chenhai Shangying Equity Investment Partnership (Limited Partnership), Ningbo Taiyuan Enterprise Management
Consulting Partnership (Limited Partnership) and Ningbo Taiheng Enterprise Management Consulting Partnership (Limited Partnership) (collectively,
the “Strategic Investment Subsidiaries”), is engaged in an investment company business, but rather each entity is primarily
engaged in the business of providing online live streaming platforms and related services.

While each of the Strategic Investment
Subsidiaries may be deemed to be engaged in an investment company business under Section 3(a)(1)(A) of the Investment Company
Act in support of the Company’s overall operating business, each such entity is exempt from registration as an investment company
under the Investment Company Act as described in the Company’s response to comment 3 below.

The analysis of the application of the
Tonopah Factors contained in Appendix B to Company’s Supplemental Submission reflects factual and other information
as of September 30, 2023, as requested in parts (a) and (b) of this comment 1. In addition, the Company has included each
entity’s actual income amounts and relevant factual information under the heading “Sources of the Company’s Income”
in Appendix B to the Company’s Supplemental Submission as requested in part (c) of this comment and has updated the
discussion under the heading “Nature of Present Assets” in Appendix B to the Company’s Supplemental Submission
to reflect the Company’s assets on a consolidated basis as requested in part (d) of this comment.

 2. Please clarify whether the corporate structure chart previously provided depicting the Company Group
is comprehensive and includes all the Company’s subsidiaries. In addition, further to comment 1 above, please ensure that your discussion
of “investment company” status under Section 3(a)(1)(A) and Section 3(a)(1)(C) of the Investment Company
Act addresses all subsidiaries.

The Company respectfully submits that the corporate structure
chart previously provided depicting the Company Group is comprehensive and includes all subsidiaries of the Company and the variable interest
entities validly existing as of June 30, 2023. For the Staff’s reference, the Company is submitting, under a separate cover
and on a confidential, supplemental basis, a corporate structure chart depicting all subsidiaries of the Company and the variable interest
entities validly existing as of September 30, 2023 as Appendix C to the Company’s Supplemental Submission.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

January 17, 2024

Page 4

 3. We note that the response to prior comment 11 states, in part, that “investment securities may
represent greater than 40% of the Adjusted Total Assets of certain of the Company’s subsidiaries.” Please provide information
regarding (i) whether each such subsidiary is registered, or intends to register, as an “investment company” under the
Investment Company Act or (ii) the exclusion or exemption from “investment company” status you believe such subsidiary
may be able to rely upon.

Investment securities represent greater than 40% of the Adjusted
Total Assets of the following subsidiaries: Tiger Jungle Inc., HT Inc., Tiger Information Technology Inc., Hainan Huya Entertainment Information
Technology Co., Ltd., Foshan Huya Huxin Technology Co., Ltd., Ningbo Taiheng Enterprise Management Consulting Partnership (Limited
Partnership), Ningbo Taiyuan Enterprise Management Consulting Partnership (Limited Partnership) and Ningbo Meishan Free Trade Port Area
Chenhai Shangying Equity Investment Partnership (Limited Partnership) (collectively, the “Applicable Subsidiaries”).
None of these entities are registered, and they will not be registered, as investment companies under the Investment Company Act because
the Applicable Subsidiaries are not required to be so registered.

Although investment securities constituted greater than 40%
of the Adjusted Total Assets of each of Tiger Information Technology Inc., Hainan Huya Entertainment Information Technology Co., Ltd.,
and Foshan Huya Huxin Technology Co., Ltd. as of September 30, 2023, they are each nonetheless not an investment company as
defined in the Investment Company Act by application of the Tonopah factors as discussed in the Company’s response to comment
1 above. None of Tiger Information Technology Inc., Hainan Huya Entertainment Information Technology Co., Ltd., or Foshan Huya Huxin
Technology Co., Ltd. holds itself out to be an investment company, and the activities of each of these subsidiaries in support of
the Company’s business, as described in the 2022 Form 20-F, demonstrates that it is a part of the Company’s primary operating
business of providing online live streaming platforms and related services and is not engaged in an investment business. Thus, even though
each of these subsidiaries’ Adjusted Total Assets consisted of greater than 40% of investment securities as of September 30,
2023 when calculated in accordance with Section 3(a)(1)(C), each of them is excepted from the Section 3(a)(1)(C) definition
of an investment company by Section 3(b)(1).

Although
investment securities constituted greater than 40% of the Adjusted Total Assets of each of Tiger Jungle Inc., HT Inc., Ningbo Taiheng
Enterprise Management Consulting Partnership (Limited Partnership), Ningbo Taiyuan Enterprise Management Consulting Partnership (Limited
Partnership) and Ningbo Meishan Free Trade Port Area Chenhai Shangying Equity Investment Partnership (Limited Partnership) for purposes
of Section 3(a)(1)(C) of the Investment Company Act as of September 30, 2023, they are exempt from registration pursuant
to Sections 3(c)(1), 3(c)(7) and/or 7(d) of the Investment Company Act despite that they are also Strategic Investment Subsidiaries.
Because none of Tiger Jungle Inc., HT Inc., Ningbo Taiheng Enterprise Management Consulting Partnership (Limited Partnership), Ningbo
Taiyuan Enterprise Management Consulting Partnership (Limited Partnership) and Ningbo Meishan Free Trade Port Area Chenhai Shangying Equity
Investment Partnership (Limited Partnership) are making, and none of them propose to make, a public offering of securities, and each of
their outstanding securities are beneficially owned by fewer than one hundred persons, each of them would be excepted from the definition
of an investment company pursuant to Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act. In addition,
each of Tiger Jungle Inc., HT Inc., Ningbo Taiheng Enterprise Management Consulting Partnership (Limited Partnership), Ningbo Taiyuan
Enterprise Management Consulting Partnership (Limited Partnership) and Ningbo Meishan Free Trade Port Area Chenhai Shangying Equity Investment
Partnership (Limited Partnership) would be prohibited from publicly offering, selling or delivering any securities in the United States
by use of the mails and means or instrumentalities of interstate commerce by Section 7(d) of the Investment Company Act.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

January 17, 2024

Page 5

Moreover, even if any of the Applicable Subsidiaries were
to be deemed an investment company under the Investment Company Act, it would nonetheless be exempt from registration under applicable
provisions of the Investment Company Act. None of the Applicable Subsidiaries publicly offer for sale their securities in any jurisdiction.
In addition, each Applicable Subsidiary is a direct or indirect wholly-owned subsidiary of the Company, beneficially owned by fewer than
one hundred persons. Furthermore, the Company notes that none of the Applicable Subsidiaries is a guarantor of any other company’s
outstanding securities.

 4. Please supplementally clarify how the wholly foreign-owned enterprise (“WFOE”) treats the
variable interest entity (“VIE”) for purposes of Section 3(a)(1)(C) and explain the rationale for this treatment.
More specifically, please discuss whether the WFOE treats its relationship with the VIE as comprising the applicable WFOE’s total
assets for purposes of Section 3(a)(1)(C) and, if so, how the Company is calculating the “value” of such amounts
for purposes of Section 2(a)(41) of the Investment Company Act.

Section 2(a)(43)
of the Investment Company Act defines “wholly-owned subsidiary” of a person as a company 95 per centum or more of the outstanding
voting securities of which are owned by such person, or by a company which, within the meaning of that paragraph, is a wholly-owned subsidiary
of such person. Section 2(a)(42) of the Investment Company Act defines “voting security” to mean, in pertinent
part, any security presently entitling the owner or holder thereof to vote for the election of directors of a company. This voting control
need not be held by reason of the ownership of securities; rather it may arise under a voting agreement.3
It is clear, reading Sections 2(a)(42) and 2(a)(43) of the Investment Company Act together, that a wholly-owned subsidiary is defined
with reference to the ability to elect a majority of its board of directors. Moreover, the courts and the Commission have taken the position
that the possessor of an economic interest in an issuer, such that the holder of the economic interest has the power to exercise control
over how the issuer is managed, is considered to hold the equivalent of a voting security.4

 3 See Farley,