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HUYA INC.

Building A3, E-Park

280 Hanxi Road

Panyu District, Guangzhou 511446

People’s Republic of China

March 22, 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 January 17, 2024

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 February 9, 2024 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 January 17, 2024 (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 Consolidated Financial Statements

Note 2. Principal Accounting Policies

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

 1. In
                                            your response letter dated January 17, 2024 (“response”), we note that you
                                            make reference to relying on Section 3(b)(1) of the Investment Company Act of 1940
                                            (“Investment Company Act”) in your analysis of several different entities, such
                                            as Tiger Information Technology Inc., Hainan Huya Entertainment Technology Co., Ltd.,
                                            and Foshan Huya Huxin Technology Co., Ltd. Please advise as to whether you have opinions
                                            of counsel regarding Section 3(b)(1) with regard to such entities and, if so, whether
                                            you are willing to share such opinions with the staff.

As noted in the Company’s prior
Correspondence dated January 17, 2024, the Company believes that the application of the Tonopah Factors as set forth in response
1 in the Correspondence and the applicable Appendices referenced therein applied to each of Tiger Information Technology Inc., Hainan
Huya Entertainment Technology Co., Ltd., and Foshan Huya Huxin Technology Co., Ltd., each of which is a subsidiary of the Company.
The Company has not obtained opinions of counsel regarding Section 3(b)(1) with regard to these subsidiaries.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

March 22, 2024

Page 2

 2. In
                                            your response, we note that you make reference to relying on Section 3(c)(1) and
                                            3(c)(7) of the Investment Company Act in your analysis of several different entities,
                                            such as 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). Under Section 3(a)(2) of the Investment Company
                                            Act, these assets would generally be investment securities in the hands of the applicable
                                            investing entity. Please confirm that your previous (and future) analysis under Section 3(a)(1)(C) did
                                            not, and will not, treat such investments as “investment securities.”

In response to the Staff’s comment,
the Company respectfully confirms that its previous and future analysis under Section 3(a)(1)(C) of the Investment Company
Act did and will treat the interests in the referenced subsidiaries as “investment securities” in accordance with the definition
of “investment securities” set forth in Section 3(a)(2) of the Investment Company Act, which excludes securities
of majority owned subsidiaries only if such subsidiaries are not investment companies, and are not relying on the exception from the
definition of investment company in paragraphs 3(c)(1) or 3(c)(7) of the Investment Company Act.

 3. Please
                                            provide for the staff’s review a draft risk factor disclosing risks related to the
                                            Company potentially operating as an “investment company” under the Investment
                                            Company Act. Please ensure that the risk factor, among other things, (i) discloses,
                                            with appropriate specificity, why the Company may be at risk of being considered an investment
                                            company and (ii) describes the consequences to the Company if it were deemed to be an
                                            unregistered investment company. Please ensure that the Company addresses, for example, the
                                            risk that the Company would be subject to penalties and that the Company could be unable
                                            to enforce certain contracts.

In response to the Staff’s comment, the Company respectfully
submits the following draft risk factor for the Staff’s review:

If the Company is deemed to
be an investment company under the United States Investment Company Act of 1940, as amended, it may be required to institute burdensome
compliance requirements and its activities may be restricted.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

March 22, 2024

Page 3

We do not believe that we are an “investment
company” and we do not intend to become registered as an “investment company” under the United States Investment Company
Act of 1940, as amended, or the Investment Company Act. Certain of our assets and our future holdings may be deemed to be “investment
securities” within the meaning of the Investment Company Act. Under the Investment Company Act, a company is deemed to be an “investment
company” if it (i) is engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, owning,
holding or trading in securities or (ii) owns or proposes to acquire investment securities having a value exceeding 40% of the value
of the company’s total assets (exclusive of government securities and cash items) on an unconsolidated basis. On a consolidated
basis, a significant portion of our present assets as of December 31, 2023 consists of time deposits held for cash management purposes,
which may be deemed to be“ investment securities” within the meaning of the Investment Company Act. However, we do not hold
ourselves out as being primarily engaged, or proposing to engage primarily, in the business of investing, reinvesting or trading in securities.
Rather, we are primarily engaged in the business of providing online live streaming platforms and related services.

We seek to conduct our operations
so that we do not meet the definition of an “investment company” under the Investment Company Act. Doing so may require us
to forego potential future acquisitions of interests in companies that may be deemed to be “investment securities” within
the meaning of the Investment Company Act. If we are unable to structure or operate our business in a manner that avoids investment company
status under the Investment Company Act, we may be deemed to be an investment company within the meaning of the Investment Company Act.
As a foreign private issuer, we would not be eligible to register under the Investment Company Act unless the SEC issued an order permitting
us to do so. As a result, if we are deemed to be an investment company within the meaning of the Investment Company Act, we would either
have to obtain exemptive relief from the SEC or dispose of investment securities in order to fall outside the definition of an investment
company. Failure to avoid being deemed an investment company under the Investment Company Act, coupled with our inability as a foreign
private issuer to register under the Investment Company Act, could make us unable to comply with our reporting obligations as a public
company in the United States and lead to our being delisted from the New York Stock Exchange, which would materially and adversely affect
the liquidity and value of the ADSs. We would also be unable to raise capital through the sale of securities in the United States or
to conduct business in the United States. Moreover, if we were deemed to be an investment company under the Investment Company Act and
not exempted from the application of the Investment Company Act, contracts we enter into in violation of, or the performance of which
entails a violation of, the Investment Company Act, including any securities sold in the United States or to U.S. persons, may not be
enforceable against us. In addition, we may be subject to SEC enforcement action or purported class action lawsuits for alleged violations
of U.S. securities laws. Defending ourselves against any such enforcement action or lawsuits would require significant attention from
our management and divert resources from our existing businesses and could materially and adversely affect our business, results of operations,
and financial condition.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

March 22, 2024

Page 4

 4. In
                                            response to staff’s prior comment 1, we note the discussion of “Sources of Income”
                                            in Appendix B. Please update the discussion of “Sources of Income” to reflect
                                            the Company’s and its wholly-owned subsidiaries’ assets on a consolidated basis
                                            as of the most recent fiscal quarter end.

For the Staff’s reference, the
Company is submitting, under a separate cover and on a confidential, supplemental basis, an updated discussion of “Source of Income”
to reflect the status as of the most recent fiscal quarter end, as part of the 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”).

 5. More
                                            generally, in your response, we note that you use factual information and data as of September 30,
                                            2023, per the staff’s previous request. Please update all previous data and analysis
                                            to reflect the most recent fiscal quarter end. Alternatively, please advise the staff whether
                                            there were any changes between September 30, 2023 and the most recent fiscal quarter
                                            end that would materially impact the investment company analysis previously provided.

For the Staff’s reference, the Company is submitting
an updated discussion of the analysis previously performed in the Supplemental Submission to reflect the status of the Company and each
of its subsidiaries as of the most recent fiscal quarter end.

 6. We
                                            note your response to the staff’s prior comment 4 regarding value of the VIE. Based
                                            on the information provided, we do not necessarily agree with your view that the book value
                                            of the VIE reflects fair value consistent with section 2(a)(41) of the Investment Company
                                            Act. In addition, your response to prior comment 4 references Accounting Series Release
                                            (“ASR”) No. 113, Financial Reporting Codification (CCH) §404.04 (Oct. 21,
                                            1969) and ASR No. 118, Financial Reporting Codification (CCH) §404.03 (Dec.23,
                                            1970). However, ASR 113 and ASR 118 have been rescinded in their entirety. See Good Faith
                                            Determinations of Fair Value, SEC Investment Company Act Rel. No. 34128 (Dec. 3,
                                            2020). Please ensure that, going forward, the Company values the VIE in a manner consistent
                                            with the Investment Company Act. Please confirm your understanding of the foregoing.

For purposes of Section 3(a)(1)(C) of the Investment
Company Act, the Company confirms that it will value the VIE in a manner consistent with the Investment Company Act.

Division of Corporation Finance

Office of Technology

Securities
and Exchange Commission

March 22, 2024

Page 5

 7. The
                                            Company’s response states that, as of September 30, 2023, a very significant portion
                                            of the Company’s assets on a consolidated basis consisted of time deposits. The response
                                            to Staff’s prior comment 5 indicates that the Company has maintained such significant
                                            holdings in time deposits for “cash management purposes” and further states that
                                            “the purpose of such investments [in time deposits] is to ensure the availability of
                                            cash for essential resources and services required for the Company’s ongoing operations.”
                                            However, the response also notes that the Company uses time deposits “to seek to preserve
                                            the value of [its holdings] in the current inflationary environment.”

 a. Please
                                            provide further analysis as to how the Company’s very significant holdings in “short-term
                                            time deposits,” which carry maturity dates of up to one year, are consistent with the
                                            statement that the Company’s holdings in time deposits are tantamount to “cash
                                            holdings” for “essential resources and services required for the Company’s
                                            ongoing operations,” particularly in light of the availability of more liquid investments.

The
Company manages its short-term deposits in part through the use of staggered maturities to ensure that such deposits are available for
redemption in connection with the Company’s cash needs in order to ensure the availability of essential resources and services
required for the Company’s ongoing operations while utilizing such time deposits to preserve the value of its cash holdings. For
example, as of December 31, 2023, the Company held RMB1,865,713,000 in time deposits with a remaining maturity of three months or
less and RMB7,538,739,800 in time deposits with a remaining maturity greater than three months. These