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August 8, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
Response letter dated July 21, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have reviewed your July 21, 2023 response to our comment letter.  In order to help us
more fully evaluate your responses to prior comments 1 and 2 regarding the Investment
Company Act of 1940 (the “Investment Company Act”), we have the following comments.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
July 7, 2023 letter.
Response letter dated July 21, 2023
Item 3. Key Information, page 3
1.Please update your analysis under Section 3(a)(1)(A) and 3(a)(1)(C) of the Investment
Company Act to account for information as of the most recent fiscal quarter end.
2.Thank you for your detailed legal analysis regarding whether the Company meets the
definition of an “investment company” under Section 3(a)(1)(A) of the Investment
Company Act. However, in our prior questions, we also asked that you also provide a
similarly detailed response regarding whether each of the Company’s subsidiaries meets
the definition of an “investment company” under Section 3(a)(1)(A) of the Investment

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 August 8, 2023 Page 2
 FirstName LastName
Shan-Nen  Bong
Aurora Mobile Limited
August 8, 2023
Page 2
Company Act. Please provide that analysis and, in your response, please address, in detail,
each of the factors outlined in Tonapah Mining Company of Nevada, 26 SEC 426 (1947)
and provide legal and factual support for your analysis of each such factor as they apply to
each of the Company’s subsidiaries.
3.While we appreciate the summary calculations you provided in Appendix A of your
response letter, the staff’s question specifically asked that the Company identify each
constituent part of the numerators and denominators when performing your analysis under
section 3(a)(1)(C) of the Investment Company Act. Accordingly, please provide all
relevant calculations under Section 3(a)(1)(C), identifying and describing each constituent
part of the numerators and denominators for UA Mobile Limited, KK Mobile Limited,
and JPush Information Consultation (Shenzhen) Co., Ltd. In doing so, please (i)
specifically describe the types of assets included within “cash and cash equivalents,”
“long-term investments” and “short-term investments” on your balance sheet and (ii)
describe and discuss their proposed treatment for purposes of section 3(a)(1)(C), as well
as any other substantive determinations and/or characterizations of assets that are material
to your calculations.
            You may contact Becky Chow, Staff Accountant at 202-551-6524, or Stephen Krikorian,
Accounting Branch Chief, at 202-551-3488 if you have questions regarding comments on the
financial statements and related matters. Please contact Austin Pattan, Staff Attorney, at 202-
551-6756, or Larry Spirgel, Office Chief, at 202-551-3815 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology