SecProbe.io

January 2, 2025
Jun Liu
Vice President of Finance
PDD Holdings Inc.
First Floor, 25 St. Stephen’s Green
Dublin 2, D02 XF99
Ireland
Re:PDD Holdings Inc.
Form 20-F for Fiscal Year Ended December 31, 2023
Response dated September 30, 2024
File No. 001-38591
Dear Jun Liu:
            We have reviewed your filing and have the following comment(s).
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2023
Our Company, page 3
1.We note your response to comment 1. Please further revise your disclosure to clarify,
as you do in your response, that despite their differentiated geographical coverage,
Pinduoduo and Temu have the same value propositions and operational model, and
both platforms serve merchants in China.
2.You list your headquarters as Dublin, Ireland, yet it appears all of your operations and
customers are located in China. In addition, your Irish subsidiary appears to be a
holding company in your Temu line of business. Please clarify.
Risks Related to Our Multi-jurisdictional Operations, page 9
We note your revised disclosure in response to comment 9 and reissue our comment
in part. Pages 9 and 43 still include references to “multiple jurisdictions” with respect
to disclosure that was previously focused on risks related to the PRC government.
 3.

January 2, 2025
Page 2
Remove the mitigating language and discuss plainly and directly the risks relating to
doing business in China, separate from the risks you may face in other jurisdictions.
Directors and Senior Management, page 99
4.We note your response to comment 14. Please revise to include the information
provided in your response in your disclosure, including that the appointment of
Mr. Lei Chen as an executive director is unrelated to the PDD Partnership’s rights and
functions, and clarify how many limited partners are currently in the PDD Partnership.
Note 2. Summary of Significant Accounting Policies
(x) Segment Reporting, page F-23
5.We note your response to prior comment 16 and that your CODM regularly
reviews trends in operating metrics, revisits, assesses, and adjusts significant strategic
and operational matters, and makes resource adjustments as needed. You also indicate
certain financial information can be disaggregated. Please tell us:
•What financial information is provided to the CODM on a disaggregated basis
(e.g., Pinduoduo, Temu, Duo Duo Grocery), the frequency it is provided, and how
it is used by the CODM. Clarify if the disaggregated revenue noted in your
response is provided to the CODM. Provide quantification of any disaggregated
expense information.
•What operating metrics are provided to the CODM, whether they are provided on
a consolidated or disaggregated basis, the frequency they are provided, and how
they are used by the CODM. Provide examples of how such operating metrics are
used to allocate resources and assess performance. For example, how are they
used to allocate resources for advertising expenses and incentive programs.
•What disaggregated financial information and operating metrics are provided to
the Board of Directors.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Scott Stringer at 202-551-3272 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters. Please
contact Taylor Beech at 202-551-4515 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services