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Skadden,
Arps, Slate, Meagher & Flom

  DIRECT
                                            DIAL

+86-21-61938200

EMAIL
ADDRESS

YUTING.WU@SKADDEN.COM

Partners

Geoffrey
Chan *

Shu
Du *

Andrew
L. Foster *

Chi
T. Steve Kwok *

Edward
H.P. Lam ♦*

Haiping
Li *

Rory
McAlpine ♦

Jonathan
B. Stone *

Kai
Sun

Paloma
P. Wang

♦
(Also Admitted in England & Wales)

*
(Also Admitted in New York)

  世達國際律師事務所42/F,
                                            EDINBURGH TOWER, THE LANDMARK

15
QUEEN’S ROAD CENTRAL, HONG KONG

________

TEL:
(852) 3740-4700

FAX:
(852) 3740-4727

www.skadden.com

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                                            OFFICES

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FRANKFURT

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PAULO

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TOKYO

TORONTO

            December 8,
2022

VIA EDGAR

Ms. Alyssa Wall

Mr. Dietrich King

Ms. Nasreen Mohammed

Mr. Joel Parker

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Pinduoduo
                                            Inc.

    Form 20-F
                                            for the Fiscal Year Ended December 31, 2021

    Filed
                                            on April 25, 2022 (File No. 001-38591)

Dear Ms. Wall, Mr. King, Ms. Mohammed
and Mr. Parker,

On behalf of our
client, Pinduoduo Inc. (the “Company”), we set forth below the Company’s responses to the comments contained
in the letter dated November 23, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31,
2021 filed with the Commission on April 25, 2022 (the “2021 Form 20-F”). The Staff’s comments are
repeated below in bold and are 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 2021 Form 20-F.

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

December 8, 2022

Page 2

Form 20-F
for the Year Ended December 31, 2021

Financial
Information Related to Our VIE, page 9

 1. We
                                            acknowledge your response to comment 2 and note from your prior response that you did not
                                            present the WFOE column separately because you determined that Pinduoduo Inc. is the primary
                                            beneficiary, not the WFOE. While we do not conclude on your identification of the primary
                                            beneficiary, we believe that, in light of the fact that the WFOE receives the returns from
                                            the VIE, separate presentation of the WFOE in the consolidating schedule would provide investors
                                            with meaningful information about the economic relationship between the VIE and the WFOE,
                                            and the WFOE and its Cayman Islands parent, Pinduoduo Inc. Please revise to present the WFOE
                                            in a separate column, and present intercompany transactions in separate line items.

In response to the Staff’s
comment, the Company respectfully proposes to revise the VIE financial schedules in its future Form 20-F filings per the blacklining
shown below (with deletions shown in strikethrough and additions in underline), subject to such updates and adjustments to be made in
connection with any material developments of the subject matter being disclosed:

“Financial
Information Related to Our the VIE

The
following table presents the condensed consolidating schedule of financial position for (i) Pinduoduo Inc., (ii) Hangzhou
Weimi, a PRC subsidiary of the Company that has entered into contractual arrangements with the VIE, the VIE’s shareholders and,
as applicable, their spouses, (iii) our the VIE and its subsidiaries, and (iv) the Company’s
subsidiaries other than Hangzhou Weimi and other entities as of the dates or for the periods presented.

Selected
Condensed Consolidated Statements of Income Information

    For the
    Year Ended December 31, 2021

    Pinduoduo

    Inc. (Primary

    beneficiary of

    the VIE)
    Subsidiaries

                                            Hangzhou

                                            Weimi*

    VIE and Its

    Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

    Inc.**
    Eliminations
    Consolidated

    Total

    (RMB in millions)

    Revenues
      —
      2,288,608
      77,877,339
      50,467,506
      (36,683,514 )
      93,949,939

    Total
    costs and operating expenses
      (649,171 )
      (2,273,922 )
      (62,977,072 )
      (57,836,526 )
      36,683,514
      (87,053,177 )

    Share
    of profit from subsidiaries, the VIE and subsidiaries of the VIE
      9,579,738
      —
      —
      —
      (9,579,738 )
      —

    Net
    income / (loss)
      7,768,670
      43,461
      15,169,180
      (5,632,903 )
      (9,579,738 )
      7,768,670

Division
                                            of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

December 8, 2022

Page 3

    For the
    Year Ended December 31, 2020

    Pinduoduo

                                             Inc. (Primary

                                            beneficiary of

                                            the VIE)

    Subsidiaries

                                            Hangzhou

                                            Weimi*

    VIE and Its

    Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

    Inc.**
    Eliminations
    Consolidated

    Total

    (RMB in millions)

    Revenues
      —
      1,101,213
      51,351,861
      21,614,790
      (14,575,999 )
      59,491,865

    Total
    costs and operating expenses
      (667,210 )
      (1,332,403 )
      (50,118,546 )
      (31,330,030 )
      14,575,999
      (68,872,190 )

    Share
    of profit from subsidiaries, the VIE and subsidiaries of the VIE
      (5,996,484 )
      —
      —
      —
      5,996,484
      —

    Net
    (loss) / income
      (7,179,742 )
      (229,006 )
      2,552,665
      (8,320,143 )
      5,996,484
      (7,179,742 )

    For the
    Year Ended December 31, 2019

    Pinduoduo

                                             Inc. (Primary

                                            beneficiary of

                                            the VIE)

    Subsidiaries

                                            Hangzhou

                                            Weimi*

    VIE and Its

    Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

    Inc.**
    Eliminations
    Consolidated

    Total

    (RMB in millions)

    Revenues
      —
      1,149,250
      19,875,332
      12,636,410
      (3,519,106 )
      30,141,886

    Total
    costs and operating expenses
      (670,724 )
      (1,059,794 )
      (24,309,403 )
      (16,158,996 )
      3,518,820
      (38,680,097 )

    Share
    of profit from subsidiaries, the VIE and subsidiaries of the VIE
      (6,470,882 )
      —
      —
      —
      6,470,882
      —

    Net
    (loss) / income
      (6,967,603 )
      93,183
      (3,611,656 )
      (2,946,035 )
      6,464,508
      (6,967,603 )

Selected
Condensed Consolidated Balance Sheets Information

    As of
    December 31, 2021

    Pinduoduo

                                             Inc. (Primary

                                            beneficiary of

                                            the VIE)

    Subsidiaries

                                            Hangzhou

                                            Weimi*

    VIE and Its

    Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

    Inc.**
    Eliminations
    Consolidated

    Total

    (RMB in thousands)

    Current assets:

    Cash
    and cash equivalents
      2,269
      1,033
      2,430,440
      3,992,973
      —
      6,426,715

    Restricted
    cash
      —
      —
      59,402,079
      215,177
      —
      59,617,256

    Short-term
    investments
      —
      —
      12,306,340
      74,210,278
      —
      86,516,618

    Amounts
    due from Group companies(1)
      —
      1,239,992
      40,425,872
      29,829,301
      (71,495,165 )
      —

    Others
      390
      9,393
      6,198,116
      2,140,680
      —
      8,348,579

    Total
    current assets
      2,659
      1,250,418
      120,762,847
      110,388,409
      (71,495,165 )
      160,909,168

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

December 8, 2022

Page 4

    As of December 31, 2021

    Pinduoduo
  Inc. (Primary

 beneficiary of

 the VIE)

    Subsidiaries Hangzhou Weimi*

    VIE and Its
 Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

     Inc.**
    Eliminations
    Consolidated
 Total

    (RMB in thousands)

    Non-current assets:

    Other non-current assets
      —
      —
      5,300,938
      11,125,028
      —
      16,425,966

    Investments in subsidiaries, our the VIE and its subsidiaries(2)
      86,252,341
      2,000
      —
      1,579,309
      (87,833,650 )
      —

    Others
      674,057
      9,690
      2,581,092
      609,745
      —
      3,874,584

    Total non-current assets
      86,926,398
      11,690
      7,882,030
      13,314,082
      (87,833,650 )
      20,300,550

    Total assets
      86,929,057
      1,262,108
      128,644,877
      123,702,491
      (159,328,815 )
      181,209,718

    Current liabilities:

    Payable to merchants
      —
      —
      61,947,517
      562,197
      —
      62,509,714

    Merchant deposits
      —
      —
      13,360,409
      217,143
      —
      13,577,552

    Amounts due to Group companies(1)
      —
      1,315,756
      27,978,153
      123,501,613
      (152,795,522 )
      —

    Others
      24,607
      191,953
      12,619,600
      4,806,288
      —
      17,642,448

    Total current liabilities
      24,607
      1,507,709
      115,905,679
      129,087,241
      (152,795,522 )
      93,729,714

    Non-current liabilities

    Convertible bonds
      11,788,907
      —
      —
      —
      —
      11,788,907

    Others
      996
      75
      324,285
      251,194
      —
      576,550

    Total non-current liabilities
      11,789,903
      75
      324,285
      251,194
      —
      12,365,457

    Total liabilities
      11,814,510
      1,507,784
      116,229,964
      129,338,435
      (152,795,522 )
      106,095,171

    As of December 31, 2020

    Pinduoduo
  Inc. (Primary

 beneficiary of

 the VIE)

    Subsidiaries Hangzhou Weimi*

    VIE and Its
 Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

     Inc.**
    Eliminations
    Consolidated
 Total

    (RMB in thousands)

    Current assets:

    Cash and cash equivalents
      6,566
      9,168
      3,593,192
      18,812,263
      —
      22,421,189

    Restricted cash
      —
      45,000
      52,148,852
      228,595
      —
      52,422,447

    Short-term investments
      5,840,247
      —
      7,026,442
      51,684,405
      —
      64,551,094

    Amounts due from Group companies(1)
      —
      999,964
      9,932,418
      14,699,309
      (25,631,691 )
      —

    Others
      359
      38,340
      8,788,524
      1,301,925
      —
      10,129,148

    Total current assets
      5,847,172
      1,092,472
      81,489,428
      86,726,497
      (25,631,691 )
      149,523,878

    Non-current assets:

    Other non-current assets
      —
      5,005
      4,380,476
      2,889,824
      —
      7,275,305

    Investments in subsidiaries, our the and its subsidiaries(2)
      67,814,679
      2,000
      —
      1,616,265
      (69,432,944 )
      —

    Others
      1,276,751
      23,967
      654,790
      153,923
      —
      2,109,431

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

December 8, 2022

Page 5

    As of December 31, 2020

    Pinduoduo
  Inc. (Primary

 beneficiary of

 the VIE)

    Subsidiaries Hangzhou Weimi*

    VIE and Its
 Subsidiaries
    Other

    Subsidiaries of

    Pinduoduo

     Inc.**
    Eliminations
    Consolidated
 Total

    (RMB in thousands)

    Total non-current assets
      69,091,430
      30,972
      5,035,266
      4,660,012
      (69,432,944 )
      9,384,736

    Total assets
      74,938,602
      1,123,444
      86,524,694
      91,386,509
      (95,064,635 )
      158,908,614

    Current liabilities:

    Payable to merchants
      —
      —
      53,417,259
      416,722
      —
      53,833,981

    Merchant deposits
      —
      —
      10,926,319
      —
      —
      10,926,319

    Amounts
    due to Group companies(1)
      —
      1,068,463
      9,759,506
      92,224,226
      (103,052,195 )
      —

    Others
      327,004
      334,083
      14,809,044
      3,651,646
      —
      19,121,777

    Total current liabilities
      327,004
      1,402,546
      88,912,128
      96,292,594
      (103,052,195 )
      83,882,077

    Non-current liabilities

    Convertible bonds
      14,432,792
      —
      —
      —
      —
      14,432,792

    Others
      2,918
      10,034
      366,834
      38,071
      —
      417,857

    Total non-current liabilities
      14,435,710
      10,034
      366,834
      38,071
      —
      14,850,649

    Total liabilities
      14,762,714
      1,412,580
      89,278,962
      96,330,665
      (103,052,195 )
      98,732,726

    As of December 31, 2019

    Pinduoduo
  Inc. (Primary

 beneficiary of

 the VIE)

    Subsidiaries Hangzhou Weimi*

    VIE and Its
 Subsidiaries
    Other

Subsidiaries of

Pinduoduo

 Inc.**
    Eliminations
    Consolidated
 Total

    (RMB in thousands)

    Current assets:

    Cash and cash equivalents
      661,714
      7,360
      2,816,894
      2,282,218
      —
      5,768,186

    Restricted cash
      —
      45,000
      27,528,793
      3,878
      —
      27,577,671

    Short-term investments
      6,157,221
      —
      6,560,665
      22,570,941
      —
      35,288,827

    Amounts due from Group companies(1)
      —
      58,554
      3,337,273
      5,410,374
      (8,806,201 )
      —

    Others
      17,906
      185,001
      3,706,618
      457,254
      —
      4,366,779

    Total current assets
      6,836,841
      295,915
      43,950,243
      30,724,665
      (8,806,201 )
      73,001,463

    Non-current assets:

    Other non-current assets
      —
      5,001
      60,306
      437,813
      —
      503,120

    Investments in subsidiaries, our the VIE and its subsidiaries(2)
      21,053,370
      2,000
      —
      1,728,056
      (22,783,426 )
      —

    Others
      1,994,292
      40,872
      480,602
      36,987
      —
      2,552,753

    Total non-current assets
      23,047,662
      47,873
      540,908
      2,202,856
      (22,783,426 )
      3,055,873

    Total assets
      29,884,503
      343,788
      44,491,151
      32,927,521
      (31,589,627 )
      76,057,336

    Current liabilities:

    Payable to merchants
      —
      —
      29,657,227
      269,261
      —
      29,926,488

    Merchant deposits
      —
      —
      7,840,912
      —
      —
      7,840,912

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

December 8, 2022

Page 6

    As of December 31, 2019

    Pinduoduo
  Inc. (Primary

 beneficiary of

 the VIE)

    Subsidiaries Hangzhou Weimi*

    VIE and Its
 Subsidiaries
    Other

Subsidiaries of