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Correspondence 0001104659-25-000646 from PDD Holdings Inc. (PDD)

PDD Holdings Inc.
Date: Jan. 3, 2025 · CIK: 0001737806 · Accession: 0001104659-25-000646

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File numbers found in text: 001-38591

Referenced dates: January 2, 2025

Date
January 3, 2025
Author
/s/ Yuting Wu
Form
CORRESP
Company
PDD Holdings Inc.

Letter

VIA EDGAR Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission Re: PDD Holdings Inc. Form 20-F for the Fiscal Year Ended December 31, 2023 Response dated September 30, 2024 File No. 001-38591

Dear Mr. Stringer, Mr. Parker, Ms. Beech and Ms. Ransom,

We write on behalf of our client, PDD Holdings Inc. (the “Company”). The Company has received the letter dated January 2, 2025 (the “Letter”) from the staff of the Securities and Exchange Commission regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2023 (the “2023 Form 20-F”). The Company respectfully requests an extension to the deadline for responding to the Letter due to the additional time required to gather sufficient information and prepare a thorough response. The Company will provide its response to the Letter via EDGAR as soon as possible, and in any event no later than January 31, 2025.

If you have any additional questions or comments regarding the 2023 Form 20-F, please contact the undersigned at +86 21 6193 8225 or yuting.wu@skadden.com.

January 3, 2025

Page 2

Very truly yours,
/s/ Yuting Wu

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CORRESP
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Skadden,
Arps, Slate, Meagher & Flom llp

    One Manhattan West
    FIRM/AFFILIATE OFFICES

    New York,
    NY 10001

    -----------

    ________

    BOSTON

    TEL: (212) 735-3000

    CHICAGO

    FAX: (212) 735-2000

    HOUSTON

    www.skadden.com

    LOS ANGELES

    PALO ALTO

    WASHINGTON, D.C.

    WILMINGTON

    -----------

    BEIJING

    BRUSSELS

    January 3, 2025
    FRANKFURT

    HONG KONG

    LONDON

    MUNICH

    PARIS

    SÃO PAULO

    SEOUL

    SHANGHAI

    SINGAPORE

    TOKYO

    TORONTO

VIA EDGAR

Mr. Scott Stringer

Mr. Joel
Parker

Ms. Taylor Beech

Ms. Mara Ransom

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: PDD Holdings Inc.

Form 20-F for the Fiscal Year Ended December 31, 2023

Response dated September 30, 2024

File No.  001-38591

Dear Mr. Stringer, Mr. Parker, Ms. Beech and Ms. Ransom,

We write on behalf of our
client, PDD Holdings Inc. (the “Company”). The Company has received the letter dated January 2, 2025 (the “Letter”)
from the staff of the Securities and Exchange Commission regarding the Company’s annual report on Form 20-F for the fiscal
year ended December 31, 2023 (the “2023 Form 20-F”). The Company respectfully requests an extension to the
deadline for responding to the Letter due to the additional time required to gather sufficient information and prepare a thorough response.
The Company will provide its response to the Letter via EDGAR as soon as possible, and in any event no later than January 31, 2025.

If you have any additional questions or comments
regarding the 2023 Form 20-F, please contact the undersigned at +86 21 6193 8225 or yuting.wu@skadden.com.

January 3, 2025

Page 2

    Very truly yours,

    /s/ Yuting Wu

    Yuting Wu

 cc: Lei Chen, Chairman of the Board of Directors and Co-Chief
Executive Officer, PDD Holdings Inc.

Jiazhen Zhao, Executive Director and Co-Chief Executive Officer, PDD Holdings Inc.

Harry Han, Partner, Ernst & Young Hua Ming LLP