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November 30, 2023
Shuo Shi
Chief Executive and Operations Officer
WiMi Hologram Cloud Inc.
Room #2002, Building A, Wentley Center
1st West Dawang Road, Chaoyang District
Beijing, The People’s Republic of China, 100020
Re:WiMi Hologram Cloud Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated November 13, 2023
File No. 001-39257
Dear Shuo Shi:
            We have reviewed your November 13, 2023 response to our comment letter and have the
following comments.
            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. Unless
we note otherwise, any references to prior comments are to comments in our October 30, 2023
letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 18. Financial Statements
Note 13. Goodwill, page F-50
1.We note your responses to prior comments 1 and 2, however, it remains unclear to us how
you determined that the fair value of your reporting units was approximately $192 million
when the company’s total market capitalization was only $64 million at the time of your
goodwill analysis. We further note that the company’s total market capitalization has
remained significantly below the total fair value of your reporting units throughout fiscal
2023. Please address the following:
•The growth rate projections used in your analysis do not appear to be in line with
historical revenue trends for the consolidated company and specifically
the AR advertising services segment for which Shenzhen Yidian and Shenzhen Yitian

 FirstName LastNameShuo Shi
 Comapany NameWiMi Hologram Cloud Inc.
 November 30, 2023 Page 2
 FirstName LastName
Shuo Shi
WiMi Hologram Cloud Inc.
November 30, 2023
Page 2
are included. Provide all evidence used to support the expected revenue growth for
both reporting units or explain in further detail the basis for such assumptions.
•Describe the trends in these two reporting units over the last several years and explain
how such trends factored into your assumptions.
•Tell us whether your revenue growth projections still reflect management's view of
future performance. If so, explain how you considered the decrease in Holographic
AR advertising revenue during the first half of fiscal 2023 compared to your growth
rate projections of 200% and 707% for the Shenzhen Yidian and Shenzhen Yitian
reporting units, respectively.
•Explain how the discount rate used in your valuation was determined and how
management determined such rate was appropriate.
•Tell us whether a sensitivity analysis was performed for the Shenzhen Yidian and
Shenzhen Yitian reporting units and if so, what those results were.
•Tell us whether you performed any interim impairment analysis or tell us how you
determined that such analysis was not necessary.
2.Please clarify whether the December 31, 2022 carrying value for each reporting unit
included in your response to prior comment 1 includes the goodwill allocated to each
respective reporting unit. In this regard, it is unclear why you are adjusting for net
goodwill in calculating the percentage by which fair value exceeds carrying value. Please
explain or revise.
            Please contact Megan Akst at 202-551-3407 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology