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WiMi Hologram Cloud Inc.

September 29, 2023

VIA EDGAR

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

Washington, D.C. 20549

    Attn.:
    Ms. Kathleen Collins

Ms. Megan Akst

    Re:

    WiMi Hologram Cloud Inc.

    Form 20-F for the Fiscal Year Ended December 31, 2022

    Filed April 13, 2023

    File No. 001-39257

Ladies and Gentlemen:

WiMi Hologram Cloud Inc.
(the “Company”, “we”, “us” or “our”) hereby transmits its response to the
letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”), dated September 19, 2023 regarding its Form 20-F for the fiscal year ended December 31, 2022 filed on
April 13, 2023.

Set forth below are the Company’s
responses to the Staff’s comments in the Comment Letter. The Staff’s comments are retyped below in bold for your ease of reference.
The Company respectfully advises the Staff that where the Company proposes to add or revise disclosure in its future annual reports on
Form 20-F in response to the Staff’s comments, the changes to be made will be subject to relevant factual updates and changes
in relevant laws or regulations, or in interpretations thereof.

Form 20-F for the Fiscal Year Ended December 31, 2022

Introductory Note, page iv

    1.
    We note that you exclude Hong Kong and Macau from your definition of “PRC” or “China” for the purpose of your annual report. Please revise to remove the exclusion of Hong Kong and Macau from such definition. Clarify that all the legal and operational risks associated with having operations in the People’s Republic of China (PRC) also apply to operations in Hong Kong and Macau. In this regard, ensure that your disclosure does not narrow risks related to operating in the PRC to mainland China only. Where appropriate, you may describe PRC law and then explain how law in Hong Kong and Macau differs from PRC law and describe any risks and consequences to the company associated with those laws.

In response to the Staff’s comments,
in future filings, the Company will revise its definition of “China” and the “PRC” to remove the exclusion of
Taiwan, Hong Kong and Macau. The proposed revised disclosure is set forth in Annex A. In addition, the Company will include disclosures
to clarify that the legal and operational risks associated with operating in mainland China also apply to operations in Hong Kong, without
narrowing risks related to operating in the PRC to mainland China only. Where appropriate, the Company will also explain the differences
between Hong Kong and mainland Chinese laws and describe risks and consequences to the Company associated with those laws.

The Company respectfully advises the
Staff that the Company does not have operations in Macau.

Item 3. Key Information

Non-GAAP Financial Measures, page 3

    2.
    We note that you include a discussion of non-GAAP measures before presenting any GAAP financial measures. Please revise to present the most directly comparable GAAP measures with equal or greater prominence. In this regard, consider moving your nonGAAP discussion to follow your GAAP results of operations disclosure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the non-GAAP C&DIs.

In response to the Staff’s comments,
in the Company’s future annual reports on Form 20-F, the Company will move the non-GAAP discussion to the end of Item 5 A.OPERATING
RESULTS, following its GAAP results of operations disclosure. The proposed revised disclosure is set forth in Annex A.

D. Risk Factors

The recent joint statement by the SEC and
PCAOB, proposed rule changes submitted by Nasdaq, and the HFCAA..., page 25

    3.
    Please expand this risk factor to disclose that the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, 2023, decreased the number of consecutive “non-inspection years” from three to two years, and thus, reduces the time before securities may be prohibited from trading or delisted.

In response to the Staff’s comments,
in future filings, the Company will add the following disclosure in Item 3 D. RISK FACTOR related to the Holding Foreign Companies Accountable
Act:

“On December 23, 2022,
the Accelerating Holding Foreign Companies Accountable Act, or the AHFCAA, was enacted, which amended the HFCAA by reducing the aforementioned
inspection period from three to two consecutive years, thus reducing the time period before our securities may be prohibited from trading
or delisted if our auditor is unable to meet the PCAOB inspection requirement.”

The proposed revised disclosure
is set forth in Annex A.

Item 4. Information on the Company

C. Organizational Structure, page 70

    4.
    Please revise to improve legibility by increasing the font size of the text in your organization chart.

In response to the Staff’s comments,
in future filings, the Company will improve legibility by increasing the font size of the text in its organization chart. The proposed
revised disclosure and chart is set forth in Annex A.

Item 18. Financial Statements

Consolidated Statements of Operations and Comprehensive Loss,
page F-6

    5.
    Please revise to separately present the cost of revenue from products and services on the face of your consolidated statement of operations and comprehensive loss. Refer to Rule 5-03(b)(2) of Regulation S-X.

In response to the Staff’s comments,
in the Company’s future annual reports on Form 20-F, the Company will revise to separately present the cost of revenue on the
face of its consolidated statement of operations and comprehensive loss. The proposed revised disclosure is set forth in Annex A.

    2

Note 13. Goodwill, page F-50

    6.

    We note that the company’s net book value significantly
    exceeds its market capitalization. Please address the following as it relates to your goodwill impairment evaluation:

    ● Identify each of your reporting units.
    In this regard, your disclosures on page 90 indicate that you have four reporting units with goodwill, however, the table appears to identify
    only two: AR advertising services unit and semiconductor business unit.

    Also, your disclosures elsewhere refer to reporting
    units, which appear to be based on prior acquisitions (i.e. Skystar reporting, Fe-da Electronics and Shenzhen Kuxunyou reporting units).

    ● To the extent reporting units changed
    during fiscal 2022, describe how assets, liabilities and goodwill allocated to such units were reassigned. Refer to ASC 350-20- 35-45.

    ● Tell us the fair value and carrying
    value of each reporting unit and the amount of goodwill allocated to each.

    ● Explain how the “business strategy
    adjustment” impacted Shenzhen Yitian’s operations and your goodwill analysis. In your response, clarify what specific revenue stream
    was impacted when Shenzhen Yitian’s ceased operating their business involving foreign investment restrictions.

    ● Provide us with a reconciliation of
    the estimated fair value of your reporting units to the company’s market capitalization as of December 31, 2022.

In response to the Staff’s
comments,in future filings, the company will (i) clarify the four reporting units
which have goodwill, we will list the company name of the reporting units. (ii) add Goodwill
Fair Value and Carrying Value for each reporting unit. The proposed revised disclosure at page 90 as follows:

    Segment
    Reporting Unit
    Fair Value
 Exceeds
 Carrying
 Value
    Net
 Goodwill
 as of
 December 31,
    2021
    Net
 Goodwill
 as of
 December 31,

 2022
    Goodwill Fair Value
as of
December 31,

2022
    Carrying
 Value as of
December 31,
2022

    (in RMB thousands)

    AR advertising services
    Shenzhen Yidian
      143.7 %
      137,060
      137,060
      196,955
      193,383

    Shenzhen Yitian
      954.9 %
      92,990
      92,990
      887,962
      214,101

    Guoyu
      67.9 %
      13,284
      13,284
      9,020
      6,708

    Semiconductor business
    FE-DA Electronics
      —
      33,644
      —
      —
      4,746

      276,978
      243,334
      1,093,937
      418,939

In addition, the Company respectfully
advises the Staff that the goodwill of Skystar and Shenzhen Kuxunyou has been
fully impaired as of December 31, 2021, therefore, these two companies
are not listed in the above table.

The disclosure of the company’s
20-F at page 12 as follows:

“Our operating units Kuxuanyou,
Skystar and Fe-da Electronics recorded goodwill impairment charges of approximately RMB 131.2 million, impairment of long-lived assets
of approximately RMB 4.3 million and other assets of approximately RMB 11.1 million which are mainly impairment of inventory and contract
costs due to lower profit projections for the year ended December 31, 2021.
For the year ended December 31, 2022, our operating unit Fe-da Electronics recorded goodwill impairment charges of approximately RMB 35.5
million (USD 5.1 million), impairment of long-lived assets of approximately RMB 13.7 million (USD 2.0 million).”

Moreover, the Company respectfully
advises the Staff that the Company did not undertake a reorganization during fiscal 2022, the assets,
liabilities and goodwill allocated to such units were not reassigned during fiscal 2022 refer to ASC 350-20- 35-45. As
the “business strategy adjustment” refers to a “business plan adjustment”, Shenzhen Yitian formulated a plan to
operate businesses involving foreign investment before, but it did not actually carry out any such business plans. Therefore,
the “business strategy adjustment” did not impacted Shenzhen Yitian’s operations and the goodwill, and no specific revenue stream
was impacted. Shenzhen Yitian possesses PRC Internet Content Provision (“ICP”)
licenses which enable it to operate foreign-investment restricted business in telecommunication, this is the main reason why the historical
VIE had originally been utilized instead of an equity ownership interest. Due to the business plan adjustment, the company will not operate
businesses involving foreign investment restrictions in the future, so the VIE structure was terminated in April 2022.

In
addition, the Company respectfully advises the Staff that the company’s
net asset and market capitalization are USD 165,029,543 and USD 113,427,050 respectively as of December 31, 2022.

    3

If you have any questions
regarding the Company’s responses to the Staff’s comments, please contact us via e-mail at sean@wimiar.com or by phone at
+86-10-5338-4913.

    Very truly yours,

    /s/ Shuo Shi

    Shuo Shi

    Chief Executive and Operations Officer

Enclosure:  Annex A

    4

Annex
A

Comment 1

INTRODUCTORY NOTE

● China” or “PRC” refers
to the People’s Republic of China, excluding, for the purpose of this annual report only, Taiwan, Hong Kong and Macau;

Comment 2

ITEM 5. OPERATING AND FINANCIAL REVIEW
AND PROSPECTS

A. OPERATING RESULTS

Overview

We offer AR-based holographic services and products
to cater to our customers’ needs. By leveraging our strong technological capabilities and infrastructure, we are able to deliver
superior products and services and conduct our operations in a highly efficient manner. The core of our holographic AR technologies is
used in software engineering, content production, cloud and big data. All of our services and products are centered upon providing an
innovative, immersive and interactive holographic AR experience for our customers and end users. Approximately 44.0%, 48.2% and 70.6%
of our revenues were generated by our holographic AR advertising and entertainment services for the years ended December 31,
2020, 2021, and 2022, respectively.

Starting in July 2020, we developed our semiconductor
business as we believe that the application demand of holographic 3D vision in the semiconductor sector is growing rapidly, representing
huge market potentials. We engage in the provision of central processing algorithm services and computer chip products to enterprise customers
and the sales of comprehensive solutions for central processing algorithms and related services with software and hardware integration
by establishing VIYI which subsequently merged with Venus Acquisition corporation and renamed MicroAlgo, of which we own 65.92% of equity
interest. In addition, our joint ventures VIDA Semicon Co., Limited (“VIDA”) also contributed to the growth of our semiconductor
business. Approximately 56.0%, 51.8% and 29.4% of our revenues were generated by our semiconductor business for the years ended December 31,
2020, 2021, and 2022 from the sale of semiconductor products and related accessories and the design of software for central processing
units based on customers’ specific needs.

Our total revenues were RMB 766.0 million,
RMB 933.8 million, and RMB 682.3 million (USD 98.0 million) for the year ended December 31, 2020, 2021, and 2022,
respectively. We recorded a net loss of RMB 145.0 million, RMB 254.4 million and RMB 376.8 million (USD 54.1 million) for
the years ended December 31, 2020 and 2021, and 2022 respectively.

    5

Impact of COVID-19

The novel coronavirus (COVID-19) has spread rapidly
in many parts of the world since early 2020. In March 2020, the World Health Organization declared the COVID-19 as a pandemic. The
pandemic has resulted in quarantines, travel restrictions, and the temporary closure of stores and business facilities in China for the
first few months in 2020. In addition, the Omicron variant and the Delta variant of COVID-19 began to spread rapidly over the world
and affected our business, as well as our customers and suppliers and because a majority of our business operations and our workforce
are concentrated in China, our business, results of operations, and financial condition have been adversely affected for the first half
of 2020. Our business and results of operations have been resumed to normal level in the second half of 2020 and 2021. The resurgence
of COVID-19 variant has caused further impact to our operations in 2022.

In early December 2022, Chinese government eased the strict control
measure for COVID-19, which has led to surge in increased infections and disruption in our business operations. Any future impact of COVID-19
on the Company’s China operation results will depend on, to a large extent, future developments and new information that may emerge
regarding the duration and resurgence of COVID-19 variants and the actions taken by government authorities to contain COVID-19 or treat
its impact, almost all of which are beyond our control.

Key Factors Affecting Results of Operations

Our results of operations are affected by the factors
discussed below.

Our ability to increase the number of customers and average revenue
for AR advertising services

Approximately 40.1%, 48.2% and 70.6% of our revenues
were generated from our holographic AR advertising services for the years ended December 31, 2020, 2021, and 2022, respectively.
The number of our customers for our AR advertising services increased from 294 for the year ended December 31, 2020 to 312 for the
year ended December 31, 2021, and 298 for the year ended December 31, 2022. In addition, average revenues per customer for AR
advertising services were approximately RMB 1.0 million, RMB 1.4 million, and RMB 1.6 million for the years ended
December 31, 2020, 2021 and 2022, respectively.

Our ability to increase our revenues and enhance
our profitability will depend on our ability to continue to increase our customer base and revenue per customer for our AR advertising
services. To achieve this, we strive to increase our marketing efforts and to enhance the quality and capabilities of our technologies.

Investment in technology and talent

We believe that a core element of the competitiveness
of the holographic AR industry is research and development related to technology development. The advancement of technology r