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WiMi Hologram Cloud Inc.

November 13, 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 October
30, 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.

Item 18. Financial Statements

Note 13. Goodwill, page F-50

1. Please address the following as it relates to your response
to prior comment 1:

 ● Tell us why you consider Shenzhen Kuxuanyou to be a reporting
unit as of December 31, 2022 considering you disposed of this entity and its subsidiaries in November 2022.

 ● Tell us how you determined the amounts included in the
“Percentage of Fair Value Exceeds Carrying Value” column and provide the calculations that support such amounts.

 ● Tell us whether you performed a quantitative analysis
of the difference between the  fair value as determined in your goodwill evaluation and the company’s market capitalization at December
31, 2022. If so, provide us such analysis.

 ● To the extent you considered only qualitative factors
to support your goodwill evaluation as your response implies, provide a more comprehensive discussion of how you considered the factors
noted in your response (i.e. macroeconomic, social environment, stock price volatility, emerging industry status, etc.) in reconciling
the significant difference between the company’s market capitalization, which you note is USD$57 million and the USD$192 million fair
value of your six reporting units at December 31, 2022.

In response to the Staff’s
comments, the Company respectfully advises the Staff that:

(i) the Company has not considered Shenzhen Kuxuanyou as a reporting unit as of December 31, 2022. In the
Company’s response to the Staff’s previous round of queries, the Company included Shenzhen Kuxuanyou the proposed revisions
on page 90 as a means to show that Shenzhen Kuxuanyou does not have any effect on the goodwill of the Company. In future disclosures,
the Company will not include Shenzhen Kuxuanyou on the page 90 disclosure graph to avoid misunderstanding, as reflected below.

(ii) The Percentage of Fair Value Exceeds Carrying Value is calculated as follows: Percentage of Fair Value
Exceeds Carrying Value = (Fair value - Net Goodwill - Carrying Value) / (Net Goodwill + Carrying Value) * 100%.

Segment
    Reporting Unit
    Net Goodwill

as of December 31, 2022
    Fair Value

 as of

 December 31, 2022
    Carrying Value as of

 December 31, 2022
    Percentage of

Fair Value

 Exceeds

 Carrying Value

    a
    b
    c
    d=(b-a-c)/(a+c)

    (in RMB thousands)

    AR advertising services
    Shenzhen Yidian
      137,060
      334,000
      193,383
      1 %

    AR advertising services
    Shenzhen Yitian
      92,990
      981,000
      214,101
      219 %

    AR advertising services
    Guoyu
      13,284
      22,300
      6,708
      12 %

    Semiconductor business
    FE-DA Electronics
      —
      2719
      33053
      -92 %

    AR entertainment services
    Skystar
      —
      /
      79,881
      —

    Segment
    Reporting Unit
    Net Goodwill

 as of

 December 31, 2022
    Fair Value

as of

 December 31, 2022
    Carrying Value

 as of

 December 31, 2022
    Percentage of

 Fair Value

 Exceeds

 Carrying Value

    a
    b
    c
    d=(b-a-c)/(a+c)

    (in USD thousands)

    AR advertising services
    Shenzhen Yidian
      19,680
      47,957
      27,767
      1 %

    AR advertising services
    Shenzhen Yitian
      13,352
      140,855
      30,741
      219 %

    AR advertising services
    Guoyu
      1,907
      3,202
      963
      12 %

    Semiconductor business
    FE-DA Electronics
      —
      390
      4,746
      -92 %

    AR entertainment services
    Skystar
      —
      /
      11,470
      —

In terms of the the difference between the fair
value as determined in goodwill evaluation and the company’s market capitalization, the Company respectfully advises the Staff
that considering the trading volume of the Company’s stock is very limited and inactive, the details show that the daily trading
volume data as of 30 December 2022 is only 241,606 ADS and the turnover rate is only 0.26%. Furthermore, the turnover rates between January
2023 to October 2023 are almost below 3% which also indicated that the market is very inactive and the market capitalization could not
be a good indicator to reflect the real operating condition for the Company. In
addition, influenced by the recent relations and policies between China and the United States, American stock investors are subjective
and pessimistic when they make the investment decisions to invest in Chinese companies which would result in a negative impact on the
stock market. Given the analysis above, the market cap of the Company may not be a good indicator of the fair value.

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    2.

    You state on page 90 that you use the income
    approach supplemented by the market approach when testing for goodwill impairment. However, your disclosure on page F-51 refers only to
    the use of the income approach. Please tell us whether you use both the income and market approaches in evaluating goodwill for impairment.
    If so, tell us the relative weighting used for each approach and how you determined such weighting was appropriate. Also, explain further
    your use of the market approach, if applicable, considering you state in your response there is no particular representative company in
    the industry to which investors may compare the company. In addition, provide us with the quantified assumptions (i.e. discount rates,
    terminal value, growth rates, projected revenue, control premiums, peer companies, etc.) used in determining the fair value for both Shenzhen
    Yidian and Shenzhen Yitian, and explain how changes in key assumptions could impact your fair value determination.

In response to the Staff’s comments, the
Company respectfully advises the Staff that the discounted cash flow method was adopted in the valuation exercise. The market approach
was not used in evaluating goodwill for impairment, this will be corrected in future filings.

For the sensitivity of changes in key assumptions
in relation to the determination of fair value, the higher the discount rate, the lower the fair value. On the other side, the higher
the terminal value, the higher the projected revenue, the higher the growth rate would result in a higher fair value which indicted that
those factors have a positive impact on fair value. For more details, the main assumptions are as follows:

    Reporting Unit
    Discount Rate
    Terminal Value

    RMB’000

    Shenzhen Yidian
      18.00 %
      166,610

    Shenzhen Yitian
      18.00 %
      407,424

    Reporting Unit
    2023
    2024
    2025
    2026
    2027

    RMB’000
    RMB’000
    RMB’000
    RMB’000
    RMB’000

    Shenzhen Yidian
      44,652
      125,026
      287,561
      345,073
      353,700

    Growth Rate
      200 %
      180 %
      130 %
      20 %
      2.5 %

    Shenzhen Yitian
      292,399
      321,638
      353,802
      371,492
      380,780

    Growth Rate
      707 %
      10 %
      10 %
      5 %
      2.5 %

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

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