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May 12, 2020
Philip Jiaqi Kuai
Chief Executive Officer
Dada Nexus Limited
22/F, Oriental Fisherman's Wharf
No.1088 Yangshupu Road
Yangpu District, Shanghai
People's Republic of China
Re:Dada Nexus Limited
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted May 6, 2020
CIK No. 0001793862
Dear Mr. Kuai:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 4 to Draft Registration Statement on Form F-1
Risk Factors
Risks Related to Doing Business in China, page 42
1.We note your risk factor discussion of limitations on the ability of the PCAOB to
conduct investigations of your auditor. Please include another risk factor that highlights
recent developments (e.g. Article 177 of PRC Securities Law effective March 2020)
possibly further limiting an overseas regulator from conducting investigations or from
collecting evidence within the PRC.

 FirstName LastNamePhilip Jiaqi Kuai
 Comapany NameDada Nexus Limited
 May 12, 2020 Page 2
 FirstName LastName
Philip Jiaqi Kuai
Dada Nexus Limited
May 12, 2020
Page 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Change in Independent Auditor, page 103
2.Please amend your filing to include a dated exhibit 16.1 letter from
PricewaterhouseCoopers Zhong Tian LLP that refers to disclosure herein.
Internal Control Over Financial Reporting, page 103
3.We note that you continue to implement a plan to remediate the material weakness that
you identified in your internal control over financial reporting. Please revise to clarify
what remains to be completed in your remediation plan. Also, if the material weakness has
not been fully remediated, revise to disclose how long you estimate it will take to
complete your plan and disclose any associated material costs that you have incurred or
expect to incur.

Description of American Depositary Shares
Governing Law, page 190
4.You state that the deposit agreement includes an exclusive jurisdiction provision as well
as the right of the depositary to refer any claims brought for arbitration.  Please further
disclose here and in your risk factors how the exclusive jurisdiction provision and the
arbitration provision impacts ADS holders, whether these provisions apply to actions
arising under the Securities Act or Exchange Act and address any question as to the
enforceability of the arbitration provision.  Moreover, please disclose in both your
registration statement and the depositary agreement that despite agreeing to the arbitration
provision, investors will not be deemed to have waived the company’s or the depositary’s
compliance with the federal securities laws and the rules and regulations thereunder.
General
5.We note your presentation of total value of goods delivered (GMV) for JDDJ in your
graphic.  In order to provide proper balance to the presentation, please include disclosure
of your continuing net losses.

 FirstName LastNamePhilip Jiaqi Kuai
 Comapany NameDada Nexus Limited
 May 12, 2020 Page 3
 FirstName LastName
Philip Jiaqi Kuai
Dada Nexus Limited
May 12, 2020
Page 3
            You may contact Joseph Cascarano, Senior Staff Accountant, at (202) 551-3376 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Jeff Kauten, Staff
Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Z. Julie Gao, Esq.