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August 14, 2023
Beck Chen
Chief Financial Officer
Dada Nexus Ltd
22/F, Oriental Fisherman’s Wharf
No. 1088 Yangshupu Road
Yangpu District, Shanghai 200082
People’s Republic of China
Re:Dada Nexus Ltd
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-39305
Dear Beck Chen:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 150
1.We note your statement that you reviewed the Company’s register of members and public
filings made by shareholders in connection with your required submission under
paragraph (a). Please supplementally describe any additional materials that were reviewed
and tell us whether you relied upon any legal opinions or third party certifications such as
affidavits as the basis for your submission. In your response, please provide a similarly
detailed discussion of the materials reviewed and legal opinions or third party
certifications relied upon in connection with the required disclosures under paragraphs
(b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For

 FirstName LastNameBeck Chen
 Comapany NameDada Nexus Ltd
 August 14, 2023 Page 2
 FirstName LastName
Beck Chen
Dada Nexus Ltd
August 14, 2023
Page 2
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note your list of subsidiaries in Exhibit 8.1 appears to indicate that you have
subsidiaries in Hong Kong and British Virgin Islands as well as in PRC that are not
included in your VIEs. Please note that Item 16I(b) requires that you provide disclosures
for yourself and your consolidated foreign operating entities, including variable interest
entities or similar structures.
•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and provide the
percentage of your shares or the shares of your consolidated operating entities owned
by governmental entities in each foreign jurisdiction in which you have consolidated
operating entities in your response.
•With respect to (b)(3) and (b)(5), please provide the information required by (b)(3)
and (b)(5) for you and all of your consolidated foreign operating entities in your
supplemental response.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Jimmy McNamara at 202-551-7349 or Andrew Mew at 202-551-3377
with any questions.

Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Yuting Wu