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November 9, 2022
Haijian He
Chief Financial Officer
Kingsoft Cloud Holdings Limited
Building E, Xiaomi Science and Technology Park
No. 33 Xierqi Middle Road
Haidian District, Beijing, 100085
People’s Republic of China
Re:Kingsoft Cloud Holdings Limited
Form 20-F for the Fiscal Year Ended December 31, 2021
Response dated September 20, 2022
File No. 001-39278
Dear Haijian He:
            We have reviewed your September 20, 2022 response to our comment letter 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.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
September 6, 2022 letter.
Annual Report on Form 20-F for Fiscal Year Ended December 31, 2021
Item 3 Key Information
3.D. Risk Factors, page 1
1.We note your response to prior comment 2; however, please specifically disclose here
how recent statements by China’s government, such as those related to the use of variable
interest entities (VIEs) and data security or anti-monopoly concerns, have or may impact
the company’s ability to conduct its business, accept foreign investments, or list on a U.S.
or other foreign exchange. Further, expressly disclose how all of these legal and
operational risks associated with being based in or having your operations primarily in
China could result in a material change in your operations and/or the value of the

 FirstName LastNameHaijian He
 Comapany NameKingsoft Cloud Holdings Limited
 November 9, 2022 Page 2
 FirstName LastNameHaijian He
Kingsoft Cloud Holdings Limited
November 9, 2022
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securities  or could significantly limit or completely hinder your ability to offer or
continue to offer securities to investors and cause the value of such securities to
significantly decline or be worthless.
2.Revise your reference to primary beneficiary here and elsewhere throughout the filing to
clarify that you are the “primary beneficiary” of the VIEs for accounting purposes only.
3.We note your response to prior comment 5. Please also include this language in the
summary of risk factors bullet points.
4.We note your response to prior comment 6. Please also include this language in the
summary of risk factors bullet points. Additionally, please explain whether you relied on
the opinion of counsel to determine that no permissions or approvals are required to
operate your business or offer securities.
Condensed Consolidating Schedule, page 56
5.We note your response to comment 10 and your proposed disclosure.  Please disaggregate
your WFOEs in a separate column, even if they are not the primary beneficiaries.    With
regard to your income statement presentations, given that you receive revenue from the
VIEs and VIE subsidiaries via service agreements, it is not clear to us why the balances
in the line item "Contractual interests in VIEs and VIEs subsidiary" are materially
higher than inter-company revenue.  Please advise.   Also, your proposed footnote
(4) states that Contractual interests in VIEs and VIEs’ subsidiaries "represents the
Company’s economic interests in the VIEs and VIEs’ subsidiaries in the same manner as
an entity consolidated based on voting interests."  Please revise to refrain from implying
that the contractual agreements are equivalent to equity ownership in the business of the
VIE.  In regards to your balance sheet presentation, please disaggregate your line items
labeled "Investments in subsidiaries" and "Amounts due from group companies" to make
it is clear what portion relates to non-VIE subsidiaries and what portion relates to VIEs
and VIEs' subsidiaries.

Notes to Consolidated Financial Statements
1. Organization and Basis of Presentation
Cash and cash equivalents, page F-21
6.We note your response to comment 19 and your proposed disclosure.  However,  the
disclosure requested should be located in the area where cash is discussed, cash and cash
equivalents section of your notes to the consolidated financial statements. Please revise
accordingly.   Also, your current disclosure states that cash is unrestricted as to
withdrawal and use.  This statement contradicts other disclosure.  Please revise
accordingly.

 FirstName LastNameHaijian He
 Comapany NameKingsoft Cloud Holdings Limited
 November 9, 2022 Page 3
 FirstName LastName
Haijian He
Kingsoft Cloud Holdings Limited
November 9, 2022
Page 3

3. Concentration of Risks
Currency convertibility risk, page F-32
7.We note your response to comment 22 and your proposed disclosure.  Please expand your
disclosure to prominently state if your operating subsidiaries, which appear to hold your
cash and cash equivalents in RBM, have ever converted the RMB to a foreign currency
and if they plan do so in the future.
24. Condensed Financial Information of the Parent Company, page F-56
8.We note your response to comment 26 and proposed disclosure.  On the face of the
balance sheet, please disaggregate your line items labeled "Investments in subsidiaries,"
"Amounts due from group companies," and "Amounts due to group companies," to make
it clear what portion relates to non-VIE subsidiaries and what portion relates to VIEs and
VIEs' subsidiaries.  Also, your proposed footnote (2) states that Contractual interests in
VIEs and VIEs’ subsidiaries "represent the Company’s economic interests in the VIEs and
VIEs’ subsidiaries in the same manner as an entity consolidated based on voting
interests." Please revise to refrain from implying that the contractual agreements are
equivalent to equity ownership in the business of the VIE.

General
9.We note the revisions proposed in response to prior comment 27; however, we re-issue
this comment.  Please revise your definition of “we,” “us,” “our company,” the
“Company,” and “our” to remove the VIE from this definition.  In this regard, when
describing the activities and functions of the VIEs, your disclosure should refer to the
VIEs.
            You may contact Inessa Kessman, Senior Staff Accountant, at 202-551-3371 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 Alexandra
Barone, Staff Attorney, at (202) 551-8816 or Mitchell Austin, Staff Attorney, at (202) 551-
3574 with any other questions.-
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ran Li, Esq.