SEC Comment Letter 0000000000-23-000898 to Kingsoft Cloud Holdings Ltd (KC)
Kingsoft Cloud Holdings Ltd
Date: Jan. 26, 2023 · CIK: 0001795589 · Accession: 0000000000-23-000898
AI Filing Summary & Sentiment
File numbers found in text: 001-39278
Letter
United States securities and exchange commission logo January 26, 2023 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 December 16, 2022 File No. 001-39278 Dear Haijian He: We have reviewed your December 16, 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 November 9, 2022 letter. Form 20-F for the Fiscal Year Ended December 31, 2021 Item 3 Key Information 3.D. Risk Factors, page 1 1.We note your response to prior comment 1. Please expand your disclosure here to state that 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.
FirstName LastNameHaijian He Comapany NameKingsoft Cloud Holdings Limited January 26, 2023 Page 2 FirstName LastName Haijian He Kingsoft Cloud Holdings Limited January 26, 2023 Page 2
2.We note your response to prior comment 4. Please clearly state in a summary of risk factors bullet point the risks related to obtaining any permissions or approvals required to be obtained from Chinese authorities to (i) operate your business and (ii) offer the securities being registered to foreign investors. Include a specific cross-reference to a more detailed risk factor discussion. Additionally, with a view toward revised disclosure, please clarify in your prospectus summary that you relied on the opinion of counsel to conclude that you have obtained all necessary permissions and approvals to operate your business and to offer the securities being registered to foreign investors. 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 at 202-551- 3574 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Ran Li, Esq.
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United States securities and exchange commission logo
January 26, 2023
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 December 16, 2022
File No. 001-39278
Dear Haijian He:
We have reviewed your December 16, 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
November 9, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Item 3 Key Information
3.D. Risk Factors, page 1
1.We note your response to prior comment 1. Please expand your disclosure here to state
that 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.
FirstName LastNameHaijian He
Comapany NameKingsoft Cloud Holdings Limited
January 26, 2023 Page 2
FirstName LastName
Haijian He
Kingsoft Cloud Holdings Limited
January 26, 2023
Page 2
2.We note your response to prior comment 4. Please clearly state in a summary of risk
factors bullet point the risks related to obtaining any permissions or approvals required to
be obtained from Chinese authorities to (i) operate your business and (ii) offer the
securities being registered to foreign investors. Include a specific cross-reference to a
more detailed risk factor discussion. Additionally, with a view toward revised disclosure,
please clarify in your prospectus summary that you relied on the opinion of counsel to
conclude that you have obtained all necessary permissions and approvals to operate
your business and to offer the securities being registered to foreign investors.
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 at 202-551-
3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Ran Li, Esq.