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CORRESP
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December 16, 2022

    Division of Corporation Finance

    U.S. Securities & Exchange
    Commission

    100 F Street, NE

    Washington, D.C. 20549

 Re: Kingsoft Cloud Holdings Limited
 Form 20-F for Fiscal Year Ended December 31, 2021

                                                                                File No. 001-39278

 Attn: Division of Corporation Finance Office of Trade &
Services

VIA EDGAR

Dear Inessa Kessman, Robert Littlepage, Alexandra Barone and Mitchell
Austin:

This letter sets forth the responses of Kingsoft Cloud Holdings Limited
(“Kingsoft Cloud” or the “Company”) to the comment (the “Comment”) the Company received from the Securities
and Exchange Commission (the “Commission”) in a letter dated November 9, 2022.

For your convenience, we have included herein the comment in bold,
and the Company’s responses are set forth immediately below the Comment.

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 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.

Response

In response to the Staff’s Comment, the Company respectfully proposes to further revise the disclosure on page 1 of the 2021 Annual Report in its future Form 20-F filings (with deletions shown as strike-through and additions underlined) as follows, subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed:

We face various legal and operational risks and uncertainties as a company based in and primarily operating in China. Such legal and operational risks associated with being based in China could result in a material change in the operations of us and the VIEs, and/or the value of our securities, or could significantly limit or completely hinder our ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless. For example, we face risks associated with regulatory approvals of offshore offerings, anti-monopoly regulatory actions, cybersecurity and data privacy, as well as the lack of inspection from the Public Company Accounting Oversight Board (United States), or the PCAOB, on our auditors. The PRC government may also intervene with or influence our operations as the government deems appropriate to further regulatory, political and societal goals.

      1

For example, the PRC Data Security Law and the PRC Personal Information Protection Law posed additional challenges to our cybersecurity and data privacy compliance. The Cybersecurity Review Measures issued by the CAC and several other PRC governmental authorities in December 2021, as well as the Administration Regulations on Cyber Data Security (Draft for Comments) published by the CAC for public comments in November 2021, exposes uncertainties and potential additional restrictions on China-based overseas-listed companies like us. If the detailed rules, implementations, or the enacted version of the draft measures mandate clearance of cybersecurity review and other specific actions to be completed by us, we face uncertainties as to whether such clearance can be timely obtained, the failure of which may subject us to penalties, which could materially and adversely affect our business and results of operations and the price of our ADSs. See “Item 3. Key Information—Risk Factors—Risks Related to Our Business and Industry—We face challenges from the evolving regulatory environment regarding cybersecurity, information security, privacy and data protection, and user attitude toward data privacy and protection. Many of these laws and regulations are subject to changes and uncertain interpretation, and any actual or alleged failure to comply with related laws and regulations regarding cybersecurity, information security, data privacy and protection could materially and adversely affect our business and results of operations.”

 On December 24, 2021, the
CSRC published the draft Regulations of the State Council on the Administration of Overseas Issuance and Listing of Securities by
Domestic Companies (Draft for Comments) (the “Administrative Provisions”) and the draft Measures for the Record-Filing
of Overseas Issuance and Listing of Securities by Domestic Companies (Draft for Comments) (the “Filing Measures”) for
public comments till January 23, 2022. Pursuant to these drafts, a filing-based regulatory system will be applied to both
 “direct overseas offering and listing” and “indirect overseas offering and listing” of PRC domestic
companies. At the press conference held for these draft regulations on December 24, 2021, officials from the CSRC confirmed
that if complying with applicable PRC laws and regulations, companies with VIE structure may conduct overseas offering and listing
after fulfilling the relevant filing procedures.  As of the date of this annual report, it remains uncertain when the final
Administrative Provisions and Filing Measures will be adopted and whether they will be adopted in the current draft form. See
 “Item 3. Key Information—Risk Factors—Risks Relating to Doing Business in China— The filing, approval or
other administrative requirements of the CSRC or other PRC government authorities may be required to maintain our listing status or
conduct future offshore securities or debt offerings.”

The Holding Foreign Companies Accountable Act, or the HFCAA, was enacted on December 18, 2020. The HFCAA states if the SEC determines that we have filed audit reports issued by a registered public accounting firm that has not been subject to inspection by the PCAOB for three consecutive years beginning in 2021, the SEC shall prohibit our shares or ADSs from being traded on a national securities exchange or in the over-the-counter trading market in the United States. On December 16, 2021, the PCAOB issued the HFCAA Determination Report to notify the SEC of its determination that the PCAOB is unable to inspect or investigate completely registered public accounting firms headquartered in mainland China and Hong Kong. The PCAOB identified our auditor as one of the registered public accounting firms that the PCAOB is unable to inspect or investigate completely. In June 2022, we were conclusively identified by the SEC under the HFCAA as having filed audit reports issued by a registered public accounting firm that cannot be inspected or investigated completely by the PCAOB in connection with our filing of the annual report on Form 20-F for the fiscal year ended December 31, 2021. Under the current law, delisting and prohibition from over-the-counter trading in the U.S. could take place in 2024, or 2023 if the acceleration bill were enacted. If this happens there is no certainty that we will be able to list our ADSs or shares on a non-U.S. exchange or that a market for our shares will develop outside of the U.S. On August 26, 2022, the PCAOB signed a Statement of Protocol with the China Securities Regulatory Commission and the Ministry of Finance of the People’s Republic of China governing inspections and investigations of audit firms based in China, which marks the first step toward providing access for the PCAOB to inspect and investigate registered public accounting firms in China without any limitations on scope. However, uncertainties exist with respect to the implementation of this framework. The PCAOB is now required to reassess its determinations for purposes of the HFCAA by the end of 2022. Whether the PCAOB will be able to conduct inspections of our auditor before the issuance of our financial statements on Form 20-F in the future, or at all, is subject to substantial uncertainty and depends on a number of factors out of our control. If we are unable to meet the PCAOB inspection requirement in time, we could be delisted from the Nasdaq Stock Market and our ADSs will not be permitted for trading “over-the-counter” either. Such a delisting would substantially impair your ability to sell or purchase our ADSs when you wish to do so, and the risk and uncertainty associated with delisting would have a negative impact on the price of the ADSs. Any such risk could result in a material change in our operations and/or the value of our securities, or could significantly limit or completely hinder our ability to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

      2

Furthermore, the PRC anti-monopoly
regulators have promulgated new anti-monopoly and competition laws and regulations or related drafts for public comments from time
to time and strengthened the enforcement of these laws and regulations. There remains uncertainties as to how the laws, regulations
and guidelines recently promulgated will be implemented or whether the relevant drafts will be adopted in the current form
ultimately, and whether these laws, regulations and guidelines will have a material impact on our business, financial condition,
results of operations and prospects. We cannot assure you that our business operations comply with such regulations and
authorities’ requirements in all respects. If any non-compliance were found by relevant authorities and determined against us,
we may be subject to fines and other penalties. See “Item 3. Key Information—Risk Factors—Risks Relating to Our
Business and Industry— We and our business partners with which we collaborate are subject to anti-corruption, anti-bribery,
anti-money laundering, and similar laws, and noncompliance with such laws can subject us to criminal penalties or significant fines
and harm our business and reputation.”

The PRC government has published
new policies that significantly affected certain industries such as the education and internet industries (where some of our clients operate), and we cannot
rule out the possibility that it will in the future release regulations or policies regarding our industry that could adversely
affect our business, financial condition and results of operations. Furthermore, the PRC government has recently indicated an intent
to exert more oversight and control over overseas securities offerings and other capital markets activities and foreign investment
in China-based companies like us. Any such action, once taken by the PRC government, could cause the value of our securities to
significantly decline or in extreme cases, become 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.

Response

In response to the Staff’s comment, the Company respectfully undertakes to clarify that the Company is considered the primary beneficiary of the VIEs only for accounting purposes throughout its future Form 20-F filings.

3. We note your response to prior comment 5. Please also include this language in the summary of risk factors bullet points.

Response

In
response to the Staff’s comment, the Company respectfully undertakes to include the following revised language in the summary
of risk factors bullet points in its future Form 20-F filings.

We face various legal and operational risks and uncertainties
as a company based in and primarily operating in China. The PRC government has significant authority to exert influence on the
ability of a China-based company, like us, to conduct its business, accept foreign investments or list on a U.S. stock exchange.
may intervene or influence our operations at any  time, or may  exert more control over offerings conducted overseas and/or
foreign investment in China-based issuers, which could result in a material change in our operations and/or the value of the securities
we are registering for sale. For example, we face risks associated with regulatory approvals of offshore offerings, anti-monopoly
regulatory actions, cybersecurity and data privacy, as well as the lack of inspection from the Public Company Accounting Oversight Board
(United States), or the PCAOB, on our auditors. The PRC government may also intervene with or influence our operations as the government
deems appropriate to further regulatory, political and societal goals. Any  actions by the Chinese government to exert more oversight
and control over offerings that are conducted overseas and/or foreign investment in China-based issuers could significantly limit or completely
hinder our ability to offer or continue to offer securities to investors and cause the value of such securities to significantly
decline or be worthless.

      3

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.

    Response

    In response to the Staff’s comment, the Company intends to revise
    the following disclosure in its future Form 20-F filings in the summary of risk factors bullet points (with deletions shown as strikethrough
    and additions underlined), subject to updates and adjustments to be made in connection with any material development of the subject matter
    being disclosed:

    Permissions Required from the PRC Authorities for Our Operations

    …

    Furthermore,
    in connection with our previous issuance of securities to foreign investors, under currently effective PRC laws and
    regulations, as of the date of this annual report, we are not aware of, after due and careful enquiry, including consultation with
    our PRC legal counsel, any PRC laws or regulations which explicitly require us, our PRC subsidiaries or the VIEs to obtain any approval
    or permission from the CSRC, the CAC or any other PRC governmental authorities, nor have we, our PRC subsidiaries and the VIEs received
    any formal inquiry, notice, warning or sanction from any PRC governmental authorities in connection with requirements of obtaining such
    approval or permission, under any currently effective PRC laws, regulations and regulatory rules.

    …

Condensed Consolidating Schedule, page 56

5. We note your response to comment 10 and your proposed disclosure. Please disaggregate your WFOE 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 "Investment