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CORRESP
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    December 5,
2024

    Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Kingsoft Cloud Holdings Ltd

    Form 20-F for the Fiscal Year Ended December 31, 2023

    File No. 001-39278

    Attn:
    Division of Corporation Finance

Office of Technology

VIA EDGAR

Dear Anastasia Kaluzienski and Robert Littlepage:

This letter sets forth the responses of Kingsoft
Cloud Holdings Ltd (the “Company”) to the comments (the “Comments”) the Company received from the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a letter dated
November 21, 2024. For the Staff’s convenience, we have included herein the Comments in bold, and the Company’s responses
are set forth immediately below the Comments.

General Note to the Staff

The Company respectfully submits in this letter its proposed updates
to the disclosures contained in the annual report for the year ending December 31, 2023 (the “2023 Annual Report”),
which, subject to the Staff’s review and further regulatory developments (if applicable), will be included in the Company’s
annual report for the year ending December 31, 2024 (the “2024 Annual Report”) and future filings, to the extent
applicable. All capitalized terms used but not defined in this letter shall have the meaning ascribed to such terms in the 2023 Form 20-F.

Form 20-F for the year ended 12/31/23

Introduction, page 1

 1. We note from your disclosure on page 1 that you exclude Hong Kong and Macau from your definition of “PRC” or “China”
for the purpose of your annual report. Please revise to remove the exclusion of Hong Kong and Macau from such definition. Clarify that
all the legal and operational risks associated with having operations in the People’s Republic of China (PRC) also apply to operations
in Hong Kong and Macau. In this regard, ensure that your disclosure does not narrow risks related to operating in the PRC to mainland
China only. Where appropriate, you may describe PRC law and then explain how law in Hong Kong and Macau differs from PRC law and describe
any risks and consequences to the company associated with those laws.

In response to the Staff’s comment, the Company proposes
to revise the definition of “China” or “PRC” on page 1 of the 2023 Annual Report in future filings as follows,
with the removed disclosure crossed out for ease of reference:

 · “China” or “PRC” refers to the People’s Republic of China; and only in the context of describing
PRC laws, regulations and other legal or tax matters in this annual report, excludes Taiwan, Hong Kong, and Macau;

The Company also proposes to further supplement the risk
factors section by inserting the below disclosure to clarify that operational risks associated with operations in mainland China also
apply to Hong Kong, with the added disclosure underlined for ease of reference:

Page 9 of the 2023 Annual Report

You should carefully consider all
of the information in this annual report before making an investment in the ADSs. Below please find a summary of the principal risks and
uncertainties we face, organized under relevant headings. In particular, as we are a China-based company incorporated in the Cayman Islands,
you should pay special attention to subsections headed “Item 3. Key Information—3.D. Risk Factors—Risks Relating to
Doing Business in China” and “Item 3. Key Information—3.D. Risk Factors—Risks Relating to Our Corporate Structure
and the Contractual Arrangements.” The operational risks associated with being based in and having operations in mainland China
also apply to operations in Hong Kong. The legal risks associated with being based in and having operations in mainland China are expected
to apply to mainland China entities and businesses, rather than entities or businesses in Hong Kong and Macau, if any, which operate under
a different set of laws from mainland China.

    1

Page 51 of the 2023 Annual Report

You may experience difficulties in effecting service
of legal process, enforcing foreign judgments or bringing actions in China against us or our management based on foreign laws.

We are a company incorporated under
the laws of the Cayman Islands, we conduct substantially all of our operations in China, and substantially all of our assets are located
in China. In addition, all our senior executive officers reside within China for a significant portion of time and most are PRC nationals.
As a result, it may be difficult for our shareholders to effect service of process upon us or those persons inside China. In addition,
China does not have treaties providing for the reciprocal recognition and enforcement of judgments of courts with the Cayman Islands and
many other countries and regions. Therefore, recognition and enforcement in China of judgments of a court in any of these non-PRC jurisdictions
in relation to any matter not subject to a binding arbitration provision may be difficult or impossible.

Shareholder claims that are common
in the United States, including securities law class actions and fraud claims, generally are difficult to pursue as a matter of law or
practicality in China. For example, in China, there are significant legal and other obstacles to obtaining information needed for shareholder
investigations or litigation outside China or otherwise with respect to foreign entities. Although the local authorities in China may
establish a regulatory cooperation mechanism with the securities regulatory authorities of another country or region to implement cross-border
supervision and administration, such regulatory cooperation with the securities regulatory authorities in the United States has not been
efficient in the absence of a mutual and practical cooperation mechanism. According to Article 177 of the PRC Securities Law, which
became effective in March 2020, no overseas securities regulator is allowed to directly conduct investigation or evidence collection
activities within the territory of the PRC. Accordingly, without the consent of the competent PRC securities regulators and relevant authorities,
no organization or individual may provide the documents and materials relating to securities business activities to overseas parties.

There is uncertainty as to whether
the judgment of United States courts will be directly enforced in Hong Kong, as the United States and Hong Kong do not have a treaty or
other arrangements providing for reciprocal recognition and enforcement of judgments of courts of the United States in civil and commercial
matters. However, a foreign judgment may be enforced in Hong Kong at common law by bringing an action in a Hong Kong court since the judgment
may be regarded as creating a debt between the parties to it, provided that the foreign judgment, among other things, is a final judgment
conclusive upon the merits of the claim and is for a liquidated amount in a civil matter and not in respect of taxes, fines, penalties,
or similar charges. Such a judgment may not, in any event, be so enforced in Hong Kong if (a) it was obtained by fraud; (b) the
proceedings in which the judgment was obtained were opposed to natural justice; (c) its enforcement or recognition would be contrary
to the public policy of Hong Kong; (d) the court of the United States was not jurisdictionally competent; or (e) the judgment
was in conflict with a prior Hong Kong judgment.”

Page 53 of the 2023 Annual Report

We may rely on dividends and other distributions on
equity paid by our PRC subsidiaries to fund any cash and financing requirements we may have, and any limitation on the ability of our
PRC subsidiaries to make payments to us could have a material and adverse effect on our ability to conduct our business.

We are a Cayman Islands holding
company and we rely principally on dividends and other distributions on equity from our PRC subsidiaries for our cash requirements, including
for services of any debt we may incur. The ability of our PRC subsidiaries to pay dividends and other distributions on equity, in turn,
depends on the payment they receive from the VIEs as service fees pursuant to certain contractual arrangements among our PRC subsidiaries,
the VIEs and the VIEs’ shareholders entered into to comply with certain restrictions under PRC law on foreign investment. For more
details related to the VIE structure, please see “Item 4. Information on the Company—4.C. Organizational Structure—Contractual
Arrangements with the VIEs and Their Respective Shareholders.”

    2

Our PRC subsidiaries’ ability
to distribute dividends is based upon their distributable earnings. Current PRC regulations permit our PRC subsidiaries to pay dividends
to their respective shareholders only out of their accumulated profits, if any, determined in accordance with PRC accounting standards
and regulations. In addition, each of our PRC subsidiaries and each of the VIEs and their subsidiaries is required to set aside at least
10% of its after-tax profits each year, if any, to fund a statutory reserve until such reserve reaches 50% of each of their registered
capitals. These reserves are not distributable as cash dividends. If our PRC subsidiaries incur debt on their own behalf in the future,
the instruments governing the debt may restrict their ability to pay dividends or make other payments to us. Any limitation on the ability
of our PRC subsidiaries to distribute dividends or other payments to their respective shareholders could materially and adversely limit
our ability to grow, make investments or acquisitions that could be beneficial to our businesses, pay dividends or otherwise fund and
conduct our business.

With respect to our Hong Kong
entities, although currently there are not equivalent or similar restrictions or limitations in Hong Kong on cash transfers in, or out
of, our Hong Kong entities (including currency conversion), if certain restrictions or limitations in mainland China were to become applicable
to cash transfers in and out of Hong Kong entities (including currency conversion) in the future, the funds in our Hong Kong entities,
likewise, may not be available to meet our cash demand.”

Page 56 of the 2023 Annual Report

Governmental control of currency conversion may limit
our ability to utilize our revenues effectively and affect the value of your investment.

The PRC government imposes controls
on the convertibility of the Renminbi into foreign currencies and, in certain cases, the remittance of currency out of China. We receive
substantially all of our revenues in Renminbi. Under our current corporate structure, our Cayman Islands holding company primarily relies
on dividend payments from our PRC subsidiaries to fund any cash and financing requirements we may have. Under existing PRC foreign exchange
regulations, payments of current account items, including profit distributions, interest payments and trade and service-related foreign
exchange transactions, can be made in foreign currencies without prior approval of SAFE by complying with certain procedural requirements.
Specifically, under the existing exchange restrictions, without prior approval of SAFE, cash generated from the operations of our PRC
subsidiaries in China may be used to pay dividends to our company. However, approval from or registration with appropriate government
authorities is required where Renminbi is to be converted into foreign currency and remitted out of China to pay capital expenses such
as the repayment of loans denominated in foreign currencies. As a result, we need to obtain SAFE approval to use cash generated from the
operations of our PRC subsidiaries and VIEs to pay off their respective debt in a currency other than Renminbi owed to entities outside
China, or to make other capital expenditure payments outside China in a currency other than Renminbi. The PRC government may at its discretion
restrict access to foreign currencies for current account transactions in the future. If the foreign exchange control system prevents
us from obtaining sufficient foreign currencies to satisfy our foreign currency demands, we may not be able to pay dividends in foreign
currencies to our shareholders, including holders of the ADSs. Although currently there are not equivalent or similar restrictions
or limitations in Hong Kong on cash transfers in, or out of, our Hong Kong entities (including currency conversion), if certain restrictions
or limitations in mainland China were to become applicable to cash transfers in and out of Hong Kong entities (including currency conversion)
in the future, the funds in our Hong Kong entities, likewise, may not be available to meet our currency demand.

Part I, page 4

 2. We note your disclosure that the VIE structure allows you to be considered the primary beneficiary of the VIEs, which serves the
purpose of consolidating the VIEs’ operating results in your financial statements under U.S. GAAP. Please revise to ensure that
any references to control or benefits that accrue to you because of the VIEs are limited to a clear description of the conditions you
have satisfied for consolidation of the VIEs under U.S. GAAP. Additionally, your revised disclosure should clarify that you are the primary
beneficiary of the VIEs for accounting purposes.

In
response to the Staff’s comment, the Company intends to revise the following disclosure under Part I on page 4
of the 2023 Annual Report in future filings as follows, with the added disclosure underlined and the removed disclosure crossed out for
ease of reference:

This structure allows us to be considered
the primary beneficiary of the VIEs for accounting purposes, which serves the purpose of consolidating the VIEs’ operating
results in our financial statements under the U.S. GAAP, to the extent the conditions for consolidation of VIEs under
U.S. GAAP are satisfied.

The
Company also intends to revise the following disclosure under Part I on page 117 of the 2023 Annual Report in future
filings as follows, with the added disclosure underlined and the removed disclosure crossed out for ease of reference:

As a result of these contractual
arrangements, we are considered the primary beneficiary of the VIEs for accounting purposes and consolidate their operating results
in our financial statements under U.S. GAAP, to the extent the conditions for consolidation of VIEs under U.S. GAAP are satisfied.

    3

3.D. Risk Factors

Changes in China's economic or social conditions
or government policies..., page 50

 3. We note changes you made to your disclosure appearing on pages 5, 7, and 50 relating to legal and operational risks associated
with operating in China and PRC regulations. It is unclear to us that there have been changes in the regulatory environment in the PRC
since the prior 20-F review completed August 4, 2023 that would warrant revised disclosure to mitigate the challenges you face and
related disclosures. For additional guidance, please refer to the Division of Corporation Finance’s Sample Letter to China-Based
Companies, issued December 2021 and July 2023. In future filings, please restore your disclosure.

In response to the Staff’s comment,
the Company respectfully undertakes to restore the disclosure on page 5, 7 and 50 of the 2023 Annual Report relating to legal and
operational risks associated with operating in China and PRC regulations, in future filings.

You may experience difficulties effecting
service of legal process..., page 51

 4. We note your disclosure that all of your senior executive officers reside within China for a significant portion of time and most
are PRC nationals. In future filings, please identify any directors, officers, or members of senior management located in the PRC/Hong
Kong. Additionally, please include a separate "Enforceability" section that addresses whether or not investors may bring actions
under the civil liability provisions of the U.S. federal secu