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SEC Company Response from Kingsoft Cloud Holdings Ltd (KC, KCLHF) (CIK 0001795589) (KC) — Apr 17, 2020

Kingsoft Cloud Holdings Ltd (KC, KCLHF) (CIK 0001795589)
Date: April 17, 2020 · CIK: 0001795589 · Accession: 0001193125-20-110093

AI Filing Summary & Sentiment

Date
April 17, 2020
Author
Not clearly detected
Form
CORRESP
Company
Kingsoft Cloud Holdings Ltd (KC, KCLHF) (CIK 0001795589)

Letter

Office of Technology Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549

Dear Mr. Nolan, Mr. Spirgel, Ms. Kessman and Mr. Littlepage:

On behalf of Kingsoft Cloud Holdings Limited (the “Company”), a company incorporated under the laws of the Cayman Islands, we are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR with the Securities and Exchange Commission (the “Commission”).

To facilitate your review, we have separately delivered to you four courtesy copies of the Registration Statement, marked to show changes to the draft registration statement on Form F-1 confidentially submitted on March 30, 2020, and four copies of the submitted exhibits.

The Company is, concurrently with the Registration Statement, filing the Draft Registration Statement and all amendments thereto that were previously submitted for the non-public review of the staff of the Commission (the “Staff”), and plans to file an amendment to the Registration Statement containing the estimated price range and offering size and launch the road show as soon as legally permissible on or around May 5, 2020, subject to market conditions. As such, the Company would greatly appreciate the Staff’s continuing assistance and support in meeting its timetable.

If you have any questions regarding this submission, please contact Li He at +852 2533-3306 (li.he@davispolk.com) or Ran Li at +86 10 8567-5013 (ran.li@davispolk.com).

Thank you again for your time and attention.

Yours sincerely,

/s/ Li He

Li He

cc: Mr. Yulin Wang, Chief Executive Officer

Kingsoft Cloud Holdings Limited

Mr. David T. Zhang, Esq., Partner

Mr. Steve Lin, Esq., Partner

Kirkland & Ellis International LLP

Mr. Raymond Wong, Partner

Ms. Grace Lim, Partner

Ernst & Young Hua Ming LLP

Show Raw Text
CORRESP
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filename1.htm

CORRESP

New York
Northern California
Washington DC
São Paulo
 London

Paris
Madrid
Hong Kong
Beijing
Tokyo

 Resident Hong Kong Partners

 Davis Polk & Wardwell

 Hong Kong
Solicitors

 The Hong Kong Club Building

 3A Chater Road

Hong Kong

852 2533 3300 tel

 Karen Chan †

Yang Chu †

 James C. Lin*

Gerhard Radtke*

Martin Rogers †
 Patrick S. Sinclair*

Miranda So*

 James Wadham†

Hong Kong Solicitors

* Also Admitted in New York

† Also Admitted in England and Wales

April 17, 2020

Re:
 Kingsoft Cloud Holdings Limited (CIK: 0001795589)

 Registration Statement on Form F-1

Confidential

 Mr. Bernard Nolan

Mr. Larry Spirgel

 Ms. Inessa Kessman

Mr. Robert Littlepage

 Office of Technology

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Dear Mr. Nolan, Mr. Spirgel, Ms. Kessman and Mr. Littlepage:

On behalf of Kingsoft Cloud Holdings Limited (the “Company”), a company incorporated under the laws of the Cayman Islands, we
are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR with the Securities and Exchange Commission (the
“Commission”).

 To facilitate your review, we have separately delivered to you four courtesy copies of the Registration
Statement, marked to show changes to the draft registration statement on Form F-1 confidentially submitted on March 30, 2020, and four copies of the submitted exhibits.

The Company is, concurrently with the Registration Statement, filing the Draft Registration Statement and all amendments thereto that were
previously submitted for the non-public review of the staff of the Commission (the “Staff”), and plans to file an amendment to the Registration Statement containing the estimated price range
and offering size and launch the road show as soon as legally permissible on or around May 5, 2020, subject to market conditions. As such, the Company would greatly appreciate the Staff’s continuing assistance and support in meeting its
timetable.

 If you have any questions regarding this submission, please contact Li He at +852 2533-3306
(li.he@davispolk.com) or Ran Li at +86 10 8567-5013 (ran.li@davispolk.com).

 Thank you again for your time and attention.

Yours sincerely,

 /s/ Li He

 Li He

cc:
 Mr. Yulin Wang, Chief Executive Officer

Kingsoft Cloud Holdings Limited

Mr. David T. Zhang, Esq., Partner

Mr. Steve Lin, Esq., Partner

Kirkland & Ellis International LLP

Mr. Raymond Wong, Partner

Ms. Grace Lim, Partner

Ernst & Young Hua Ming LLP

 2