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CORRESP Filing

KE Holdings Inc.
Date: July 22, 2025 · CIK: 0001809587 · Accession: 0001104659-25-069441

Financial Reporting Regulatory Compliance Internal Controls

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File numbers found in text: 001-39436

Referenced dates: July 17, 2025

Date
July 22, 2025
Author
/s/ Tao Xu
Form
CORRESP
Company
KE Holdings Inc.

Letter

VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Securities and Exchange Commission Re: KE Holdings Inc. (the "Company") Form 20-F for the Fiscal Year Ended December 31, 2024 Response dated July 10, 2025 File No. 001-39436

Dear Ms. Monick and Mr. Efron:

This letter sets forth the Company's responses to the comments contained in the letter dated July 17, 2025 from the staff (the " Staff ") of the Securities and Exchange Commission (the " Commission ") regarding the Company's annual report on Form 20-F for the fiscal year ended December 31, 2024 filed with the Commission on April 17, 2025 (the " 2024 Form 20-F ") and the Company's response dated July 10, 2025. The Staff's comments are repeated below in bold and are followed by the Company's responses thereto. All capitalized terms used but not defined in this letter shall have the meaning ascribed to such terms in the 2024 Form 20-F.

Form 20-F for the Fiscal Year Ended December 31, 2024

Notes to Consolidated Financial Statements

2. Significant Accounting Policies, page F-20

1. We note your response to our prior comment 2, which clarifies the nature of the line item for customer deposits payable. Please confirm you will also disclose the nature of this line item in future filings.

The Company confirms that it will disclose the nature of this line item in future Form 20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

* * *

If you have any additional questions or comments regarding the 2024 Form 20-F, please contact the Company's U.S. counsel, Haiping Li of Skadden, Arps, Slate, Meagher & Flom LLP, at +852 3740-4835 or haiping.li@skadden.com. Thank you very much.

Very truly yours,
/s/ Tao Xu

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CORRESP
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 KE Holdings Inc.

 Oriental Electronic Technology Building

 No. 2 Chuangye Road, Haidian District

 Beijing 100086

 People's Republic of China

 July 22, 2025

 VIA EDGAR

 Ms. Jennifer Monick

 Mr. Howard Efron

 Division of Corporation Finance

 Office of Real Estate & Construction

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: KE Holdings Inc. (the "Company")

 Form 20-F for the Fiscal Year Ended December 31, 2024

 Response dated July 10, 2025

 File No. 001-39436

 Dear Ms. Monick and Mr. Efron:

 This letter sets forth the
Company's responses to the comments contained in the letter dated July 17, 2025 from the staff (the " Staff ")
of the Securities and Exchange Commission (the " Commission ") regarding the Company's annual report on Form 20-F
for the fiscal year ended December 31, 2024 filed with the Commission on April 17, 2025 (the " 2024 Form 20-F ")
and the Company's response dated July 10, 2025. The Staff's comments are repeated below in bold and are followed by the
Company's responses thereto. All capitalized terms used but not defined in this letter shall have the meaning ascribed to such terms
in the 2024 Form 20-F.

 Form 20-F for the Fiscal Year Ended
December 31, 2024

 Notes to Consolidated Financial Statements

 2. Significant Accounting Policies, page F-20

 1. We note your response to our prior comment 2, which clarifies the nature of the line item for customer
deposits payable. Please confirm you will also disclose the nature of this line item in future filings.

 The Company confirms that it will disclose
the nature of this line item in future Form 20-F filings, subject to updates and adjustments to be made in connection with any material
development of the subject matter being disclosed.

 * * *

 If you have any additional
questions or comments regarding the 2024 Form 20-F, please contact the Company's U.S. counsel, Haiping Li of Skadden, Arps,
Slate, Meagher & Flom LLP, at +852 3740-4835 or haiping.li@skadden.com. Thank you very much.

 Very truly yours,

 /s/ Tao Xu

 Tao Xu

 Chief Financial Officer

 cc: Yongdong Peng, Chairman of the Board of Directors and Chief Executive Officer, KE Holdings Inc.

 Haiping Li, Esq., Partner, Skadden, Arps,
Slate, Meagher & Flom LLP

 Shu Du, Esq., Partner, Skadden, Arps, Slate,
Meagher & Flom LLP

 Lanny Lu, Partner, PricewaterhouseCoopers Zhong
Tian LLP