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November 16, 2023
Vivien Weiwei Wang
Chief Financial Officer
iHuman Inc.
Floor 8, Building B
No. 1 Wangjing East Road
Chaoyang District, Beijing 100102
People’s Republic of China
Re:iHuman Inc.
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated October 24, 2023
File No. 001-39591
Dear Vivien Weiwei Wang:
            We have reviewed your October 24, 2023 response to our comment letter and have the
following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our September 26, 2023
letter.
Response Letter dated October 24, 2023
"Our business generates and processes data in the ordinary course, and we are required to
comply with PRC and . . . ", page 23
1.We note your proposed revised disclosure in response to comment 1, including that you
have been "advised" by PRC counsel that you are not required to apply with the
Cybersecurity Review Office for a cybersecurity review and that you are in compliance
with the permissions and approvals requirements under the existing PRC regulations and
policies on cybersecurity, data security and personal data protection issued by the
CAC. Please tell us if you are relying on the opinion of counsel in this context and if so,
please revise to state as much.  If you are not relying on the opinion of counsel, please
revise to state as much, and explain why not.

 FirstName LastNameVivien Weiwei Wang
 Comapany NameiHuman Inc.
 November 16, 2023 Page 2
 FirstName LastNameVivien Weiwei Wang
iHuman Inc.
November 16, 2023
Page 2
General
2.We note your response to comment 2, as well as your proposed revised disclosure
that "[i]f we or the VIE is found to be in violation of any existing or future laws or
regulations in mainland China, or fail to obtain or maintain any of the required permits or
approvals, the relevant mainland China regulatory authorities would have a certain degree
of discretion within their scope of authority to take action in dealing with such violations
or failures."  Please revise to revert to your original disclosure that "China regulatory
authorities would have broad discretion to take action in dealing with such violations or
failures." Please tell us what your disclosure will look like.
3.We note your proposed revised disclosure that the "mainland China government
has significant oversight and discretion over the conduct of our business, and may
intervene or influence our operations."  In future filings, please revise to disclose that the
mainland China government may intervene or influence your operations at any time,
which could result in a material change in your operations and/or the value of your
securities.  Please tell us what your disclosure will look like.
4.We note your proposed revised disclosure that “[t]he interpretation and application of
current and future laws, regulations and rules in mainland China regarding the status of
the rights of our Cayman Islands holding company with respect to its contractual
arrangements with the VIE and its shareholders are subject to changes.”  Please revise to
revert to your original disclosure that “[t]here are substantial uncertainties regarding the
interpretation and application . . . .”  (Emphasis added).  Please tell us what your
disclosure will look like.
5.We note your proposed revised disclosure that "the mainland China government may
promulgate certain regulations and rules to exert more oversight over offerings that are
conducted overseas and foreign investment in mainland China-based issuers depending on
the facts and circumstances," and that, "[i]n the event that we fail to comply with any legal
and regulatory requirements of mainland China in relation to overseas securities issuance
or foreign investment, our ability to offer or continue to offer securities to investors could
be significantly limited or completely hindered and the value of such securities could
significantly decline or become worthless."  In future filings, please revise to clarify that,
given recent statements by the Chinese government indicating an intent to exert more
oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers, any such action 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.  In revising your disclosure, please also
refrain from indicating that such changes may be "depending on the facts and
circumstances."  Please tell us what your disclosure will look like.  In this regard, while
we note your response that you are "not owned or controlled by a governmental entity of
mainland China," we remind you that, pursuant to federal securities rules, the term
“control” (including the terms “controlling,” “controlled by,” and “under common control

 FirstName LastNameVivien Weiwei Wang
 Comapany NameiHuman Inc.
 November 16, 2023 Page 3
 FirstName LastName
Vivien Weiwei Wang
iHuman Inc.
November 16, 2023
Page 3
with”) means “the possession, direct or indirect, of the power to direct or cause the
direction of the management and policies of a person, whether through the ownership of
voting securities, by contract, or otherwise."
            Please contact Robert Shapiro at 202-551-3273 or Stephen Kim at 202-551-3291 if you
have questions regarding comments on the financial statements and related matters. Please
contact Brian Fetterolf at 202-551-6613 or Cara Wirth at 202-551-7127 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Peng Dai, Chief Executive Officer