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IHUMAN INC.

Floor 8, Building
B

No. 1 Wangjing
East Road

Chaoyang District,
Beijing 100102

People’s Republic
of China

August 31, 2023

VIA EDGAR

Mr. Robert Shapiro

Mr. Stephen Kim

Mr. Christopher Dunham

Mr. Kyle Wiley

Mr. Dieter King

Mr. Brian Fetterolf

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 RE: iHuman Inc. (the “Company”)

Form 20-F
for Fiscal Year Ended December 31, 2022

Filed April 25,
2023

File No. 001-39591

Dear Mr. Shapiro, Mr. Kim,
Mr. Dunham, Mr. Wiley, Mr. King and Mr. Fetterolf:

This letter sets
forth the Company’s response to the comments contained in the letter dated August 3, 2023 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, 2022 filed with the Commission on April 25, 2023 (the “2022 Form 20-F”).
The Staff’s comments are repeated below in bold and 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 2022 Form 20-F.

Form 20-F
for the Fiscal Year Ended December 31, 2022

Item 3. Key
Information

Cash Flows
through Our Organization, page 4

 1. We note your disclosure
quantifying your cash transfers in 2020, 2021 and 2022. In future filings, where you discuss the transfers to your subsidiaries, please
revise to quantify the amounts transferred to each of Hongen Investment and Hongen EduTech. Where you discuss the transfers between your
WFOEs and the VIE, similarly distinguish between each of your two mainland China subsidiaries. Please tell us what your disclosure will
look like.

In response
to the Staff’s comment, the Company respectfully proposes to revise the referenced disclosure as follows (page reference is
made to the 2022 Form 20-F to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with
deletions shown as strike-through and additions underlined), subject to updates and adjustments to be made in connection with any material
development of the subject matter being disclosed:

    Division of Corporation Finance
 Office of Trade & Services
 Securities and Exchange Commission
 August 31, 2023
 Page 2

Page 4

“Cash
Flows through Our Organization

iHuman
Inc. is a holding company with no material operations of its own. We conduct our operations primarily through our subsidiaries, the VIE
and VIE’s subsidiaries in mainland China. As a result, iHuman Inc.’s ability to pay
dividends depends upon dividends paid by our subsidiaries in China. If our existing subsidiaries in mainland China or any newly formed
ones incur debt on their own behalf in the future, the instruments governing their debt may restrict their ability to pay dividends to
us. In addition, current regulations in mainland China permit our subsidiaries in mainland China to pay dividends to their respective
shareholders only out of their retained earnings, if any, determined in accordance with accounting standards and regulations in mainland
China. Furthermore, our subsidiaries, the VIE and VIE’s subsidiaries in mainland China are required to make appropriations to certain
statutory reserve funds or may make appropriations to certain discretionary funds, which are not distributable as cash dividends except
in the event of a solvent liquidation of the companies. There is no assurance that the mainland China government will not promulgate
or amend the laws and regulations in the future depending on the facts and circumstances, which may affect the ability of iHuman Inc.,
its subsidiaries, and the VIE to transfer cash or other assets. To the extent cash or other assets in the business are in mainland China
or a mainland China entity, the funds or other assets may not be available to fund operations or for other use outside of mainland China.
As of the date of this annual report, there is no equivalent or similar restriction or limitation in Hong Kong on cash or other assets
transfers in, or out of, our Hong Kong entities. However, if restrictions or limitations were to become applicable to cash or other assets
transfers in and out of Hong Kong entities in the future, the funds or other assets in our Hong Kong entities may not be available to
fund operations or for other use outside of Hong Kong. For more details, see “Item 3. Key Information—D. Risk Factors—Summary
of Risk Factors—Risks Related to Our Corporate Structure,” “Item 3. Key Information—D. Risk Factors— Risks
Related to Our Corporate Structure —We may rely on dividends paid by our subsidiaries in mainland China to fund cash and financing
requirements. Any limitation on the ability of our subsidiaries in mainland China to pay dividends to us could have a material adverse
effect on our ability to conduct our business and to pay dividends to holders of the ADSs and our ordinary shares,” and For
more details, see “Item 5. Operating and Financial Review and Prospects—B. Liquidity and Capital Resources—Holding
Company Structure.”

    Division of Corporation Finance
 Office of Trade & Services
 Securities and Exchange Commission
 August 31, 2023
 Page 3

We
have established stringent controls and procedures for cash flows within our organization. Each
transfer of cash between our Cayman Islands holding company and its subsidiaries, the VIE and VIE’s subsidiaries is subject to
internal approval. The cash inflows of the Cayman Islands holding company were primarily generated from the proceeds we received from
our public offerings of ordinary shares. In 2020, there was no capital contributions from iHuman Inc. to our subsidiaries in mainland
China, including Hongen Investment and Hongen Edutech. In 2021 and 2022, iHuman Inc., through its intermediate holding company,
made capital contributions of RMB63.8 million and RMB68.7 million (US$10.0 million) to Hongen Investmentour subsidiaries
in mainland China, respectively, which subsequently made transfers to Hongen Edutech, Hongen Investment’s subsidiary,
when needed, in the corresponding year. In 2020, 2021 and 2022, iHuman Inc. provided to its subsidiaries in Hong Kong loans
of RMB457.0 million, nil and nil, respectively, and received repayments of nil, RMB127.5 million and nil, respectively. For the years
ended December 31, 2020, 2021 and 2022, no assets other than cash were transferred between the Cayman Islands holding company and
its subsidiaries, the VIE and VIE’s subsidiaries; no subsidiaries paid dividends or made other distributions to the holding company;
and no dividends or distributions were paid or made to U.S. investors. We currently intend to retain most, if not all, of our available
funds and any future earnings to operate and expand our business. See “Item 8. Financial Information—A. Consolidated Statements
and Other Financial Information—Dividend Policy.” For mainland China and United States federal income tax considerations
in connection with an investment in our ADSs, see “Item 10. Additional Information—E. Taxation.”

The
VIE is required to transfer cash to our WFOEs by paying service fees according to the contractual arrangements. The VIE paid our
WFOEsHongen Edutech service fees of RMB5.0 million, RMB43.0 million and RMB89.5 million (US$13.0 million) in 2020, 2021
and 2022, respectively. In 2020, 2021 and 2022, the VIE provided to our WFOEsHongen Edutech loans of nil, RMB55.0
million and RMB126.0 million (US$18.3 million), respectively, and received repayments of nil, nil and RMB90.0 million (US$13.0 million),
respectively. From 2020 to 2022, there was no transfer of cash between the VIE and Hongen Investment. For details of the financial
position, cash flows and results of the VIE, see “Item 3. Key Information—Financial Information Related to the VIE”
and page F-13 of this annual report on Form 20-F. Going forward, we intend to transfer the benefits of the VIE and VIE’s
subsidiaries to our WFOEs under the contractual arrangements.”

    Division of Corporation Finance
 Office of Trade & Services
 Securities and Exchange Commission
 August 31, 2023
 Page 4

 2. In
                                            future filings, please revise here and in the risk factors to state that, to the extent cash
                                            and/or assets in the business are in Hong Kong/China or a Hong Kong/China entity, the funds
                                            and/or assets may not be available to fund operations or for other use outside of Hong Kong
                                            or China due to interventions in or the imposition of restrictions and limitations on the
                                            ability of you or your subsidiaries by the PRC government to transfer cash and/or assets.
                                            Provide cross-references to this discussion in the risk factors section. Please tell us what
                                            your disclosure will look like.

Please
refer to the Company’s response to Comment #1 with respect to the proposed revision to the section “Cash Flows through Our
Organization”. Furthermore, the Company respectfully proposes to revise the referenced risk factor disclosure as follows (page reference
is made to the 2022 Form 20-F to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with
deletions shown as strike-through and additions underlined), subject to updates and adjustments to be made in connection with any material
development of the subject matter being disclosed:

Page 16

“Risks
Related to Our Corporate Structure

 · […]

 · Any
                                            failure by the VIE or its shareholders to perform their obligations under our contractual
                                            arrangements with them would have a material and adverse effect on our business; and

 · The
                                            shareholders of the VIE may have actual or potential conflicts of interest with us.;
                                            and

 · We
                                            may rely on dividends paid by our subsidiaries in mainland China to fund cash and financing
                                            requirements. Any limitation on the ability of our subsidiaries in mainland China to pay
                                            dividends to us could have a material adverse effect on our ability to conduct our business
                                            and to pay dividends to holders of the ADSs and our ordinary shares.”

Pages 40-41

“We
may rely on dividends paid by our subsidiaries in mainland China to fund cash and financing requirements. Any limitation on the ability
of our subsidiaries in mainland China to pay dividends to us could have a material adverse effect on our ability to conduct our business
and to pay dividends to holders of the ADSs and our ordinary shares.

We
are a holding company, and we may rely on dividends to be paid by our subsidiaries in mainland China for our cash and financing requirements,
including the funds necessary to pay dividends and other cash distributions to the holders of the ADSs and our ordinary shares and service
any debt we may incur. If our subsidiaries in mainland China incurs debt on its own behalf in the future, the instruments governing the
debt may restrict its ability to pay dividends or make other distributions to us.

    Division of Corporation Finance
 Office of Trade & Services
 Securities and Exchange Commission
 August 31, 2023
 Page 5

There
is no assurance that the mainland China government will not promulgate or amend the laws
and regulations in the future depending on the facts and circumstances, which may affect the ability of iHuman Inc., its subsidiaries,
and the VIE to transfer cash or other assets. To the extent cash or other assets in the business are in mainland China or a mainland
China entity, the funds or other assets may not be available to fund operations or for other use outside of mainland China. See “Item
3. Key Information—Cash Flows through Our Organization.”

Under
laws and regulations in mainland China, wholly foreign-owned enterprises in mainland China, such as Hongen Investment, may pay dividends
only out of their accumulated profits as determined in accordance with accounting standards and regulations in mainland China. In addition,
a wholly foreign-owned enterprise is required to set aside at least 10% of its after-tax profits each year, after making up previous
years’ accumulated losses, if any, to fund certain statutory reserve funds, until the aggregate amount of such a fund reaches 50%
of its registered capital. Any limitation on the ability of our wholly-owned subsidiaries in mainland China to pay dividends or make
other distributions to us could materially and adversely limit our ability to grow, make investments or acquisitions that could be beneficial
to our business, pay dividends, or otherwise fund and conduct our business.

As
of the date of this annual report, there is no equivalent or similar restriction or limitation in Hong Kong on cash or other assets transfers
in, or out of, our Hong Kong entities. However, if restrictions or limitations were to become applicable to cash or other assets transfers
in and out of Hong Kong entities in the future, the funds or other assets in our Hong Kong entities may not be available to fund operations
or for other use outside of Hong Kong.

    Division of Corporation Finance
 Office of Trade & Services
 Securities and Exchange Commission
 August 31, 2023
 Page 6

Under
the PRC Enterprise Income Tax Law and related regulations, dividends, interests, rent or royalties payable by a foreign-invested enterprise,
such as our subsidiaries in mainland China, to any of its foreign non-resident enterprise investors, and proceeds from any such foreign
enterprise investor’s disposition of assets (after deducting the net value of such assets) are subject to a 10% withholding tax,
unless the foreign enterprise investor’s jurisdiction of incorporation has a tax treaty with China that provides for a reduced
rate of withholding tax. For more details, see “Item 5. Operating and Financial Review and Prospects—B. Liquidity and Capital
Resources—Holding Company Structure.” The Cayman Islands, where iHuman Inc. is incorporated, does not have such a tax treaty
with China. Hong Kong has a tax arrangement with China that provides for a 5% withholding tax on dividends subject to certain conditions
and requirements, such as the requirement that the Hong Kong resident enterprise own at least 25% of the enterprise of mainland China
distributing the dividend at all times within the 12-month period immediately preceding the distribution of dividends and be a “beneficial
owner” of the dividends. For example, iHuman Online Limited, which directly owns our subsidiaryies in mainland
China, Hongen Investment, is incorporated in Hong Kong. However, if iHuman Online Limited is not considered to qualify for any conditions
and requirements under applicable tax circulars, such dividends would be subject to withholding tax at a rate of 10%. If our subsidiaries
in mainland China declare and distribute profits to us, such payments will be subject to withholding tax, which will increase our tax
liability and reduce the amount of cash available to our company.

Permissions
Required from the PRC Authorities for Our Operations, page 6

 3. In
                                            future filings, in each instance where you refer to “permissions,” expand your
                                            discussion to also address “approvals.” With respect to all permissions or approvals
                                            discussed in this section, state affirmatively whether you