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 May 20, 2025

Ivy Zhen
Chief Financial Officer
MicroCloud Hologram Inc.
Room 302, Building A, Zhong Ke Na Neng Building,
Yue Xing Sixth Road, Nanshan District,
Shenzhen, People's Republic of China 518000

 Re: MicroCloud Hologram Inc.
 Form 20-F for the fiscal year ended December 31, 2024
 File No. 001-40519
Dear Ivy Zhen:

 We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 20-F for the fiscal year ended December 31, 2024
Risk Factors
If our equity ownership is challenged by the PRC authorities..., page 23

1. We note changes you made to your disclosure 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
filing of your
 prior Form 20-F on April 2, 2024, which 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.
Operating and Financial Review and Prospects
Key Factors Affecting Results of Operations, page 65

2. You state that your ability to increase the number of customers and
average revenue
 for holographic technology services are key factors affecting your
results. In addition,
 May 20, 2025
Page 2

 on page 5 you discuss how your results of operations may be harmed if
your are
 unable to retain customers. We further note in response to comment 27 in
your letter
 dated December 30, 2021, you added the number of customers and customer
retention
 rates to your disclosures. Please revise to disclose the number of
customers and
 customer retention rate for each period presented or tell us what
measures
 management uses to monitor customer expansion and retention, and include
a
 quantified discussion of such measures in future filings. Similarly,
tell us what
 measures you use to manage the holographic solutions business and revise
 accordingly. Refer to SEC Release 33-10751.
Results of Operations
Revenue, page 68

3. Please revise to include the segment results, as disclosed on page F-40,
and include a
 discussion of the period-over-period changes for each segment in future
filings.
 Ensure that your revised disclosures include a quantified discussion of
the impact of
 the Yichang Ji Yue acquisition on your cost of revenue for your
holographic
 technology service segment. In this regard, we note you attribute the
significant
 growth in cost of revenue to such transaction in your disclosures on
page 69, without
 quantifying such impact. Refer to Item 5.A of Form 20-F and Section
III.B of SEC
 Release 33-8350.
4. You disclose service revenue increased from the year ended December 31,
2023 to the
 year ended December 31, 2024 due to increased marketing efforts on the
internet
 advertising business. However, you attribute the significant increase in
cost of
 services revenue for the same period mainly due to the business
combination of
 Beijing Ji Yue and Yihang Ji Yue in 2024. Please revise in future
filings to quantify
 and discuss the impact of this acquisition on service revenue and
separately quantify
 the impact of the increased marketing efforts on the increase in
revenue.
General and administrative expenses, page 70

5. You indicate that the reason for the reduction in general and
administrative expenses
 from the year ended December 31, 2023 compared to the year ended
December 31,
 2024 was due the company implementing an employee equity incentive plan
in 2023.
 Please tell us, and revise in future filings to explain, how this
resulted in a decrease in
 this line item.
Consolidated Balance Sheets, page F-3

6. We note that on September 27, 2024, 100.0 million Ordinary Shares were
re-
 designated as Class B Ordinary Shares with 20 votes per share.
Disclosures on page
 81 indicate that Tiger Initiative Investment Ltd. and Lucky Monkey
Holding Limited
 hold 10.0 million and 6.0 million shares, respectively at December 31,
2024. Please
 tell how you determined which shareholders would receive Class B
Ordinary shares.
 Clarify whether Class B shares were issued to any other shareholders and
if so, how
 many. Also, explain why such shares are not reflected in the December
31, 2024
 financial statements or revise as necessary.
 May 20, 2025
Page 3

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Melissa Kindelan at 202-551-3564 or Kathleen Collins at
202-551-
3499 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
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