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CORRESP
 1
 filename1.htm

 MicroCloud
Hologram Inc.

 May
30, 2025

 VIA
EDGAR

 Division
of Corporation Finance

 Office
of Technology

 Securities
and Exchange Commission

 Washington,
D.C. 20549

 Attn.:
 Melissa Kindelan

 Kathleen Collins

 Re: MicroCloud
Hologram Inc.

 Form
20-F for the fiscal year ended December 31, 2024

 File
No. 001-40519

 Ladies
and Gentlemen:

 MicroCloud
Hologram Inc. (the "Company", "we", "us" or "our") hereby transmits its response to the
letter received from the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission"),
dated May 20, 2025 regarding its Form 20-F filed on March 21, 2025.

 Set
forth below are the Company's responses to the Staff's comments in the Comment Letter. The Staff's comments are retyped
below in bold for your ease of reference, and the Company's responses are set forth immediately below the 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.

 Response:
 The Company acknowledges the Staff's comment and will restore the disclosure in future filings.

 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, 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.

 Response:
 We have revised the disclosures, as detailed in Comment 2 of Annex A attached hereto.

 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.

 Response:
 We have revised the disclosures related to revenues and cost of revenues on pages 68 and
69 in 20-F, as detailed in Comments 3 & 4 of Annex A attached hereto.

 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.

 Response:
 See response in Comments 3 & 4 of Annex
A attached hereto.

 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.

 Response: The
Company filed Form S-8 on 28 August 2023 which registers 8,960,000 ordinary shares, to be issued by the Company pursuant to the 2023
Equity Incentive Plan. In 2023, 8,600,000 shares were exercised, recognizing administrative expenses of RMB 32.2 million. In 2024,
360,000 shares were exercised, recognizing administrative expenses of RMB 1.0 million.

 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.

 Response: The
Company respectfully acknowledges the Staff's comment and advises as follows:

 2

 1、Shareholders
Allocated Class B Ordinary Shares

 As
of March 12, 2025（the last executable date of the 20-F）, the Company confirms that the Class B Ordinary Shares were allocated
exclusively to Tiger Initiative Investment Ltd. and Lucky Monkey Holding Limited in accordance with the Convertible Note Purchase Agreement
(Form 6-K filed with the SEC on August 15, 2024). As of March 12, 2025, no Class B Ordinary Shares had been issued to other shareholders.

 2、Clarification
on Share Re - designation Date and Financial Statement Presentation

 Pursuant
to the requirements of Form 20 - F under the United States Securities Exchange Act, the date referenced in Annex A, Comment 6 has been
revised to March 12, 2025 to reflect the most recent practicable date as mandated by SEC regulations. The 10.0 million and 6.0 million
shares of Class B Ordinary Shares held by Tiger Initiative Investment Ltd. and Lucky Monkey Holding Limited, respectively, were all issued
by the Company in 2025. Disclosures on page 81 set forth that the share distribution as of March 12, 2025. Pursuant to ASC 505-10-S99-4,
as this situation does not constitute a stock dividend, stock split or reverse split, the Company is not required to give retroactive
effect in the balance sheet. Accordingly, such shares are not reflected in the December 31, 2024 financial statements.

 If
you have any questions regarding the Company's responses to the Staff's comments, please contact us via e-mail at ivy@mcvrar.com
or by phone at +86 (0755) 2291 2036.

 Very truly
 yours,

 /s/
 Ivy Zhen

 Ivy Zhen

 Chief Financial Officer

 3

 Annex
A

 Comments
2

 Key
Factors Affecting Results of Operations

 Our
results of operations are affected by the factors discussed below.

 Our
ability to increase the number of customers and average revenue for Holographic technology services

 Approximately
68.4%, 66.4% and 55.6% of our revenues were generated from our Holographic technology services for the years ended December 31, 2022,
2023 and 2024 respectively.

The
Company's total customers were 180 and 119, respectively for the years ended December 31, 2022 and 2023, representing a33.9%
decrease, of which 76 are new customers. The decrease in the number of customers led to a decline in total revenue. Total customers were
119 and 142, respectively for the year ended December 31, 2023 and 2024, representing a 19.3% increase, of which 102 are new customers.
Due to the increase in the total number of customers, the total revenue has also increased.

The
Company considers customers with or over RMB 0.5 million revenue as high paying customers. The numbers of high payment customers
are 65 and 42, respectively for the years ended December 31, 2022 and 2023, representing 97.5% and 96.1% of total revenue for
each period and a 58.9% decrease. The numbers of high payment customers are 42 and 69, respectively for the years ended December 31,
2023 and 2024, representing 96.1% and 96.6% of total revenue for each period and a 43.4% increase. the Company's overall customer
retention rates are 31% and 24% respectively for the years ended December 31, 2022 and 2023. Retention rates of high paying customer
are 38% and 29% respectively for the same period. Retention rates of the Company's top 10 customers are both 50% for the years
ended December 31, 2022, and 2023, respectively. Retention rates of the Company's top 20 customers are 45% and 55% for the
years ended December 31, 2022, and 2023, respectively.

The
Company's overall customer retention rates are 24% and 34% respectively for the year ended December 31, 2023 and 2024. Retention
rates of high paying customer are 29% and 43% respectively for the same period. Retention rates of the Company's top 10 customers
are50% and 30% for the year ended December 31, 2023 and 2024, respectively. Retention rates of the Company's top 20 customers
are 55% and 20% for the year ended December 31, 2023 and 2024, respectively. Retention rate is calculated by first counting the
number of customers at the beginning of the period (denominator) and the number of old customers during measurement period (numerator),
then dividing the numerator by the denominator. Old customers repeating customer who keeps loyalty to the company's services throughout
the measurement periods and calculated as number of total customers at the end of measurement period minus new customers obtained during
the measurement period. Customers counted for the purpose of calculating retention rate are based on those that were customers at any
point during the period. The Company's total customers increase from 119 for the year ended December 31, 2023 to 142 for year
ended December 31, 2024. The increase is mainly due to (i) the business combination of Beijing Ji Yue and Yichang Ji Yue in 2024,
which brought in 51 new customers. (ii) The Company disposed of Shenzhen Youmi, Qianhai Youshi, Shenzhen Tianyuemeng and their subsidiaries
in 2023, led to 31 old customers to cease collaboration.

The
Company's overall customer retention rates are 24% and 34%, for the year ended December 31, 2023 and 2024. This is due to
the fact that the company adopts ​data-driven customer management. The company leverage data analytics
to deliver ​personalized product solutions​ and ​tailored
service experiences​ to improve our service quality. Additionally, by monitoring ​
performance metrics such as high paying customers​ rate and ​new customer
acquisition rate, we dynamically allocate resources to prioritize key accounts while optimizing client relationship maintenance frameworks.

 Our
ability to increase our revenues and enhance our profitability will depend on our ability to continue to increase our customer base and
revenue per customer for our Holographic technology services. To achieve this, we strive to increase our marketing efforts and to enhance
the quality and capabilities of our technologies.

 4

 Comments
3 & 4

 Revenues

 We
generate revenues primarily through (i) sales of product related to holographic solutions services, which include LiDAR and other holographic
technology hardware products, licensing and content products, and technology development service, and (ii) services related to holographic
technology services, which include holographic technology advertising, software development kit ("SDK") service, and game
promotion services.

 Our
breakdown of revenues for the years ended December 31, 2022, 2023 and 2024, respectively, is summarized below:

 Year ended December 31,

 2022
 2023
 2024

 RMB
 RMB
 RMB

 Amount
 Percentage
 Amount
 Percentage
 Amount
 Percentage

 Revenues:

 Products
 124,609,677
 26 %
 22,401,569
 11 %
 7,903,228
 3 %

 Services
 363,329,187
 74 %
 181,146,436
 89 %
 282,394,756
 97 %

 Total revenues
 487,938,864
 100 %
 203,548,005
 100 %
 290,297,984
 100 %

 Products
Revenues

 Our
products revenue was RMB 7.9 million (USD 1.1 million) for 2024, compared to RMB 22.4 million and RMB 124.6 million, respectively, for
2023 and 2022.

 Our
product revenue decreased by approximately RMB 102.2 million from approximately RMB 124.6 million for the year ended December 31, 2022
to approximately RMB 22.4 million for the year ended December 31, 2023. A decrease of 82.0%. The decrease was mainly due to market changes
affecting the demand for our products and the reduced demand for holographic solutions from our customers.

 The
revenue of our products, which decreased by approximately RMB 14.5 million, decrease of 64.7%, from approximately RMB 22.4 million for
the year ended December 31, 2023, compared to approximately RMB 7.9 million (USD 1.1 million) for the year ended December 31,
2024. The decline is due to the reduced demand for holographic solutions from our customers.

 Services
Revenues

 Our
Services revenues was RMB 282.4 million (USD 39.7 million) for 2024, compared to RMB 181.1 million and RMB 363.3 million, respectively,
for 2023 and 2022.

 Our
services revenue decreased by approximately RMB 182.2 million, or 50.1%, from approximately RMB 363.3 million for the year ended December 31,
2022, to approximately RMB 181.1 million for the year ended December 31, 2023. This decrease was mainly attributed to the overall
market environment for Internet advertising, with lower customer demand and fewer customers.

 Our
services revenue increased by approximately RMB 101.2 million, or 55.9%, from approximately RMB 181.1 million for the year ended December 31,
2023, to approximately RMB 282.4 million (USD 39.7 million) for the year ended December 31, 2024. This increase was mainly attributed
to the increased marketing efforts on the Internet advertising business, which tapped the potential demand of customers and increased
the number of customers.

 5

 Year ended December 31,

 2022
 2023
 2024

 RMB
 RMB
 RMB

 Amount
 Percentage
 Amount
 Percentage
 Amount
 Percentage

 Revenues:

 Holographic solutions
 153,996,661
 32 %
 68,345,506
 34 %
 128,892,234
 44 %

 Holographic technology service
 333,942,203
 68 %
 135,202,499
 66 %
 161,405,749
 56 %

 Total revenues
 487,938,864
 100 %
 203,548,005
 100 %
 290,297,984
 100 %

 Holographic
solutions Revenues

Our
holographic solutions revenues was RMB 128.9 million (USD18.1 million) for 2024, compared to RMB 68.3 million and RMB 154.0 million,
respectively, for 2023 and 2022.

Our
holographic solutions revenues decreased by approximately RMB 85.7 million from approximately RMB 154.0 million for the year ended December
31, 2022 to approximately RMB 68.3 million for the year ended December 31, 2023. A decrease of 55.6%. The decrease was mainly due to
market changes affecting the demand for our products and the reduced demand for holographic solutions from our customers.

The
revenues of our holographic solutions, which increased by approximately RMB 60.5 million, crease of 88.6%, from approximately RMB 68.3
million for the year ended December 31, 2023, compared to approximately RMB 128.9million (USD 18.1 million) for the year ended December 31,
2024. This significant increase was mainly attributable to the business expansion of Mcloudvr HK in 2024, which has brought a significant
increase of RMB 69.1 million in holograp