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    Davis Polk & Wardwell

    Hong Kong Solicitors

    The Hong Kong Club Building

    3A Chater Road

    Hong Kong

    davispolk.com

    Resident Hong Kong Partners

    Yang Chu **

    James C. Lin *

    Gerhard Radtke *

    Martin Rogers **

    Miranda So *

    James Wadham **

    Xuelin Wang *

    Hong Kong Solicitors

    * Also Admitted in New York

    ** Also Admitted in England and
    Wales

    November 24, 2023

    Re:
    ZEEKR Intelligent Technology Holding Limited (CIK: 0001954042)

    Registration Statement on Form F-1 Submitted November 9, 2023

Confidential

Mr. Charles Eastman

Mr. Hugh West

Mr. Bradley Ecker

Mr. Geoffrey Kruczek

Division of Corporation
Finance

Office of Manufacturing

Securities and
Exchange Commission

100 F Street, N.E.

Washington, D.C.
20549

Ladies and Gentlemen:

On
behalf of ZEEKR Intelligent Technology Holding Limited (the “Company”), an exempted company incorporated under the
laws of the Cayman Islands, we submit to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
this letter to inform the Staff that the Company is publicly filing the Amendment No.1 to its registration statement on Form F-1 (the
 “Registration Statement”) and certain exhibits via EDGAR to the Commission. As communicated previously, the Company
has included certain financial information relating to the nine months ended September 30, 2022 and 2023 in the recent development section
of the Registration Statement, as well as certain other updates.

Subject
to the review of the Staff, the Company currently plans to file another amendment to the Registration Statement containing the estimated
offering size and price range on or around December 1, 2023 and commence its roadshow and related marketing activities shortly thereafter.
The Company currently plans to request that the Staff declare the effectiveness of the Registration Statement on or about December 7,
2023. The Company would appreciate the Staff’s continued assistance to help the Company meet this timeline.

*                *
*               *

November 24, 2023

If
you have any questions regarding this submission, please contact Ran Li at +86-10-8567-5013 (ran.li@davispolk.com).

Thank
you again for your time and attention.

    Yours sincerely,

    /s/
    Ran Li

    Ran Li

    cc:
    Mr. Conghui An, Chief Executive Officer

    Mr. Jing Yuan, Chief Financial Officer

    ZEEKR Intelligent Technology Holding Limited

    Mr. Neo Lin, Partner

    Deloitte Touche Tohmatsu Certified Public
    Accountants LLP

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