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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

March 20,
2024

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

 Amendment No. 2 to Registration Statement on Form F-1 Filed on December 29, 2023

File No. 333-275427

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 setting forth the Company’s responses to the comments contained in the Staff’s
letter dated January 5, 2024 on the Company’s Amendment No. 2 to Registration Statement on Form F-1 filed on December 29,
2023 (the “Registration Statement”). Concurrently with the submission of this letter, the Company is publicly filing
its revised registration statement on Form F-1 (the “Revised Registration Statement”) via
EDGAR to the Commission. The Company confirms that its securities have not been previously sold pursuant to an effective registration
statement under the Securities Act of 1933, as amended (the “Securities Act”).

The
Company has responded to the Staff’s comments by revising the Registration Statement. The Staff’s comments are repeated
below in bold, followed by the Company’s response to such comments. The Company has included page numbers to refer
to the location in the Revised Registration Statement where the language addressing a particular comment appears. The Company has
included in this submission its audited combined and consolidated financial statements as of and for the fiscal year ended December
31, 2021, 2022 and 2023.

March 20,
2024

*	          *	          *	          *

Form F-1 filed December 29, 2023

General

 1. We note your response to our prior comment 3 and reissue in part. Please revise your risk factors to
discuss the arbitration provision's related risks to investors, such as increased costs to bring a claim, limited access to information
and other imbalances of resources between the company and shareholders.

The Company respectfully advises the
Staff that it has revised the disclosure on pages 75 to 76 in the Revised Registration Statement in response to the Staff’s
comment.

 2. Please update your compensation disclosure to reflect the fiscal year ended December 31, 2023.

The Company respectfully advises the
Staff that it has updated the disclosure on page 185 in the Revised Registration Statement in response to the Staff’s comment.

*	          *	          *	          *

March 20,
2024

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