SecProbe.io

CORRESP
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 Aurora Mobile Limited

 31/F, Block 12-A, Shenzhen Bay Science and Technology
Ecological Park,

 Nanshan District, Shenzhen, Guangdong 518057

 People's Republic of China

 September 29, 2025

 VIA EDGAR

 Ms. Charli Wilson

 Office
of Technology

 Division of Corporation Finance

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: Aurora Mobile Limited
Registration Statement on Form F-3 (File No. 333-290371)
Acceleration Request

 Dear Ms. Charli,

 Pursuant to Rule 461 of Regulation C promulgated
under the Securities Act of 1933, as amended, Aurora Mobile Limited (the "Company") hereby requests that the effectiveness
of the above-referenced Registration Statement on Form F-3 (the "Registration Statement") be accelerated to, and that the
Registration Statement become effective at, 4 P.M., Eastern Time on October 2, 2025, or as soon thereafter as practicable.

 If there is any change in the acceleration request
set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration
of the effectiveness of the Registration Statement in accordance with Rule 461 of Regulation C. Such request may be made by an executive
officer of the Company or by any attorney from the Company's U.S. counsel, Skadden, Arps, Slate, Meagher & Flom LLP.

 [Signature page follows]

 Very truly yours,

 Aurora Mobile Limited

 By:
 /s/ Shan-Nen Bong

 Name:
 Shan-Nen Bong

 Title:
 Chief Financial Officer

 [Signature Page to Acceleration
Request]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 26, 2025

Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
31/F, Block 12-A, Shenzhen Bay Science and Technology Ecological Park,
Nanshan District, Shenzhen, Guangdong 518057
People s Republic of China

 Re: Aurora Mobile Limited
 Registration Statement on Form F-3
 Filed September 19, 2025
 File No. 333-290371
Dear Shan-Nen Bong:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Charli Wilson at 202-551-6388 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Shu Du
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
January 9, 2024
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have completed our review of your filing. 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.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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CORRESP

 AURORA MOBILE LIMITED

14/F, China Certification and Inspection Building

No. 6, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

December 28, 2023

 VIA EDGAR

Ms. Becky Chow

 Mr. Stephen Krikorian

Division of Corporation Finance

 Office of Technology

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

RE:
 Aurora Mobile Limited (the “Company”)

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

Filed on April 18, 2023

Response Letter Dated November 29, 2023

File
No. 001-38587

 Dear Ms. Chow
and Mr. Krikorian:

 This letter sets forth the Company’s response to the comment contained in the letter dated December 21,
2023 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s response letter dated November 29, 2023. The Staff’s comment is repeated below in
bold and followed by the Company’s response 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.

Response Letter Dated November 29, 2023

Risks related to our business and industry, page 16

1.
 In response to the proposed risk factor from the Company, we have the following comments:

•

 In the first paragraph after the risk factor heading, please strike the beginning of the sentence which
states: “We are not an “investment company””. Please revise the sentence to be a statement of intent or belief, rather than a conclusionary statement.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

December 28, 2023

 Page 2

•

 In the second paragraph, please strike the following sentence: “As a foreign private issuer, we would not
be eligible to register under the Investment Company Act unless the SEC issued an order permitting us to do so.”

•

 In the third sentence of the second paragraph, please strike the reference to obtaining exemptive relief from
the SEC.

 In response to the Staff’s comment, the Company respectfully proposes to include the following revised
disclosure in Item 3. Key Information - D. Risk Factors in its future Form 20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject matter being
disclosed:

 If we are deemed an “investment company” under the Investment Company Act of 1940, it could adversely affect
the price of the ADSs and could materially and adversely affect our business, results of operations, and financial condition.

We do not intend to become registered as an “investment company” under Section 3(a) of the Investment Company
Act of 1940, or the Investment Company Act. We are primarily engaged in businesses of providing customer engagement and marketing technology services.

Under Section 3(a)(1)(C) of the Investment Company Act, a company is deemed to be an “investment company” if it
is engaged, or proposes to engage, in the business of investing, reinvesting, owning, holding, or trading in securities and owns or proposes to acquire investment securities having a value exceeding 40% of the value of its total assets (exclusive of
government securities and cash items) on an unconsolidated basis. As a result, if we and/or certain of our subsidiaries are deemed to be an investment company within the meaning of the Investment Company Act, we would have to dispose of investment
securities in order to fall outside the definition of an investment company. Additionally, we may have to forego potential future acquisitions of interests in companies that may be deemed to be investment securities within the meaning of the
Investment Company Act. Failure to avoid being deemed an investment company under the Investment Company Act, coupled with our inability as a foreign private issuer to register under the Investment Company Act, could make us unable to comply with
our reporting obligations as a public company in the United States and lead to our being delisted from the Nasdaq, which would materially and adversely affect the liquidity and value of the ADSs. We would also be unable to raise capital through the
sale of securities in the United States or to conduct business in the United States. In addition, we may be subject to SEC enforcement action or purported class action lawsuits for alleged violations of U.S. securities laws. Defending ourselves
against any such enforcement action or lawsuits would require significant attention from our management and divert resources from our existing businesses and could materially and adversely affect our business, results of operations, and financial
condition.

 *    *    *

 2

 If you have any additional questions or comments regarding the 2022 Form 20-F, please contact the undersigned at +86 755-8388-1462 or the Company’s U.S. corporate counsel, Shu Du of Skadden, Arps, Slate, Meagher & Flom LLP at +852
3740 4858 or shu.du@skadden.com.

Sincerely yours,

Aurora Mobile Limited

By:

 /s/ Shan-Nen Bong

Name:

Shan-Nen Bong

Title:

Chief Financial Officer

cc:
 Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Maple Liao, Partner, Ernst & Young Hua Ming LLP

 3

United States securities and exchange commission logo
December 21, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
Response letter dated November 29, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have reviewed your November 29, 2023 response to our comment letter and have the
following comment.
            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. Unless
we note otherwise, any references to prior comments are to comments in our November 29,
2023 letter.
Response letter dated November 29, 2023
Risks related to our business and industry, page F-16
1.In response to the proposed risk factor from the Company, we have the following
comments:
•In the first paragraph after the risk factor heading, please strike the beginning of the
sentence which states: “We are not an “investment company””. Please revise the
sentence to be a statement of intent or belief, rather than a conclusionary statement.
•In the second paragraph, please strike the following sentence: “As a foreign private
issuer, we would not be eligible to register under the Investment Company Act unless
the SEC issued an order permitting us to do so.”

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 December 21, 2023 Page 2
 FirstName LastName
Shan-Nen  Bong
Aurora Mobile Limited
December 21, 2023
Page 2
•In the third sentence of the second paragraph, please strike the reference to obtaining
exemptive relief from the SEC.
            Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
1
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CORRESP

 AURORA MOBILE LIMITED

14/F, China Certification and Inspection Building

No. 6, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

November 29, 2023

 VIA EDGAR

Ms. Becky Chow

 Mr. Stephen Krikorian

Division of Corporation Finance

 Office of Technology

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

RE:
 Aurora Mobile Limited (the “Company”)

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

Filed on April 18, 2023

Response Letter Dated October 25, 2023

File No. 001-38587

Dear Ms. Chow and Mr. Krikorian:

 This
letter sets forth the Company’s response to the comment contained in the letter dated November 17, 2023 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding
the Company’s response letter dated October 25, 2023. The Staff’s comment is repeated below in bold and followed by the Company’s response 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.

 Response Letter Dated October 25, 2023

Risks related to our business and industry, page 16

1.
 Please consider including a risk factor indicating that: (1) the Company intends to conduct its
operations such that it will not be an “investment company” under Section 3(a) of the Investment Company Act of 1940 (the “Investment Company Act”); and (2) the Company’s ability to operate in its current form
would be significantly impacted if the Company (and/or certain of its subsidiaries) were deemed to be an investment company under the Investment Company Act.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

November 29, 2023

 Page 2

 In response to the Staff’s comment, the Company respectfully proposes to include the
following disclosure in Item 3. Key Information—D. Risk Factors in its future Form 20-F filings, subject to updates and adjustments to be made in connection with any material development of the subject
matter being disclosed:

 If we are deemed an “investment company” under the Investment Company Act of 1940, it could
adversely affect the price of the ADSs and could materially and adversely affect our business, results of operations, and financial condition.

We are not an “investment company” and do not intend to become registered as an “investment company” under
Section 3(a) of the Investment Company Act of 1940, or the Investment Company Act. We are primarily engaged in businesses of providing customer engagement and marketing technology services.

Under Section 3(a)(1)(C) of the Investment Company Act, a company is deemed to be an “investment company” if it
is engaged, or proposes to engage, in the business of investing, reinvesting, owning, holding, or trading in securities and owns or proposes to acquire investment securities having a value exceeding 40% of the value of its total assets (exclusive of
government securities and cash items) on an unconsolidated basis. As a foreign private issuer, we would not be eligible to register under the Investment Company Act unless the SEC issued an order permitting us to do so. As a result, if we and/or
certain of our subsidiaries are deemed to be an investment company within the meaning of the Investment Company Act, we would either have to obtain exemptive relief from the SEC or dispose of investment securities in order to fall outside the
definition of an investment company. Additionally, we may have to forego potential future acquisitions of interests in companies that may be deemed to be investment securities within the meaning of the Investment Company Act. Failure to avoid being
deemed an investment company under the Investment Company Act, coupled with our inability as a foreign private issuer to register under the Investment Company Act, could make us unable to comply with our reporting obligations as a public company in
the United States and lead to our being delisted from the Nasdaq, which would materially and adversely affect the liquidity and value of the ADSs. We would also be unable to raise capital through the sale of securities in the United States or to
conduct business in the United States. In addition, we may be subject to SEC enforcement action or purported class action lawsuits for alleged violations of U.S. securities laws. Defending ourselves against any such enforcement action or lawsuits
would require significant attention from our management and divert resources from our existing businesses and could materially and adversely affect our business, results of operations, and financial condition.

*            *
  *

 2

 If you have any additional questions or comments regarding the 2022 Form 20-F, please contact the undersigned at +86 755-8388-1462 or the Company’s U.S. corporate counsel, Shu Du of Skadden, Arps, Slate, Meagher & Flom LLP at +852
3740 4858 or shu.du@skadden.com.

Sincerely yours,

Aurora Mobile Limited

By:

/s/ Shan-Nen Bong

Name:

Shan-Nen Bong

Title:

Chief Financial Officer

cc:
 Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Maple Liao, Partner, Ernst & Young Hua Ming LLP

 3

United States securities and exchange commission logo
November 17, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
Response letter dated October 25, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have reviewed your October 25, 2023 response to our comment letter and have the
following comment.
            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. Unless
we note otherwise, any references to prior comments are to comments in our October 12,
2023 letter.
Response letter dated October 25, 2023
Risks related to our business and industry, page 16
1.Please consider including a risk factor indicating that: (1) the Company intends to conduct
its operations such that it will not be an “investment company” under Section 3(a) of the
Investment Company Act of 1940 (the “Investment Company Act”); and (2) the
Company’s ability to operate in its current form would be significantly impacted if the
Company (and/or certain of its subsidiaries) were deemed to be an investment company
under the Investment Company Act.

            Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 if

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 November 17, 2023 Page 2
 FirstName LastName
Shan-Nen  Bong
Aurora Mobile Limited
November 17, 2023
Page 2
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
1
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CORRESP

 AURORA MOBILE LIMITED

14/F, China Certification and Inspection Building

No. 6, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

 October 25,
2023

 VIA EDGAR

 Ms. Becky Chow

Mr. Stephen Krikorian

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

RE:
 Aurora Mobile Limited (the “Company”)

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

Filed on April 18, 2023

Response Letter Dated July 21, 2023

File No. 001-38587

Dear Ms. Chow and Mr. Krikorian:

 This
letter sets forth the Company’s response to the comments contained in the letter dated October 12, 2023 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding
the Company’s response letter dated July 21, 2023 (the “July Response Letter”) and September 20, 2023 (the “September Response Letter”). 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.

Response Letter Dated September 20, 2023

Item 3. Key Information, page 3

1.
 In response to prior comment 2, you stated “As of June 30, 2023, the Company and its subsidiaries
and VIE had 429 employees, none of whom are actively engaged in managing the Company’s and its subsidiaries’ and VIE’s investments on a full-time basis.” Please clarify whether the Company, its subsidiaries or the VIE have any
employees, and the number of employees, who manage the Company’s and its subsidiaries’ and VIE’s investments on a part-time basis.

The Company respectfully submits to the Staff that three employees from the Company’s finance department are asked, from time to time, to
assist with various tasks as needed on an ad-hoc basis, including cash management, and that this activity accounts for less than 15% of such employees’ time.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

October 25, 2023

  Page
 2

2.
 In response to prior comment 3, we note that you provided a table for the Company, listing “Value of
subsidiary” at 127, 422, 195 USD. We also note that the organization chart you provided in the response letter from July 21, 2023 listed two subsidiaries: 1) Meta Reality Limited and 2) UA Mobile Limited. Please clarify whether the
“value of subsidiary” notation includes both such entities. If not, please update the table to reflect the value of both of the Company’s subsidiaries.

The Company respectfully submits to the Staff that the “value of subsidiary” notation includes only UA Mobile Limited. Meta Reality
Limited is carried at $0 value.

3.
 In response to prior comment 3, pertaining to the table you provide for JPush Information Consultation
(Shenzhen) Co., Ltd. (“JPush”) we have the following comments:

•

 Please explain how the VIE is reflected on the JPush table.

The Company respectfully submits to the Staff that JPush does not own equity in the VIE, and the VIE and JPush have only the VIE Contractual
Arrangements (as defined in the July Response Letter) described in response to Comment #2 in the July Response Letter. Therefore, JPush does not account for any equity value attributable to the VIE on its balance sheet.

However, the inter-Company group loan reflected on the JPush balance sheet in the amount of RMB267,889,420 (see the September Response Letter)
is a loan JPush has made to the VIE. The stated value includes the principal amount of the loan and interest receivable. Although JPush has been treating this loan as an investment security for purposes of its responses to the Staff’s comments,
this loan is not an investment security. As reflected in the Company’s analysis in response to Comment #2 in the July Response Letter, the VIE Contractual Arrangements are the functional equivalent of voting securities of the VIE and the VIE is
the functional equivalent of a wholly-owned subsidiary of JPush for purposes of the Investment Company Act (as defined in the July Response Letter). Therefore, the loan JPush made to the VIE is not an investment security under Section 3(a)(2)
of the Investment Company Act because it is a security issued by a majority-owned subsidiary of the owner that is not itself an investment company, as reflected in the September Response Letter. The Company has only reflected this asset as an
investment security in its responses to the Staff’s comments in an effort to demonstrate that JPush does not fail the 40% Test (as defined in the July Response Letter) under even the most ultraconservative assumptions.

 2

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

October 25, 2023

  Page
 3

•

 The table refers to “trade receivables,” “prepayments,” “other receivables,” and
a “right-of-use asset.” As requested previously, please provide a detailed factual description of each of these items and the legal basis for your apparent
position that such items are not investment securities.

 Trade receivables represent the amounts that JPush has
invoiced to the VIE for technical services and backend support services that it has delivered but for which it has not yet received payment. The VIE is engaged in selling activities in mainland China on behalf of the Company, while the
Company’s research and development activities are jointly performed by JPush and the VIE. The trade receivables are current balances due for delivered services arising from ordinary course business operating activities, are not represented by
any note or other evidence of indebtedness, and are therefore not “securities” as defined in Section 2(a)(36) of the Investment Company Act, and therefore cannot be “investment securities” as defined in Section 3(a)(2)
of the Investment Company Act.1

 Prepayments represent primarily prepaid audit fees,
prepaid service fees and other prepayments. These prepayments are ordinary course payments made to ensure the availability of essential resources or services required for the Company’s ongoing operations, are not represented by any note or
other evidence of indebtedness, and are therefore not “securities” as defined in Section 2(a)(36) of the Investment Company Act, and therefore cannot be “investment securities” as defined in Section 3(a)(2) of the
Investment Company Act.2

1
 See, e.g., Merrill, Lynch, Pierce, Fenner & Smith Inc., SEC Staff
No-Action Letter (Oct. 28, 1982) (characterizing notes and evidences of indebtedness generally as transactions in which the use of money is obtained in exchange for a promise to pay interest and to repay a
fixed sum at a future date). Cf. Reves v. Ernst & Young, 494 U.S. 56, 66 (1990) (stating that, even with respect to a note, if it is exchanged to facilitate a commercial or consumer purpose, it is “less sensibly described” as a
“security”); Certain Prima Facie Investment Companies, Investment Company Act Rel. No. 10937 (Nov. 13, 1979) (stating that even certificates of deposit may be treated as cash items – and not as securities – where purchased
as an integral part of an operating business).

2
 See supra, note 1.

 3

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

October 25, 2023

  Page
 4

 The Company respectfully notes that Note 2 to the JPush table in September Response Letter
contains a detailed factual description of each material element of the “other receivables” line item in the JPush table. The nature of the VAT (value added tax) and other surcharges, a prepaid joint technology development fee and an
office rental deposit are self-evident and these assets plainly are not “securities” as defined in Section 2(a)(36) of the Investment Company Act, and therefore cannot be “investment securities” as defined in
Section 3(a)(2) of the Investment Company Act. Additionally, the service charges and other operational receivables that comprise amounts due from inter companies are not represented by any note or other evidence of indebtedness, and are
therefore not “securities” because they do not represent the use of money being obtained in exchange for a promise to pay interest and to repay a fixed sum at a future date.3

Right-of-use assets represent a lessee’s right to use a
leased asset over a lease term. Here, the leased asset is office space and the right-of-use asset represents use rights through an operating lease. The value of a
company’s lease right to use office space in furtherance of its operating business is not a “security” as defined in Section 2(a)(36) of the Investment Company Act, and therefore cannot be an “investment security” as
defined in Section 3(a)(2) of the Investment Company Act.4

4.
 The staff reserves the right to ask additional questions about the tables provided for various other
entities, including, in particular, your proposed treatment of various assets as non-investment securities. In the meantime, the staff notes that, in the response to prior comment 3, you state in note 5 that:
“Intangible assets represent computer software, systems and technology, brand and customer relationship acquired in a business combination.” Please provide specific facts and details regarding the nature of the intangible assets and the
business combination mentioned.

 The computer software, systems and technology is comprised of Office, Adobe, Zoom,
Mlink and other software and technology that the Company purchased from third parties and are principally used for daily operation and management.

On March 8, 2022, the VIE completed the acquisition of 52.37% of the equity interests in Wuhan SendCloud Technology Co., Ltd.,
(“SendCloud”), China’s leading Email API platform for consumer marketing and user-centric transactional email services, for total cash consideration of RMB34,473 thousand.

3
 See, e.g., Merrill, Lynch, Pierce, Fenner & Smith Inc., SEC Staff
No-Action Letter (Oct. 28, 1982).

4
 See Companies Engaged in the Business of Acquiring Mortgages and Mortgage-Related Instruments, Investment
Company Act Rel. No. 29778 (Aug. 31, 2011) (characterizing leasehold interests as actual interests in real estate); Health Facility Credit Corp., SEC Staff No-Action Letter (Feb. 6, 1985) (same).

 4

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

October 25, 2023

  Page
 5

 The acquisition supports the Company’s strategy of providing a more reliable and
effective customer engagement platform for different industry vertical. Both SendCloud and the Company provide developer-centric services and are highly complementary in products and customer base. Leveraging SendCloud’s reliable
high-performance system and database services along with real-time email protocols analysis, together the Company and SendCloud will provide customers with industry-leading technology to simplify their omni-channel communications, through an
integrated central platform, which will further reduce customers’ management costs, simplify the complexity for customers to integrate different services and maximize user value.

With the assistance of third party valuation specialist firm, the Company used the income approach to value the acquired brand and customer
relationships. The income approach calculates fair value by discounting the forecasted after-tax cash flows back to a present value using an appropriate discount rate. The significant assumptions used in the
determination of the fair value of acquired brand and customer relationships include revenue growth rates, discount rates, terminal growth rates and economic useful life.

The Company amortizes intangible assets on a straight-line basis over the periods benefited. These intangible assets plainly are not
“securities” as defined in Section 2(a)(36) of the Investment Company Act, and therefore cannot be “investment securities” as defined in Section 3(a)(2) of the Investment Company Act.

*  *   *

 5

 If you have any additional questions or comments regarding the 2022 Form 20-F, please contact the undersigned at +86 755-8388-1462, the Company’s U.S. corporate counsel, Shu Du of Skadden, Arps, Slate, Meagher & Flom LLP at +852 3740
4858 or shu.du@skadden.com or the Company’s U.S. Investment Company Act counsel, Kenneth E. Burdon of Skadden, Arps, Slate, Meagher & Flom LLP at +1
617-573-4836 or kenneth.burdon@skadden.com.

Sincerely yours,

Aurora Mobile Limited

By:

/s/ Shan-Nen Bong

Name:

Shan-Nen Bong

Title:

Chief Financial Officer

cc:
 Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Kenneth E. Burdon, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Maple Liao, Partner, Ernst & Young Hua Ming LLP

 6

United States securities and exchange commission logo
October 12, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
Response letter dated September 20, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have reviewed your September 20, 2023 response to our comment letter.. In order to
help us more fully evaluate your responses to prior comments 2 and 3 regarding the Investment
Company Act of 1940 (the “Investment Company Act”), we 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. Unless
we note otherwise, any references to prior comments are to comments in our July 21, 2023 letter.
Response letter dated September 20, 2023
Item 3. Key Information, page 3
1.In response to prior comment 2, you stated “As of June 30, 2023, the Company and its
subsidiaries and VIE had 429 employees, none of whom are actively engaged in managing
the Company’s and its subsidiaries’ and VIE’s investments on a full-time basis.” Please
clarify whether the Company, its subsidiaries or the VIE have any employees, and the
number of employees, who manage the Company’s and its subsidiaries’ and VIE’s
investments on a part-time basis.
2.In response to prior comment 3, we note that you provided a table for the Company,
listing “Value of subsidiary” at 127, 422, 195 USD. We also note that the organization

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 October 12, 2023 Page 2
 FirstName LastName
Shan-Nen  Bong
Aurora Mobile Limited
October 12, 2023
Page 2
chart you provided in the response letter from July 21, 2023 listed two subsidiaries: 1)
Meta Reality Limited and 2) UA Mobile Limited. Please clarify whether the “value of
subsidiary” notation includes both such entities.  If not, please update the table to reflect
the value of both of the Company’s subsidiaries.
3.In response to prior comment 3, pertaining to the table you provide for JPush
InformationConsultation (Shenzhen) Co., Ltd. (“JPush”) we have the following
comments:
•Please explain how the VIE is reflected on the JPush table.
•The table refers to “trade receivables,” “prepayments,” “other receivables,” and a
“right-of-use asset.” As requested previously, please provide a detailed factual
description of each of these items and the legal basis for your apparent position that
such items are not investment securities.
4.The staff reserves the right to ask additional questions about the tables provided for
various other entities, including, in particular, your proposed treatment of various assets as
non-investment securities. In the meantime, the staff notes that, in the response to prior
comment 3, you state in note 5 that: “Intangible assets represent computer software,
systems and technology, brand and customer relationship acquired in a business
combination.” Please provide specific facts and details regarding the nature of the
intangible assets and the business combination mentioned.
            Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
1
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CORRESP

 AURORA MOBILE LIMITED

14/F, China Certification and Inspection Building

No. 6, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

September 20, 2023

 VIA EDGAR

Ms. Becky Chow

 Mr. Stephen Krikorian

Mr. Austin Pattan

 Mr. Larry Spirgel

Division of Corporation Finance

 Office of Technology

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

RE:
 Aurora Mobile Limited (the “Company”)

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

Filed on April 18, 2023

Response Letter Dated July 21, 2023

File No. 001-38587

Dear Ms. Chow, Mr. Krikorian, Mr. Pattan and Mr. Spirgel:

This letter sets forth the Company’s response to the comments contained in the letter dated August 8, 2023 from the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Company’s response letter dated July 21, 2023. 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.

Response Letter Dated July 21, 2023

Item 3. Key Information, page 3

1.
 Please update your analysis under Section 3(a)(1)(A) and 3(a)(1)(C) of the Investment Company Act to
account for information as of the most recent fiscal quarter end.

 The more detailed analyses requested below reflect
unaudited information as of June 30, 2023, which is the Company’s most recent fiscal quarter end, and contain updated unaudited financial information for the Company in addition to the additional information requested with respect to the
Company’s subsidiaries.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 20, 2023

 Page 2

2.
 Thank you for your detailed legal analysis regarding whether the Company meets the definition of an
“investment company” under Section 3(a)(1)(A) of the Investment Company Act. However, in our prior questions, we also asked that you also provide a similarly detailed response regarding whether each of the Company’s subsidiaries
meets the definition of an “investment company” under Section 3(a)(1)(A) of the Investment Company Act. Please provide that analysis and, in your response, please address, in detail, each of the factors outlined in Tonapah Mining
Company of Nevada, 26 SEC 426 (1947) and provide legal and factual support for your analysis of each such factor as they apply to each of the Company’s subsidiaries.

Section 3(a)(1)(A) of the Investment Company Act defines the term “investment company” to include any issuer which “is or
holds itself out as being engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, or trading in securities” (emphasis added).

The determination of an issuer’s primary business engagement requires a fact-specific inquiry. Over the years, the Commission and the
courts have developed a number of criteria to be used in determining whether a company is engaged primarily in a non-investment business. The criteria applicable to nearly every situation are: (i) the
company’s historical development; (ii) its public representations of policy; (iii) the activities of its officers and directors; (iv) the sources of its present income; and (v) the nature of its present assets (the
“Tonopah Factors”).1

 Although the Commission has not indicated how
much emphasis should be placed on any particular criterion, it has indicated that, in general, more significance should be placed on the character of a company’s assets (as evidenced by the relative percentage of a company’s assets
invested in operating businesses (“operating assets”) versus investment instruments (“investment assets”)), and the sources of the company’s present income (as evidenced by the relative percentage of the company’s
income derived from operating assets versus investment assets).2 However, other factors may outweigh the foregoing factors, such as the company’s need for cash for operations or acquisitions
or other needs. In general, Commission and court decisions indicate that if an applicant has demonstrated significant activity in a non-investment business, a need for available capital, and the absence of
public representations that it is in the investment business, no registration is required.

1
 Tonopah Mining Co. of Nev., 26 S.E.C. 426, 427 (1947); Certain Prima Facie Inv. Cos., Investment Company
Act Release No. IC-10937, 18 S.E.C. Docket 948 (1979).

2
 Investment Company Act Release No. IC-10937, supra note 1;
Tonopah, 26 S.E.C. at 427.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 20, 2023

 Page 3

 Historical Development

Since 2014, the Company has devoted itself to the business of providing customer engagement and marketing technology services in mainland
China. The Company was launched in May 2012 as Shenzhen Hexun Hungu Information Technology Co., Ltd., or Hexun Huagu. The current shareholders of Hexun Huagu are Mr. Weidong Luo and Mr. Guangyan Chen. In May 2012, UA Mobile Limited was
incorporated in the British Virgin Islands by KK Mobile Limited, a company wholly owned by Mr. Weidong Luo. UA Mobile Limited set up a wholly-owned subsidiary, KK Mobile Investment Limited, in Hong Kong in June 2012. In April 2014, Aurora
Mobile Limited was incorporated in the Cayman Islands as an offshore holding company to facilitate financing and offshore listing. Subsequently, Mr. Weidong Luo transferred his entire ownership of UA Mobile Limited to Aurora Mobile Limited. In
June 2014, KK Mobile Investment Limited established a wholly-owned subsidiary in mainland China, JPush Information Consultation (Shenzhen) Co., Ltd., or Shenzhen JPush. On August 5, 2014, the Company obtained the ability to direct the business
operations of Hexun Huagu through Shenzhen JPush by entering into a series of contractual arrangements with Hexun Huagu and its then shareholders, whom were Mr. Weidong Luo, Mr. Xiaodao Wang and Mr. Jiawen Fang.

The Company is a holding company that conducts its business through its subsidiaries and VIE, as described above. Therefore, the discussions of
the Tonopah Factors as they apply to the Company are equally applicable to its subsidiaries and the VIE, and this aspect of the Section 3(a)(1)(A) analysis is clarified in the following discussions.3

 The Company and its subsidiaries and VIE have historically generated revenue from both
their software-as-a-service (“SAAS”) businesses and targeted marketing. The Company and its subsidiaries and VIE
strategically wound down their targeted marketing business in 2020, and beginning in 2021, the Company and its subsidiaries and VIE shifted their focus to the SAAS businesses.

The Company’s and its subsidiaries’ and VIE’s devotion to their business of providing customer engagement and marketing
technology services leveraging mobile behavioral data is demonstrated by the fact that substantially all of their revenue and income is derived from subscription and service fees generated from their SAAS businesses. For each of the unaudited twelve
month periods ended June 30, 2022 and June 30, 2023, over 99% of the Company’s total revenue (which, for this purpose, includes income from investment assets) was derived from subscription and service fees relating the Company’s
and its subsidiaries’ and VIE’s SAAS businesses, and not from investment assets. Similarly, more than 99% of the Company’s and its subsidiaries’ and VIE’s expenses for the unaudited twelve month period ended June 30,
2023 were incurred in connection with their SAAS businesses.

3
 References to “subsidiaries” in this letter include only the Company’s subsidiaries that are
material to this analysis, as acknowledged in the Staff’s comment #3, below: UA Mobile Limited, KK Mobile Investment Limited and JPush Information Consultation (Shenzhen) Co., Ltd. References to the “VIE” include only Shenzhen Hexun
Huagu Information Technology Co., Ltd. The VIE is included in this analysis and in the calculation provided in response to the Staff’s comment #3, below, even though it is not expressly referenced in the Staff’s comment #3, below, given
the Company’s position is that the VIE is the functional equivalent of an indirect wholly-owned subsidiary of the Company for purposes of the Investment Company Act (expressed in response to comment #2 in its July 21, 2023 response letter
to the Staff). Reference is also made to the structure chart included in the Company’s July 21, 2023 response letter.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 20, 2023

 Page 4

 Public Representations

Neither the Company nor any of its subsidiaries and VIE has ever held itself out to the public (or to investors) as an investment company. The
Company and its subsidiaries and VIE were organized for the purpose of, and since the Company became a public company in 2018 has always stated that their business purpose is, providing customer engagement and marketing technology software services
leveraging device-level mobile behavioral data gathered through the Company’s and its subsidiaries’ and VIE’s comprehensive suite of mobile application developer services. The price of the Company’s American depositary shares
moves in response to changes in its revenue growth and operating profits, among other factors, rather than changes in its investment income.4 To the best of the Company’s knowledge,
securities and investment analysts view the Company’s consolidated cash position and investment assets in terms of whether the Company and its subsidiaries and VIE appear to have the resources to carry out their business plan and not whether
their investment assets merit investment in the Company in order to obtain an interest in its and its subsidiaries’ and VIE’s investment returns. Moreover, neither the Company nor its subsidiaries and VIE devote attention to or disclose
their financial management or securities activities on their web site or in their public documents except as required by law.

 Officers
and Employees

 The business activities of the Company’s and its subsidiaries’ and VIE’s officers and employees
historically have been devoted almost exclusively to the pursuit of the governance and operational activities involved to support their business of providing customer engagement and marketing technology services leveraging mobile behavioral data.

 As of June 30, 2023, the Company and its subsidiaries and VIE had 429 employees, none of whom are actively engaged in managing the
Company’s and its subsidiaries’ and VIE’s investments on a full-time basis. All of the Company’s and its subsidiaries’ and VIE’s officers and employees devote substantially all of their time and business efforts to
their SAAS businesses, including providing mobile application developer services to facilitate the gathering of device-level mobile behavioral data and providing customer engagement and marketing services leveraging such data, and to functions that
support those businesses and not to managing investments owned by the Company and its subsidiaries and VIE. These employees are actively engaged in growing the Company’s and its subsidiaries’ and VIE’s business and utilize the
Company’s and its subsidiaries’ and VIE’s cash to fund the Company’s and its subsidiaries’ and VIE’s business operations.

4
 See, e.g., Securities and Exchange Commission v. National Presto Industries, Inc., 486 F.3d 305 (7th
Cir. 2007) (finding that Section 3(b)(1) of the Investment Company Act is about considerations other than assets (or at least in addition to assets) and stating “what principally matters is the beliefs the company is likely to induce in
investors” and whether “its portfolio and activities [would] lead investors to treat a firm as an investment vehicle or as an operating enterprise.”).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 20, 2023

 Page 5

 Sources of Income

The Company’s and its subsidiaries’ and VIE’s income is derived mainly from their SAAS businesses, and prior to 2021 from
targeted marketing revenues.

 Over 99% of the Company’s and each subsidiary’s and the VIE’s total revenue (which, for this
purpose, includes income from investment assets) for each of the unaudited 12 months ended June 30, 2022 and June 30, 2023 was derived from their SAAS businesses such as providing developer services, market intelligence, financial risk
management and location-based intelligence services, and not from investment assets. Similarly, more than 99% of the Company’s and each subsidiary’s and the VIE’s expenses for the unaudited 12 months ended June 30, 2023 were
incurred in connection with providing developer services, market intelligence, financial risk management and location-based intelligence services, and not in connection with investment activities. Although the Company, its subsidiaries and the VIE
were in a net loss position for the unaudited 12 months ended June 30, 2023, virtually all of the Company’s, its subsidiaries’ and the VIE’s revenue and expenses were derived from, or incurred in connection with, services
relating to the Company’s, its subsidiaries’ and the VIE’s SAAS businesses, including providing mobile application developer services to facilitate the gathering of device-level mobile behavioral data and providing customer engagement
and marketing services leveraging such data, and not from investment assets.5

Nature of Present Assets

As described in more detail in response to comment #3,6 investment securities represent
the following approximate percentages of the Company’s, each subsidiary’s and the VIE’s unaudited adjusted total assets as of June 30, 2023 when calculated in accordance with Section 3(a)(1)(C) of the Investment Company Act:

5
 See DRX, Inc., SEC Staff No-Action Letter (Jun. 28, 1988)
(stating, with respect to the Rule 3a-1 income test, “[W]e believe the Commission’s intent was to focus on activities that generate revenue for the company. Whether the net result is positive or
negative, the purpose is to review the company’s day-to-day activities by looking at its sources of income.”).

6
 The Company expressly notes that the percentages reflected below are qualified in all respects by the analysis
described in further detail in response to comment #3.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

September 20, 2023

 Page 6

Entity

Section 3(a)(1)(C)
Percentage

 Aurora Mobile Limited (the Company)

4.63
%

 UA Mobile Limited

0.00
%

 KK Mobile Investment Limited

0.00
%

 JPush Information Consultation (Shenzhen) Co., Ltd.

32.20
%

 Shenzhen Hexun Huagu Information Technology Co., Ltd. (the VIE)

31.41
%

 Because these amounts are less than 45% of each entity’s adjusted total assets, this factor indicates
that none of the Company, its subsidiaries or the VIE is engaged in an investment company business.7

3.
 While we appreciate the summary calculations you provided in Appendix A of your response letter, the
staff’s question specifically asked that the Company identify each constituent part of the numerators and denominators when performing your analysis under section 3(a)(1)(C) of the Investment Company Act. Accordingly, please provide all
relevant calculations under Section 3(a)(1)(C), identifying and describing each constituent part of the numerators and denominators for UA Mobile Limited, KK Mobile Limited, and JPush Information Consultation (Shenzhen) Co., Ltd. In doing so,
please (i) specifically describe the types of assets included within “cash and cash equivalents,” “long-term investments” and “short-term investments” on your balance sheet and (ii) describe and discuss their
proposed treatment for pu

CORRESP
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CORRESP

 AURORA MOBILE LIMITED

14/F, China Certification and Inspection Building

No. 6, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

 August 17, 2023

 VIA EDGAR

 Ms. Becky Chow

Mr. Stephen Krikorian

 Mr. Austin Pattan

Mr. Larry Spirgel

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Aurora Mobile Limited (the “Company”)

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

Filed on April 18, 2023

File
No. 001-38587

Dear Ms. Chow, Mr. Krikorian, Mr. Pattan and Mr. Spirgel:

The Company has received the letter dated August 8, 2023 from the staff of the Securities and Exchange Commission (the
“Staff”) regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2022 filed with the Commission on April 18, 2023 (the “2022 Form 20-F”). The Company respectfully submits to the Staff to request an extension of 20 business days to the deadline for responding to the letter due to the additional time required to gather sufficient
information and prepare thorough responses to address certain comments in the letter. The Company will provide its response to the letter via EDGAR as soon as possible, on or prior to September 20, 2023.

If you have any additional questions or comments regarding the 2022 Form 20-F, please contact the
Company’s U.S. counsels, Shu Du of Skadden, Arps, Slate, Meagher & Flom LLP at +852 3740 4858 or shu.du@skadden.com, or the Chief Financial Officer of the Company, Shan-Nen Bong, via e-mail at
bongsn@jiguang.cn.

 Thank you very much.

Very truly yours,

/s/ Shan-Nen Bong

Shan-Nen Bong

Chief Financial Officer

cc:
 Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Maple Liao, Partner, Ernst & Young Hua Ming LLP

United States securities and exchange commission logo
August 8, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
Response letter dated July 21, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have reviewed your July 21, 2023 response to our comment letter.  In order to help us
more fully evaluate your responses to prior comments 1 and 2 regarding the Investment
Company Act of 1940 (the “Investment Company Act”), we have the following comments.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
July 7, 2023 letter.
Response letter dated July 21, 2023
Item 3. Key Information, page 3
1.Please update your analysis under Section 3(a)(1)(A) and 3(a)(1)(C) of the Investment
Company Act to account for information as of the most recent fiscal quarter end.
2.Thank you for your detailed legal analysis regarding whether the Company meets the
definition of an “investment company” under Section 3(a)(1)(A) of the Investment
Company Act. However, in our prior questions, we also asked that you also provide a
similarly detailed response regarding whether each of the Company’s subsidiaries meets
the definition of an “investment company” under Section 3(a)(1)(A) of the Investment

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 August 8, 2023 Page 2
 FirstName LastName
Shan-Nen  Bong
Aurora Mobile Limited
August 8, 2023
Page 2
Company Act. Please provide that analysis and, in your response, please address, in detail,
each of the factors outlined in Tonapah Mining Company of Nevada, 26 SEC 426 (1947)
and provide legal and factual support for your analysis of each such factor as they apply to
each of the Company’s subsidiaries.
3.While we appreciate the summary calculations you provided in Appendix A of your
response letter, the staff’s question specifically asked that the Company identify each
constituent part of the numerators and denominators when performing your analysis under
section 3(a)(1)(C) of the Investment Company Act. Accordingly, please provide all
relevant calculations under Section 3(a)(1)(C), identifying and describing each constituent
part of the numerators and denominators for UA Mobile Limited, KK Mobile Limited,
and JPush Information Consultation (Shenzhen) Co., Ltd. In doing so, please (i)
specifically describe the types of assets included within “cash and cash equivalents,”
“long-term investments” and “short-term investments” on your balance sheet and (ii)
describe and discuss their proposed treatment for purposes of section 3(a)(1)(C), as well
as any other substantive determinations and/or characterizations of assets that are material
to your calculations.
            You may contact Becky Chow, Staff Accountant at 202-551-6524, or Stephen Krikorian,
Accounting Branch Chief, at 202-551-3488 if you have questions regarding comments on the
financial statements and related matters. Please contact Austin Pattan, Staff Attorney, at 202-
551-6756, or Larry Spirgel, Office Chief, at 202-551-3815 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
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filename1.htm

CORRESP

 AURORA MOBILE LIMITED

14/F, China Certification and Inspection Building

No. 6, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

 July 21,
2023

 VIA EDGAR

 Ms. Becky Chow

Mr. Stephen Krikorian

 Mr. Austin Pattan

Mr. Larry Spirgel

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

RE:
 Aurora Mobile Limited (the “Company”)

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

Filed on April 18, 2023

File
No. 001-38587

Dear Ms. Chow, Mr. Krikorian, Mr. Pattan and Mr. Spirgel:

This letter sets forth the Company’s response to the comments contained in the letter dated July 7, 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 18, 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, page 3

1.
 Please provide a detailed legal analysis regarding whether the Company and its subsidiaries meet the
definition of an “investment company” under Section 3(a)(1)(A) of the Investment Company Act of 1940 (“Investment Company Act”). In your response, please address, in detail, each of the factors outlined in Tonapah Mining
Company of Nevada, 26 SEC 426 (1947) and provide legal and factual support for your analysis of each such factor.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 2

 Section 3(a)(1)(A) of the Investment Company Act defines the term “investment
company” to include any issuer which “is or holds itself out as being engaged primarily, or proposes to engage primarily, in the business of investing, reinvesting, or trading in securities” (emphasis added).

The determination of an issuer’s primary business engagement requires a fact-specific inquiry. Over the years, the Commission and the
courts have developed a number of criteria to be used in determining whether a company is engaged primarily in a non-investment business. The criteria applicable to nearly every situation are: (i) the
company’s historical development; (ii) its public representations of policy; (iii) the activities of its officers and directors; (iv) the sources of its present income; and (v) the nature of its present assets (the
“Tonopah Factors”).1

 Although the Commission has not indicated how
much emphasis should be placed on any particular criterion, it has indicated that, in general, more significance should be placed on the character of a company’s assets (as evidenced by the relative percentage of a company’s assets
invested in operating businesses (“operating assets”) versus investment instruments (“investment assets”)), and the sources of the company’s present income (as evidenced by the relative percentage of the company’s
income derived from operating assets versus investment assets).2 However, other factors may outweigh the foregoing factors, such as the company’s need for cash for operations or acquisitions
or other needs. In general, Commission and court decisions indicate that if an applicant has demonstrated significant activity in a non-investment business, a need for available capital, and the absence of
public representations that it is in the investment business, no registration is required.

 Tonopah Analysis

Historical Development

Since 2014, the Company has devoted itself to the business of providing customer engagement and marketing technology services in mainland
China. The Company was launched in May 2012 as Shenzhen Hexun Hungu Information Technology Co., Ltd., or Hexun Huagu. The current shareholders of Hexun Huagu are Mr. Weidong Luo and Mr. Guangyan Chen. In May 2012, UA Mobile Limited was
incorporated in the British Virgin Islands by KK Mobile Limited, a company wholly owned by Mr. Weidong Luo. UA Mobile Limited set up a wholly-owned subsidiary, KK Mobile Investment Limited, in Hong Kong in June 2012. In April 2014, Aurora
Mobile Limited was incorporated in the Cayman Islands as an offshore holding company to facilitate financing and offshore listing. Subsequently, Mr. Weidong Luo transferred his entire ownership of UA Mobile Limited to Aurora Mobile Limited. In
June 2014, KK Mobile Investment Limited established a wholly-owned subsidiary in mainland China, JPush Information Consultation (Shenzhen) Co., Ltd., or Shenzhen JPush. On August 5, 2014, the Company obtained the ability to direct the business
operations of Hexun Huagu through Shenzhen JPush by entering into a series of contractual arrangements with Hexun Huagu and its shareholders.

1
 Tonopah Mining Co. of Nev., 26 S.E.C. 426, 427 (1947); Certain Prima Facie Inv. Cos., Investment Company
Act Release No. IC-10937, 18 S.E.C. Docket 948 (1979).

2
 Investment Company Act Release No. IC-10937, supra note 1;
Tonopah, 26 S.E.C. at 427.

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 3

 The Company historically generated revenue from both its software-as-a-service (“SAAS”) businesses and targeted marketing. The Company strategically wound down its targeted marketing business in 2020, and beginning
in 2021 the Company shifted its focus to its SAAS businesses.

 The Company’s devotion to its business of providing customer engagement
and marketing technology services leveraging mobile behavioral data is demonstrated by the fact that substantially all of the Company’s revenue and income is derived from subscription and service fees relating to the Company’s SAAS
businesses. For each of the twelve month periods ended December 31, 2021 and December 31, 2022, over 99% of the Company’s total revenue (which, for this purpose, includes income from investment assets) was derived from subscription
and service fees relating the Company’s SAAS businesses, and not from investment assets. Similarly, more than 99% of the Company’s expenses for the twelve month period ended December 31, 2022 were incurred in connection with the
Company’s SAAS businesses.

 Public Representations

The Company has never held itself out to the public (or to investors) as an investment company. The Company was organized for the purpose of,
and since becoming a public company in 2018 has always stated that its business purpose is, providing customer engagement and marketing technology software services leveraging device-level mobile behavioral data gathered through the Company’s
comprehensive suite of mobile application developer services. The price of the Company’s American depositary shares moves in response to changes in its revenue growth and operating profits, among other factors, rather than changes in its
investment income.3 To the best of the Company’s knowledge, securities and investment analysts view the Company’s cash position and investment assets in terms of whether the Company
appears to have the resources to carry out its business plan and not whether its investment assets merit investment in the Company in order to obtain an interest in its investment returns. Moreover, the Company does not devote attention to nor
disclose its financial management or securities activities on its web site or in its public documents except as required by law.

3
 See, e.g., Securities and Exchange Commission v. National Presto Industries, Inc.,
486 F.3d 305 (7th Cir. 2007) (finding that Section 3(b)(1) of the Investment Company Act is about considerations other than assets (or at least in addition to assets) and stating “what principally matters is the beliefs the company is
likely to induce in investors” and whether “its portfolio and activities [would] lead investors to treat a firm as an investment vehicle or as an operating enterprise.”).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 4

 Officers and Employees

The business activities of the Company’s officers and employees historically have been devoted almost exclusively to the pursuit of the
governance and operational activities involved to support its business of providing customer engagement and marketing technology services leveraging mobile behavioral data.

As of December 31, 2022, the Company had 460 employees, none of whom are actively engaged in managing the Company’s investments on a
full-time basis. All of the Company’s officers and employees devote substantially all of their time and business efforts at the Company to the Company’s SAAS businesses, including providing mobile application developer services to
facilitate the gathering of device-level mobile behavioral data and providing customer engagement and marketing services leveraging such data, and to functions that support those businesses and not to managing investments owned by the Company. These
employees are actively engaged in growing the Company’s business and utilize the Company’s cash to fund the Company’s business operations.

Sources of Income

 The
Company’s income is derived mainly from its SAAS businesses, and prior to 2021 from targeted marketing revenues.

 Over 99% of the
Company’s total revenue (which, for this purpose, includes income from investment assets) for each of the years ended December 31, 2021 and December 31, 2022 was derived from its SAAS businesses such as providing developer services,
market intelligence, financial risk management and location-based intelligence services, and not from investment assets. Similarly, more than 99% of the Company’s expenses for the year ended December 31, 2022 were incurred in connection
with providing developer services, market intelligence, financial risk management and location-based intelligence services, and not in connection with investment activities. Although the Company was in a net loss position for the fiscal year ended
December 31, 2022, virtually all of the Company’s revenue and expenses were derived from, or incurred in connection with, services relating to the Company’s SAAS businesses, including providing mobile application developer services to
facilitate the gathering of device-level mobile behavioral data and providing customer engagement and marketing services leveraging such data, and not from investment assets.4

4
 See DRX, Inc., SEC Staff No-Action Letter (Jun.
28, 1988) (stating, with respect to the Rule 3a-1 income test, “[W]e believe the Commission’s intent was to focus on activities that generate revenue for the company. Whether the net result is
positive or negative, the purpose is to review the company’s day-to-day activities by looking at its sources of income.”).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 5

 Nature of Present Assets

 As described in more detail in response to comment #2, investment
securities represent approximately 4.58% of the Company’s adjusted total assets as of December 31, 2022 when calculated in accordance with Section 3(a)(1)(C) of the Investment Company Act. Because this is less than 45% of the
Company’s adjusted total assets, this factor indicates that the Company is not engaged in an investment company business.5

Conclusion

 Based on the
foregoing, the Company is not engaged in an investment company business, but rather is primarily engaged in the business of providing customer engagement and marketing technology software services leveraging device-level mobile behavioral data
gathered through the Company’s comprehensive suite of mobile application developer services.

2.
 Please provide a detailed legal analysis regarding whether the Company or any of its subsidiaries meet the
definition of an “investment company” under Section 3(a)(1)(C) of the Investment Company Act. In your response, please include all relevant calculations under Section 3(a)(1)(C), identifying each constituent part of the
numerators and denominators. Please also (i) specifically describe the types of assets included within “cash and cash equivalents,” “long-term investments” and “short-term investments” on your balance sheet and
(ii) describe and discuss their proposed treatment for purposes of section 3(a)(1)(C), as well as any other substantive determinations and/or characterizations of assets that are material to your calculations. Finally, please include a legal
analysis of whether the interests held by the Company in its VIE are “investment securities” for purposes of Section 3(a)(2) of the Investment Company Act.

Section 3(a)(1)(C) Calculations

Attached to this letter as Appendix A is a calculation of the value of the investment securities owned by the Company expressed as a percentage
of the value of its adjusted total assets, calculated in accordance with Section 3(a)(1)(C) of the Investment Company Act (the “40% Test”), as well as separate calculations for each of its wholly-owned subsidiaries, majority-owned
subsidiary and variable interest entity (“VIE”) as of December 31, 2022. Attached to this letter as Appendix B is a corporate structure chart for the Company and its wholly-owned subsidiaries, majority-owned subsidiary and VIE. The
Company treats its VIE as equivalent to a wholly-owned subsidiary for purposes of calculating the 40% Test. Please see below for an explanation of why this treatment is appropriate.

5
 See Investment Company Act Release No. IC-10937,
supra note 1 (“As a general rule, however, if a company has no more than 45 percent of its assets invested in—and derives no more than 45 percent of its income from—investment securities, it is primarily engaged in a
business other than being an investment company. Accordingly, it would not appear necessary or appropriate in the public interest for the Commission to regulate such a company under the [Investment Company] Act.”).

 Division of Corporation Finance

Office of Technology

 Securities and Exchange Commission

July 21, 2023

  Page
 6

 The calculations conclude investment securities represent approximately 4.58% of the
Company’s adjusted total assets as of December 31, 2022 when calculated in accordance with the unique method required by the 40% Test. For purposes of these 40% Test calculations, the Company treated all securities held by the Company as
investment securities, excluding (i) U.S. government securities, (ii) U.S. registered money market funds6 and (iii) securities of majority-owned subsidiaries and VIEs that are not
themselves investment companies.

 With respect to certain specific unconsolidated assets of the Company and its wholly-owned subsidiaries,
majority-owned subsidiary and VIE (the “Company Group”) as of December 31, 2022:

•

 All of the “cash and cash equivalents” owned by the Company Group consist of demand deposits at banks
or cash held in non-bank accounts (e.g., PayPal or similar payment platforms). These assets were eliminated from the numerator and the denominator in the Company Group’s 40% Test calculations.

•

 No “short-term investments” existed; however, the “short-term investment” held as of
December 31, 2021 consisted of a term deposit at a bank.

•

 “Long-term investments” consist of equity investments in entities the Company does not control, were
treated as investment securities in these 40% Test calculations and were included in both the numerator and the denominator in these 40% Test calculations. The bulk of these assets are held at Shenzhen Hexun Huagu Information Technology Co., Ltd.,
with the remainder at Aurora Mobile Ltd.

•

 Various members of the Company Group also own debt investments and intra-Company Group loan

United States securities and exchange commission logo
July 7, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Form 20-F filed on April 18, 2023
File No. 001-38587
Dear Shan-Nen Bong:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F filed on April 18, 2023
Item 3. Key information, page 3
1.Please provide a detailed legal analysis regarding whether the Company and its
subsidiaries meet the definition of an “investment company” under Section 3(a)(1)(A) of
the Investment Company Act of 1940 (“Investment Company Act”). In your response,
please address, in detail, each of the factors outlined in Tonapah Mining Company of
Nevada, 26 SEC 426 (1947) and provide legal and factual support for your analysis of
each such factor.
2.Please provide a detailed legal analysis regarding whether the Company or any of its
subsidiaries meet the definition of an “investment company” under Section 3(a)(1)(C) of
the Investment Company Act. In your response, please include all relevant calculations
under Section 3(a)(1)(C), identifying each constituent part of the numerators and

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 July 7, 2023 Page 2
 FirstName LastNameShan-Nen  Bong
Aurora Mobile Limited
July 7, 2023
Page 2
denominators. Please also (i) specifically describe the types of assets included within
“cash and cash equivalents,” “long-term investments” and “short-term investments” on
your balance sheet and (ii) describe and discuss their proposed treatment for purposes of
section 3(a)(1)(C), as well as any other substantive determinations and/or
characterizations of assets that are material to your calculations. Finally, please include a
legal analysis of whether the interests held by the Company in its VIE are “investment
securities” for purposes of Section 3(a)(2) of the Investment Company Act.
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 152
3.We note your statement that you reviewed your register of members and public filings
made by your shareholders in connection with your required submission under paragraph
(a). Please supplementally describe any additional materials that were reviewed and tell us
whether you relied upon any legal opinions or third party certifications such as affidavits
as the basis for your submission. In your response, please provide a similarly detailed
discussion of the materials reviewed and legal opinions or third party certifications relied
upon in connection with the required disclosures under paragraphs (b)(2) and (3).
4.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
5.We note that your disclosures pursuant to Items 16I(b)(2), (b)(3), and (b)(5) are provided
for “Aurora Mobile Limited or the VIE.” We also note that your list of subsidiaries and
consolidated variable interest entity in Exhibit 8.1 appears to indicate that you have
subsidiaries in Hong Kong, mainland China and countries outside China that are not
included in your VIE. Please note that Item 16I(b) requires that you provide disclosures
for yourself and your consolidated foreign operating entities, including variable interest
entities or similar structures.
•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and tell us the
percentage of your shares or the shares of your consolidated operating entities owned
by governmental entities in each foreign jurisdiction in which you have consolidated
operating entities.
•With respect to (b)(3) and (b)(5), please provide the required information for you and
all of your consolidated foreign operating entities in your supplemental response.
6.With respect to your disclosure pursuant to Item 16I(b)(5), we note that you have included
language that such disclosure is “to our knowledge.” Please supplementally confirm
without qualification, if true, that your articles and the articles of your consolidated
foreign operating entities do not contain wording from any charter of the Chinese

 FirstName LastNameShan-Nen  Bong
 Comapany NameAurora Mobile Limited
 July 7, 2023 Page 3
 FirstName LastName
Shan-Nen  Bong
Aurora Mobile Limited
July 7, 2023
Page 3
Communist Party.
            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.
            You may contact Becky Chow, Staff Accountant at 202-551-6524, or Stephen Krikorian,
Accounting Branch Chief, at 202-551-3488 if you have questions regarding comments on the
financial statements and related matters. Please contact Austin Pattan, Staff Attorney, at 202-
551-6756, or Larry Spirgel, Office Chief, at 202-551-3815 with  any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology

CORRESP
1
filename1.htm

CORRESP

 Aurora Mobile Limited

14/F, China Certification and Inspection Building

No. 8, Keji South 12th Road, Nanshan District

Shenzhen, Guangdong 518057

People’s Republic of China

September 28, 2022

 VIA EDGAR

Mr. Kyle Wiley, Staff Attorney

 Ms. Jan Woo, Legal
Branch Chief

 Office of Technology

 Division of Corporation
Finance

 Securities and Exchange Commission

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:
 Aurora Mobile Limited

Registration Statement on Form F-3 (File
No. 333-260944)

 Acceleration Request

Ladies and Gentlemen:

 Pursuant to Rule 461 of
Regulation C promulgated under the Securities Act of 1933, as amended, Aurora Mobile Limited (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form
F-3 (the “Registration Statement”) be accelerated to, and that the Registration Statement become effective at, 4 P.M., Eastern Time on September 30, 2022, or as soon thereafter as practicable.
In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

 If there is any
change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with
Rule 461 of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Skadden, Arps, Slate, Meagher & Flom LLP.

[Signature page follows]

Very truly yours,

Aurora Mobile Limited

By:

 /s/ Shan-Nen Bong

Name:

Shan-Nen Bong

Title:

Chief Financial Officer

 [Signature Page to Acceleration Request]

CORRESP
1
filename1.htm

CORRESP

 PARTNERS

GEOFFREY CHAN *

 SHU
DU *

 ANDREW L. FOSTER *

CHI T. STEVE KWOK *

EDWARD H.P. LAM ◆*

HAIPING LI *

 RORY
MCALPINE ◆

 JONATHAN B. STONE *

KAI SUN

 PALOMA P.
WANG

 ◆ (ALSO ADMITTED IN ENGLAND & WALES)

* (ALSO ADMITTED IN NEW YORK)

 SKADDEN, ARPS, SLATE, MEAGHER &
FLOM

 世達國際律師事務所

42/F, EDINBURGH TOWER, THE LANDMARK

15 QUEEN’S ROAD CENTRAL, HONG KONG

———

 TEL: (852)
3740-4700

 FAX: (852) 3740-4727

www.skadden.com

 AFFILIATE OFFICES

———

 BOSTON

CHICAGO

 HOUSTON

LOS ANGELES

 NEW YORK

PALO ALTO

 WASHINGTON, D.C.

WILMINGTON

 ———

BEIJING

 BRUSSELS

FRANKFURT

 LONDON

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

TOKYO

 TORONTO

 September 22, 2022

VIA EDGAR

 Mr. Kyle Wiley, Staff Attorney

Ms. Jan Woo, Legal Branch Chief

 Office of Technology

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Aurora Mobile Limited

Response to the Staff’s Comments on

Amendment No. 2 to Registration Statement on Form F-3

Filed on May 19, 2022 (File No. 333-260944)

Dear Ms. Woo and Mr. Wiley:

 On behalf
of our client, Aurora Mobile Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), 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 June 7, 2022, on the Company’s Amendment No. 2 to Registration Statement on Form F-3 filed on May 19, 2022. The Staff’s comments are repeated below in bold and are followed by the Company’s responses.

Aurora Mobile Limited

 September 22, 2022

 Page
 2

 Concurrently with the submission of this letter, the Company is filing herewith the Pre-Effective Amendment No. 3 to the Registration Statement (the “Amendment No. 3”), which reflects the revisions discussed in this letter, and certain exhibits via EDGAR
with the Commission.

 Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No. 3.

 Cover Page

1.
 We note your response to prior comment 1. We also note that your cover page disclosure and disclosure on
page 10 has not changed and still states that ““Aurora” refers to Aurora Mobile Limited, and “we,” “us,” “our company,” or “our” refers to Aurora Mobile Limited and its subsidiaries, and, when
describing our operations and consolidated financial information, also includes the VIE and its subsidiaries in China.” Please revise accordingly.

In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page, pages 2, 6-10 and where applicable of the Amendment No. 3.

2.
 We note your response to prior comment 2 and previous related response. Please disclose whether you have
written cash management policies and procedures that dictate how funds are transferred.

 In response to the
Staff’s comment, the Company has revised the disclosure on the prospectus cover page and pages 15-16 of the Amendment No. 3.

About This Prospectus, page 1

3.
 We note that your definition of “China” and “PRC” excludes Hong Kong and Macau. Please
revise your disclosure throughout the prospectus to include references to Hong Kong and Macau as China and/or the PRC.

In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page, pages 1, 6-10 and where applicable of the Amendment No. 3.

*            *
 *

Aurora Mobile Limited

 September 22, 2022

 Page
 3

 On behalf of the Company, we advise the Staff that the Company is aware of and acknowledges
that the Company is responsible for the adequacy and accuracy of the disclosure in the filing.

 If you have any questions regarding the
Amendment No. 3, please do not hesitate to contact the undersigned by phone at +852 3740-4858 or via e-mail at shu.du@skadden.com.

Very truly yours,

 /s/ Shu Du

Shu Du

 Enclosures

cc:
 Weidong Luo, Chairman of the Board of Directors and Chief Executive

Officer, Aurora Mobile Limited

 Shan-Nen Bong, Chief Financial Officer, Aurora Mobile Limited

 Maple Liao, Partner, Ernst &
Young Hua Ming LLP

United States securities and exchange commission logo
June 7, 2022
Weidong Luo
Chief Executive Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 8, Keji South 12th Road, Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Amendment No. 2 to Registration Statement on Form F-3
Filed May 19, 2022
File No. 333-260944
Dear Mr. Luo:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our May 10, 2022 letter.
Amendment No. 2 to Registration Statement on Form F-3
Cover Page
1.We note your response to prior comment 1. We also note that your cover page disclosure
and disclosure on page 10 has not changed and still states that "“Aurora” refers to Aurora
Mobile Limited, and “we,” “us,” “our company,” or “our” refers to Aurora Mobile
Limited and its subsidiaries, and, when describing our operations and consolidated
financial information, also includes the VIE and its subsidiaries in China." Please revise
accordingly.

 FirstName LastNameWeidong  Luo
 Comapany NameAurora Mobile Limited
 June 7, 2022 Page 2
 FirstName LastName
Weidong  Luo
Aurora Mobile Limited
June 7, 2022
Page 2
2.We note your response to prior comment 2 and previous related response. Please disclose
whether you have written cash management policies and procedures that dictate how
funds are transferred.
About This Prospectus, page 1
3.We note that your definition of "China" and "PRC" excludes Hong Kong and Macau.
Please revise your disclosure throughout the prospectus to include references to Hong
Kong and Macau as China and/or the PRC.
            Please contact Kyle Wiley, Staff Attorney, at 202-344-5791 or Jan Woo, Legal Branch
Chief, at 202-551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Shu Du

CORRESP
1
filename1.htm

CORRESP

 SKADDEN , ARPS , SLATE , MEAGHER &
FLOM

AFFILIATE OFFICES

——————

PARTNERS

世達國際律師事務所

BOSTON

GEOFFREY CHAN *

42/F, EDINBURGH TOWER, THE LANDMARK

CHICAGO

SHU DU *

HOUSTON

 ANDREW L. FOSTER *

CHI T. STEVE KWOK*

15 QUEEN’S ROAD CENTRAL, HONG KONG

 LOS ANGELES

NEW YORK

EDWARD H.P. LAM ◆*

——————

PALO ALTO

HAIPING LI *

 TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

WASHINGTON, D.C.

RORY MCALPINE ◆

WILMINGTON

JONATHAN B. STONE *

——————

KAI SUN

BEIJING

PALOMA P. WANG

BRUSSELS

◆ (ALSO ADMITTED IN ENGLAND & WALES)

FRANKFURT

* (ALSO ADMITTED IN NEW YORK)

LONDON

MUNICH

PARIS

SÃO PAULO

SEOUL

SHANGHAI

SINGAPORE

TOKYO

May 19, 2022

TORONTO

 VIA EDGAR

 Mr. Kyle
Wiley, Staff Attorney

 Ms. Jan Woo, Legal Branch Chief

Office of Technology

 Division of Corporation Finance

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Aurora Mobile Limited

Response to the Staff’s Comments on

Amendment No. 1 to Registration Statement on Form F-3

Filed on April 29, 2022 (File No. 333-260944)

Dear Ms. Woo and Mr. Wiley:

 On behalf
of our client, Aurora Mobile Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), 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 May 10, 2022, on the Company’s Amendment No. 1 to Registration Statement on Form F-3 filed on April 29, 2022. The Staff’s comments are repeated below in bold and are followed by the Company’s responses.

 Aurora Mobile Limited

May 19, 2022

  Page
 2

 Concurrently with the submission of this letter, the Company is filing herewith the Pre-Effective Amendment No. 2 to the Registration Statement (the “Amendment No. 2”), which reflects the revisions discussed in this letter, and certain exhibits via EDGAR
with the Commission.

 Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No. 2.

 Cover Page

1.
 We note your response to prior comment 1. We also note your disclosure that, ““Aurora” refers
to Aurora Mobile Limited, and “we,” “us,” “our company,” or “our” refers to Aurora Mobile Limited and its subsidiaries, and, when describing our operations and consolidated financial information, also includes
the VIE and its subsidiaries in China.” Refrain from using terms such as “we” or “our” when describing activities or functions of a VIE and revise accordingly.

In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page, pages 5, 17, 18, 24 and where
applicable in the Amendment No. 2.

2.
 We note your response to prior comment 4 regarding how cash is transferred through your organization. Please
include this disclosure on the cover page.

 In response to the Staff’s comment, the Company has revised the
disclosure on the prospectus cover page of the Amendment No. 2.

3.
 Given that the SEC has provisionally named you as a “Commission-Identified Issuer”, please expand
your disclosure to clarify that you will be added to the conclusive list of Commission-Identified Issuers unless you believe that you have been incorrectly identified and are disputing your placement on the provisional list.

 In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page, pages
19 and 27 of the Amendment No. 2.

 Our Company, page 5

4.
 We note your response to prior comment 6 relating to the permissions or approvals that you or your
subsidiaries may be required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors. Please also describe the consequences to you and your investors if you, your subsidiaries or
the VIEs: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and it is
required to obtain such permissions or approvals in the future.

 Aurora Mobile Limited

May 19, 2022

  Page
 3

 In response to the Staff’s comment, the Company has revised the disclosure on pages 8
and 9 of the Amendment No. 2.

 Aurora Mobile Limited

May 19, 2022

  Page
 4

 *    *     *

On behalf of the Company, we advise the Staff that the Company is aware of and acknowledges that the Company is responsible for the adequacy
and accuracy of the disclosure in the filing.

 If you have any questions regarding the Amendment No. 2, please do not hesitate to
contact the undersigned by phone at +852 3740-4858 or via e-mail at shu.du@skadden.com.

 Very truly yours,

 /s/ Shu Du

 Shu Du

 Enclosures

cc:
 Weidong Luo, Chairman of the Board of Directors and Chief Executive Officer, Aurora Mobile Limited

 Shan-Nen Bong, Chief Financial Officer, Aurora Mobile Limited

Maple Liao, Partner, Ernst & Young Hua Ming LLP

United States securities and exchange commission logo
May 10, 2022
Weidong Luo
Chief Executive Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 8, Keji South 12th Road, Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Amendment No. 1 to Registration Statement on Form F-3
Filed April 29, 2022
File No. 333-260944
Dear Mr. Luo:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 10, 2022 letter.
Amendment No. 1 to Registration Statement on Form F-3
Cover Page
1.We note your response to prior comment 1. We also note your disclosure that, "“Aurora”
refers to Aurora Mobile Limited, and “we,” “us,” “our company,” or “our” refers to
Aurora Mobile Limited and its subsidiaries, and, when describing our operations and
consolidated financial information, also includes the VIE and its subsidiaries in
China." Refrain from using terms such as “we” or “our” when describing activities or
functions of a VIE and revise accordingly.

 FirstName LastNameWeidong  Luo
 Comapany NameAurora Mobile Limited
 May 10, 2022 Page 2
 FirstName LastName
Weidong  Luo
Aurora Mobile Limited
May 10, 2022
Page 2
2.We note your response to prior comment 4 regarding how cash is transferred through your
organization. Please include this disclosure on the cover page.
3.Given that the SEC has provisionally named you as a "Commission-Identified Issuer",
please expand your disclosure to clarify that you will be added to the conclusive list
of Commission-Identified Issuers unless you believe that you have been incorrectly
identified and are disputing your placement on the provisional list.
Our Company, page 5
4.We note your response to prior comment 6 relating to the permissions or approvals that
you or your subsidiaries may be required to obtain from Chinese authorities to operate
your business and to offer the securities being registered to foreign investors. Please also
describe the consequences to you and your investors if you, your subsidiaries or the
VIEs: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently
conclude that such permissions or approvals are not required, or (iii) applicable laws,
regulations, or interpretations change and it is required to obtain such permissions or
approvals in the future.
            You may contact Kyle Wiley, Staff Attorney, at 202-344-5791 or Jan Woo, Legal Branch
Chief, at 202-551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Shu Du

CORRESP
1
filename1.htm

CORRESP

 VIA EDGAR

Ms. Jan Woo, Legal Branch Chief

 Mr. Kyle Wiley, Staff
Attorney

 Office of Technology

 Division of Corporation
Finance

 Securities and Exchange Commission

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:
 Aurora Mobile Limited

Response to the Staff’s Comments on

Registration Statement on Form F-3

Filed on November 10, 2021 (File No. 333-260944)

 Dear Ms. Woo and Mr. Wiley:

 On
behalf of our client, Aurora Mobile Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), 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 10, 2022, on the Company’s Registration Statement on Form F-3 filed on November 10, 2021 (the “Registration Statement”). The Staff’s comments are repeated below in bold and are followed by the Company’s responses.

Concurrently with the submission of this letter, the Company is filing herewith the Pre-Effective
Amendment No. 1 to the Registration Statement (the “Amendment No. 1”), which reflects the revisions discussed in this letter, and certain exhibits via EDGAR with the Commission.

 Aurora Mobile Limited

April 29, 2022

  Page
 2

 Capitalized terms used but not otherwise defined herein have the meanings set forth in the
Amendment No. 1.

 Cover Page

1.
 Clearly disclose how you will refer to the holding company, subsidiaries, and VIEs when providing the
disclosure throughout the document so that it is clear to investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business operations. Refrain from using terms such as “we” or
“our” when describing activities or functions of a VIE. For example, disclose, if true, that your subsidiaries and/or the VIE conduct operations in China, that the VIE is consolidated for accounting purposes but is not an entity in which
you own equity, and that the holding company does not conduct operations. Disclose clearly the entity (including the domicile) in which investors are purchasing an interest.

In response to the Staff’s comment, the Company has revised the disclosure where applicable in the Amendment No. 1.

2.
 Please refrain from implying that the contractual agreements are equivalent to equity ownership in the
business of the VIE. Any references to control or benefits that accrue to you because of the VIE should be limited to a clear description of the conditions the company has satisfied for consolidation of the VIE under U.S. GAAP. The disclosure also
should clarify that you are the primary beneficiary of the VIE for accounting purposes. These disclosures should be reflected throughout the filing.

In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page of the Amendment No. 1.

3.
 Provide prominent disclosure about whether the PCAOB is able to investigate completely your auditor and
whether and how the Holding Foreign Companies Accountable Act will impact your business.

 In response to the
Staff’s comment, the Company has revised the disclosure on the prospectus cover page, the prospectus summary, as well as pages 17, 18, 25 and 26 of the Amendment No. 1.

 Aurora Mobile Limited

April 29, 2022

  Page
 3

4.
 Provide a clear description of how cash is transferred through your organization. Disclose your intentions
to distribute earnings or settle amounts owed under the VIE agreements. Quantify any cash flows and transfers of other assets by type that have occurred between the holding company, its subsidiaries, and consolidated VIEs, and direction of transfer.
Quantify any dividends or distributions that a subsidiary or consolidated VIE have made to the holding company and which entity made such transfer, and their tax consequences. Similarly quantify dividends or distributions made to U.S. investors, the
source, and their tax consequences. Your disclosure should make clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign exchange and your ability to transfer cash between entities, across
borders, and to U.S. investors. Describe any restrictions and limitations on your ability to distribute earnings from the company, including your subsidiaries and/or the consolidated VIEs, to the parent company and U.S. investors as well as the
ability to settle amounts owed under the VIE agreements.

 In response to the Staff’s comment, the Company has
revised the disclosure on pages 11 and 12 of the Amendment No. 1.

 Our Company, page 4

5.
 We note that the consolidated VIEs constitute a material part of your consolidated financial statements.
Please move the condensed consolidating schedule to the prospectus summary.

 In response to the Staff’s comment,
the Company has revised the disclosure on pages 12 to 15 of the Amendment No. 1.

6.
 State whether you, your subsidiaries, or VIEs are covered by permissions requirements from the CSRC, CAC or
any other entity that is required to approve of the VIE’s operations, and state affirmatively whether you have received all requisite permissions and whether any permissions have been denied. Additionally, describe the consequences to you and
your investors if you, your subsidiaries or the VIEs: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals are not required, or (iii) applicable laws,
regulations, or interpretations change and it is required to obtain such permissions or approvals in the future.

 In
response to the Staff’s comment, the Company has revised the disclosure on pages 5 to 7 of the Amendment No. 1.

 Aurora Mobile Limited

April 29, 2022

  Page
 4

7.
 We note your disclosure that “the WFOE has not paid dividends and will not be able to pay dividends
until it generates accumulated profits and meets the requirements for statutory reserve funds.” Please clarify whether or not you have paid dividends to your investors.

In response to the Staff’s comment, the Company has revised the disclosure on page 11 of the Amendment No. 1.

8.
 Please disclose whether the PCAOB has been or is currently unable to inspect your auditor.

 In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page, as
well as pages 17 and 25 of the Amendment No. 1.

 Risk Factors, page 14

9.
 Please update your disclosure to reflect that the Commission adopted rules to implement the HFCAA and that,
pursuant to the HFCAA, the PCAOB has issued its report notifying the Commission of its determination that it is unable to inspect or investigate completely accounting firms headquartered in mainland China or Hong Kong. Please disclose whether your
auditor is subject to the determinations announced by the PCAOB on December 16, 2021 and whether and how the Holding Foreign Companies Accountable Act and related regulations will affect your company.

In response to the Staff’s comment, the Company has revised the disclosure on the prospectus cover page, as well as pages 8, 17, 18, 25
and 26 of the Amendment No. 1.

 Aurora Mobile Limited

April 29, 2022

  Page
 5

*                *
         *

 On behalf of the Company, we advise the Staff that the Company is aware of and
acknowledges that the Company is responsible for the adequacy and accuracy of the disclosure in the filing.

 If you have any questions
regarding the Registration Statement, please do not hesitate to contact the undersigned by phone at +852 3740-4863 or via e-mail at julie.gao@skadden.com.

Very truly yours,

 /s/ Z. Julie Gao

Z. Julie Gao

 Enclosures

cc:
 Weidong Luo, Chairman of the Board of Directors and Chief Executive Officer, Aurora Mobile Limited

 Shan-Nen Bong, Chief Financial Officer, Aurora Mobile Limited

Shu Du, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Maple Liao, Partner, Ernst & Young Hua Ming LLP

United States securities and exchange commission logo
January 10, 2022
Weidong Luo
Chief Executive Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 8, Keji South 12th Road, Nanshan District
Shenzhen, Guangdong 518057
People’s Republic of China
Re:Aurora Mobile Limited
Registration Statement on Form F-3
Filed November 10, 2021
File No. 333-260944
Dear Mr. Luo:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Cover Page
1.Clearly disclose how you will refer to the holding company, subsidiaries, and VIEs when
providing the disclosure throughout the document so that it is clear to investors which
entity the disclosure is referencing and which subsidiaries or entities are conducting the
business operations. Refrain from using terms such as “we” or “our” when describing
activities or functions of a VIE. For example, disclose, if true, that your subsidiaries
and/or the VIE conduct operations in China, that the VIE is consolidated for accounting
purposes but is not an entity in which you own equity, and that the holding company does
not conduct operations. Disclose clearly the entity (including the domicile) in which

 FirstName LastNameWeidong  Luo
 Comapany NameAurora Mobile Limited
 January 10, 2022 Page 2
 FirstName LastName
Weidong  Luo
Aurora Mobile Limited
January 10, 2022
Page 2
investors are purchasing an interest.
2.Please refrain from implying that the contractual agreements are equivalent to equity
ownership in the business of the VIE.  Any references to control or benefits that accrue to
you because of the VIE should be limited to a clear description of the conditions the
company has satisfied for consolidation of the VIE under U.S. GAAP. The disclosure also
should clarify that you are the primary beneficiary of the VIE for accounting purposes.
These disclosures should be reflected throughout the filing.
3.Provide prominent disclosure about whether the PCAOB is able to investigate completely
your auditor and whether and how the Holding Foreign Companies Accountable Act will
impact your business.
4.Provide a clear description of how cash is transferred through your organization. Disclose
your intentions to distribute earnings or settle amounts owed under the VIE agreements.
Quantify any cash flows and transfers of other assets by type that have occurred between
the holding company, its subsidiaries, and consolidated VIEs, and direction of transfer.
Quantify any dividends or distributions that a subsidiary or consolidated VIE have made
to the holding company and which entity made such transfer, and their tax consequences.
 Similarly quantify dividends or distributions made to U.S. investors, the source, and their
tax consequences.  Your disclosure should make clear if no transfers, dividends, or
distributions have been made to date.   Describe any restrictions on foreign exchange and
your ability to transfer cash between entities, across borders, and to U.S. investors.
Describe any restrictions and limitations on your ability to distribute earnings from the
company, including your subsidiaries and/or the consolidated VIEs, to the parent company
and U.S. investors as well as the ability to settle amounts owed under the VIE
agreements.
Our Company, page 4
5.We note that the consolidated VIEs constitute a material part of your consolidated
financial statements.  Please move the condensed consolidating schedule to the prospectus
summary.
6.State whether you, your subsidiaries, or VIEs are covered by permissions requirements
from the CSRC, CAC or any other entity that is required to approve of the VIE’s
operations, and state affirmatively whether you have received all requisite permissions
and whether any permissions have been denied. Additionally, describe the consequences
to you and your investors if you, your subsidiaries or the VIEs:  (i) do not receive or
maintain such permissions or approvals, (ii) inadvertently conclude that such permissions
or approvals are not required, or (iii) applicable laws, regulations, or interpretations
change and it is required to obtain such permissions or approvals in the future.

 FirstName LastNameWeidong  Luo
 Comapany NameAurora Mobile Limited
 January 10, 2022 Page 3
 FirstName LastName
Weidong  Luo
Aurora Mobile Limited
January 10, 2022
Page 3
7.We note your disclosure that “the WFOE has not paid dividends and will not be able to
pay dividends until it generates accumulated profits and meets the requirements for
statutory reserve funds.” Please clarify whether or not you have paid dividends to your
investors.
8.Please disclose whether the PCAOB has been or is currently unable to inspect your
auditor.
Risk Factors, page 14
9.Please update your disclosure to reflect that the Commission adopted rules to implement
the HFCAA and that, pursuant to the HFCAA, the PCAOB has issued its report notifying
the Commission of its determination that it is unable to inspect or investigate completely
accounting firms headquartered in mainland China or Hong Kong. Please disclose
whether your auditor is subject to the determinations announced by the PCAOB on
December 16, 2021 and whether and how the Holding Foreign Companies Accountable
Act and related regulations will affect your company.

            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Kyle Wiley, Staff Attorney, at 202-344-5791 or Jan Woo, Legal Branch
Chief, at 202-551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Julie Gao

CORRESP
1
filename1.htm

CORRESP

 Skadden, Arps, Slate, Meagher & Flom

世達國際律師事務所

 PARTNERS

CHRISTOPHER W. BETTS

WILL H. CAI ^

GEOFFREY CHAN *

ANDREW L. FOSTER *

CHI T. STEVE KWOK *

EDWARD H.P. LAM ◆*

HAIPING LI *

 RORY
MCALPINE ◆

 CLIVE W. ROUGH ◆

JONATHAN B. STONE *

 ^
(ALSO ADMITTED IN CALIFORNIA)

 ◆ (ALSO ADMITTED
IN ENGLAND & WALES)

 * (ALSO ADMITTED IN
NEW YORK)

 REGISTERED
FOREIGN LAWYERS

 Z. JULIE GAO (CALIFORNIA)

BRADLEY A. KLEIN (ILLINOIS)

 42/F, EDINBURGH TOWER, THE LANDMARK

15 QUEEN’S ROAD CENTRAL, HONG KONG

 TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

 July 23,
2018

 AFFILIATE OFFICES

 BOSTON

CHICAGO

 HOUSTON

LOS ANGELES

 NEW YORK

PALO ALTO

 WASHINGTON, D.C.

WILMINGTON

 BEIJING

BRUSSELS

 FRANKFURT

LONDON

 MOSCOW

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

TOKYO

 TORONTO

 VIA EDGAR

Ms. Barbara C. Jacobs, Assistant Director

Mr. Matthew Derby, Staff Attorney

 Mr. Craig Wilson,
Senior Assistant Chief Accountant

 Ms. Melissa Walsh, Staff Accountant

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re:

 Aurora Mobile Limited (CIK No. 0001737339)

Registration Statement on Form F-1 Filed July 13, 2018(File No. 333-225993)

 Dear Ms. Jacobs, Mr. Derby, Mr. Wilson and Ms. Walsh:

On behalf of our client, Aurora Mobile Limited, a company organized under the laws of the Cayman Islands (the “Company”), we
submit to the staff (the “Staff”) of the Securities and Exchange Commission this letter setting forth the Company’s responses to the comments contained in the Staff’s letter dated July 16, 2018 and letter dated
July 18, 2018. Concurrently with the submission of this letter, the Company is publicly filing Amendment No. 2 to its registration statement on Form F-1 (the “Registration
Statement”) and certain exhibits via EDGAR.

 The Staff’s comments are repeated below in bold and are followed by the
Company’s responses. We have included page reference in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the
Registration Statement.

 U.S. Securities and Exchange Commission

July 23, 2018

  Page
 2

 To facilitate your review, we have separately delivered to you today four courtesy copies of
the Registration Statement, marked to show changes to the Amendment No. 1 to registration statement filed on July 13, 2018.

 The
Company plans to request that the Staff declare the effectiveness of the Registration Statement on or about July 25, 2018, and will file the joint acceleration requests in time before the requested effective time. The Company would greatly
appreciate the Staff’s continued assistance and support in meeting its timetable.

 Comments in Letter Dated July 16, 2018

General

1.
We note your response to prior comment 17 from our May 17, 2018 letter and your revised disclosure indicating that “ADS holders waive the right to a jury trial of any claim they may have against us or the
depositary arising out of or relating to our shares, the ADSs or the deposit agreement, including any claim under the U.S. federal securities laws.” Please provide a risk factor regarding the impact of this provision of the deposit agreement on
the rights of ADS holders. In addition, address potential enforceability issues. Finally, clarify that by agreeing to the provision, investors will not be deemed to have waived Aurora’s or the depositary’s compliance with U.S. federal
securities laws and the rules and regulations promulgated thereunder.

 In response to the Staff’s comment, the
Company has included a risk factor on page 58 of the Registration Statement regarding the impact of the “Jury Trial Waiver” clause in the deposit agreement on the rights of ADS holders, whereby the disclosure addresses potential
enforceability issues and clarifies that by agreeing to the “Jury Trial Waiver” provision, ADS holders will not be deemed to have waived the Company’s or the depositary’s compliance with U.S. federal securities laws and the rules
and regulations promulgated thereunder.

 U.S. Securities and Exchange Commission

July 23, 2018

  Page
 3

 Comments in Letter Dated July 18, 2018

Recent Developments, page 5

1.
We note that net loss in the three months ended June 30, 2018 includes the effects of a fair value gain on derivative liability. Tell us and revise to disclose the nature and significant terms of this derivative
liability and how you are accounting for the derivative and fair value effects. Please ensure that your subsequent events disclosure on page F-41 includes the related financial effects. Refer to ASC 855-10-50-2.

The Company advises the Staff that the convertible notes issued on April 17, 2018 (the “Convertible Notes”) contain the
following terms:

(i)
if no qualified initial public offering were to occur within two years of the issue date, i.e., April 17, 2018, the outstanding obligation at their principal amount, with an amount representing a total internal
rate of return of 8% per annum, under the Convertible Notes would be immediately due and payable (“Contingent Redemption Option”), and

(ii)
if an event of default were to occur, a simple interest of 15% will accrue on the principal, and if the Company fails to deliver and register title to any shares following conversion of any Convertible Note, an interest
represents a total internal rate of return of 15 % per annum will accrue on the principal (both “Contingent Interest Feature”).

The Company evaluated the embedded conversion features contained in the Convertible Notes in accordance with ASC
815-15 and ASC 815-40 to determine if the conversion options require bifurcation. The Conversion Option of the Convertible Note did not qualify for derivative accounting
as the underlying common shares which the Convertible Notes could be converted into were not publicly traded nor could they be readily convertible into cash. Upon the consummation of the initial public offering, while the net settlement criteria is
subsequently met, the Conversion Option continues not to qualify for derivative accounting as it meets the scope exception provided for under ASC
815-10-15-74(a).

The Company also evaluated the Contingent Redemption Option and Contingent Interest Feature contained in the Convertible Notes in accordance
with ASC 815. Both features qualify for derivative accounting as they are not clearly and closely related to the debt host and will be accounted for as a single compound derivative. On issuance date, the Company recognized a derivative liability of
US$3.2 million, which was subsequently accounted for at fair value with a change in fair value of US$1.5 million recognized in the consolidated statement of comprehensive loss for the three months ended June 30, 2018.

The Company has revised the respective disclosures beginning on pages F-41 and F-68.

 U.S. Securities and Exchange Commission

July 23, 2018

  Page
 4

2.
Please revise to include reconciliations of the non-GAAP financial measure of EBITDA for the three months ended June 30, 2018 and the three months ended June 30, 2017
to the most directly comparable GAAP financial measures. Refer to Item 10(e)(1)(i)(B) of Regulation S-K.

In response to the Staff’s comment, the Company has revised the disclosure on page 6 of the Registration Statement to include
reconciliations of the non-GAAP financial measures.

3.
Please label the ADS per share data as pro forma information. Revise to clarify how you computed the weighted average number of ADSs used to calculate the net loss per ADS, and disclose the significant assumptions.
Provide a reconciliation to the weighted average number of shares used in calculating your basic and diluted historical net loss per common share, including assumptions. See Rules 11-01(a)(8) and 11-02(b)(6) and (7) of Regulation S-X.

 In
response to the Staff’s comment, the Company has revised the disclosures on page 15 of the Registration Statement.

 General

4.
We note that the Form of Deposit Agreement was filed as exhibit 4.3. In light of our comment letter issued July 16, 2018, we are reviewing the exhibit and may have additional comments.

The Staff’s comment is noted. Please see above the Company’s response to comment #1 contained in the Staff’s letter dated
July 16, 2018.

 *        *        *

 U.S. Securities and Exchange Commission

July 23, 2018

  Page
 5

 If you have any questions regarding the Registration Statement, please contact the
undersigned by phone at +852 3740-4863 or via e-mail at julie.gao@skadden.com or Lionel Li, the audit engagement partner at Ernst & Young Hua Ming LLP, by telephone at +86 755 2502-8149 or via email
at lionel.li@cn.ey.com. Ernst & Young Hua Ming LLP is the independent registered public accounting firm of the Company.

Very truly yours,

 /s/ Z. Julie Gao

Z. Julie Gao

 Enclosures

cc:
Weidong Luo, Chairman of the Board of Directors and Chief Executive Officer, Aurora Mobile Limited

Fei Chen, President, Aurora Mobile Limited

Shan-Nen Bong, Chief Financial Officer, Aurora Mobile Limited

Lionel Li, Partner, Ernst & Young Hua Ming LLP

Chris K.H. Lin, Esq., Partner, Simpson Thacher & Bartlett LLP

Daniel Fertig, Esq., Partner, Simpson Thacher & Bartlett LLP

CORRESP
1
filename1.htm

Underwriters' Acceleration Request

 Goldman Sachs (Asia) L.L.C.

68th Floor, Cheung Kong Center

 2 Queen’s Road Central

Hong Kong

 Credit Suisse Securities (USA) LLC

Eleven Madison Avenue

 New York, New York 10010

United States of America

 Deutsche Bank Securities Inc.

60 Wall Street

 New York, New York 10005

United States of America

 As representatives of the prospective
underwriters

 VIA EDGAR

 July 23, 2018

Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:

Ms. Barbara C. Jacobs, Assistant Director

Mr. Matthew Derby, Staff Attorney

Mr. Craig Wilson, Senior Assistant Chief Accountant

Ms. Melissa Walsh, Staff Accountant

Re:

Aurora Mobile Limited (the “Company”)

Registration Statement on Form F-1, as amended (Registration No. 333-225993)

Registration Statement on Form 8-A (Registration No. 001-38587)

 Dear Ladies and Gentlemen:

We hereby join the Company’s request for acceleration of the above-referenced Registration Statements, requesting effectiveness at 4:00
p.m., Eastern Daylight Time on July 25, 2018, or as soon thereafter as is practicable.

 2

 Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities
Act of 1933, as amended, we wish to advise you that between July 13, 2018 and the date hereof, copies of the Company’s Preliminary Prospectus dated July 13, 2018 were distributed as follows: approximately 460 copies to prospective
underwriters, institutional investors, dealers and others.

 We have been advised by the prospective underwriters that they have complied
and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature page follows]

Very truly yours,

Goldman Sachs (Asia) L.L.C.

Credit Suisse Securities (USA) LLC

Deutsche Bank Securities Inc.

As representatives of the prospective underwriters

GOLDMAN SACHS (ASIA) L.L.C.

By:

 /s/ Eric Liu

Name:

Eric Liu

Title:

Managing Director

 [Acceleration Request
Letter]

CREDIT SUISSE SECURITIES (USA) LLC

By:

 /s/ Anthony Kontoleon

Name:

Anthony Kontoleon

Title:

Head of Global Syndicate, Managing Director

 [Acceleration Request
Letter]

DEUTSCHE BANK SECURITIES INC.

By:

 /s/ Mark Schwartz

Name:

Mark Schwartz

Title:

Managing Director

By:

 /s/ Thomas Schweigl

Name:

Thomas Schweigl

Title:

Director

 [Acceleration Request
Letter]

CORRESP
1
filename1.htm

Issuer Acceleration Request

 July 23, 2018

VIA EDGAR

 Ms. Barbara C. Jacobs, Assistant
Director

 Mr. Matthew Derby, Staff Attorney

 Mr. Craig
Wilson, Senior Assistant Chief Accountant

 Ms. Melissa Walsh, Staff Accountant

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

U. S. A.

Re:
Aurora Mobile Limited (CIK No. 0001737339)

Registration Statement on Form F-1 (File No. 333-225993)

Registration Statement on Form 8-A (File No. 001-38587)

 Dear Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation C (“Rule 461”) promulgated under the Securities Act of 1933, as amended, Aurora Mobile Limited
(the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 (the “F-1 Registration Statement”) be accelerated to, and that the Registration Statement become effective at, 4:00
p.m., Eastern Time on July 25, 2018, or as soon thereafter as practicable.

 The Company also requests that the Registration Statement
on Form 8-A under the Securities Exchange Act of 1934, covering the American depositary shares representing Class A ordinary shares of the Company, be declared effective concurrently with the F-1 Registration Statement (the F-1 Registration
Statement, together with the Registration Statement on Form 8-A, the “Registration Statements”).

 If there is any change in the
acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461 of
Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Skadden, Arps, Slate, Meagher & Flom LLP.

The Company understands that the representatives of the underwriters, on behalf of the prospective underwriters of the offering, have joined
in this request in a separate letter filed with the Securities and Exchange Commission (the “Commission”) today.

 The Company
hereby acknowledges the following:

•

should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 [Signature page
follows]

Very truly yours,

Aurora Mobile Limited

By:

 /s/ Weidong Luo

Name:

Weidong Luo

Title:

 Chairman of the Board of Directors

 and Chief
Executive Officer

 [Signature Page to Issuer
Acceleration Request]

Mail Stop 4561
July 18, 2018

Weidong Luo
Chief Executive Officer
Aurora Mobile Ltd.
5/F, Building No. 7, Zhiheng Industrial Park
Nantou Guankou Road 2
Nanshan District, Shenzhen, Guangdong, 518052
People’s Republic of China

Re: Aurora Mobile Ltd.
Amendment No. 1 to Registration Statement on Form F -1
Filed July 13 , 2018
  File No. 333-225993

Dear Mr. Luo:

We have reviewed your amended registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
request ed information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the informatio n you
provide in response to these  comments, we may have  additional comments.

Recent Developments, page 5

1. We note that net loss in the three months ended June 30, 2018 includes the effects of a
fair value gain on derivative liability.  Tell us and revise to disclose the nature and
significant terms of this derivative liability and how you are accounting for th e derivative
and fair value effects.  Please ensure that your subsequent events disclosure on page F -41
includes the related financial effects.  Refer to ASC 855 -10-50-2.

2. Please revise to include reconciliations of the non -GAAP financial measure of EBITD A
for the three months ended June 30, 2018 and the three months ended June 30, 2017 to
the most directly comparable GAAP financial measures.  Refer to Item 10(e)(1)(i)(B) of
Regulation S -K.

Weidong Luo
Aurora Mobile Ltd.
July 18 , 2018
Page 2

 Summary Consolidated Financial and Operating Data, page 13

3. Please label the ADS per share data as pro forma information.  Revise to clarify how you
computed the weighted average number of ADSs used to calculate the net loss per ADS ,
and disclose the significant assumptions.   Provide a reconciliation to the weighted
average number of shares used in calculating your basic and diluted historical net loss per
common share, including assumptions.  See Rules 11 -01(a)(8) and 11 -02(b)(6) and (7) of
Regulation S -X.

General

4. We note that the Form of Deposit Agreement  was filed as exhibit 4.3.  In light of our
comment letter issued July 16, 2018, we are reviewing the exhibit and may have
additional comments.

You may contact Melissa Walsh, Staff Accountant, at (202) 551 -3224 or Craig Wilson,
Senior As sistant Chief Accountant, at (202) 551 - 3226 if you have questions regarding
comments on the financial statements and related matters.  Please contact Matthew Derby, Staff
Attorney, at (202) 551 -3334 o r me at (202) 551 -3735 with any other questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director
Office of Information Technologies
and Services

cc: Z. Julie Gao
 Skadden, Arps, Slate, Meagher & Flom LLP

Mail Stop 4561
July 16 , 2018

Weidong Luo
Chief Executive Officer
Aurora Mobile Ltd.
5/F, Building No. 7, Zhiheng Industrial Park
Nantou Guankou Road 2
Nanshan District, Shenzhen, Guangdong, 518052
People’s Republic of China

Re: Aurora Mobile Ltd.
Registration Statement on Form F -1
Filed June 29 , 2018
  File No. 333-225993

Dear Mr. Luo:

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested informati on.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provid e in response to these  comments, we may have  additional comments.

General

1. We note your response to prior comment 17 from our May 17, 2018 letter and your
revised disclosure indicating that “ADS holders waive the right to a jury trial of any
claim they may have against us or the depositary arising out of or relating to our shares,
the ADSs or the deposit agreement, including any claim under the U.S. federal securities
laws.”   Please provide a risk factor regarding the impact of this provision of the depo sit
agreement on the rights of ADS holders.   In addition, address potential enforceability
issues .  Finally, clarify that by agreeing to the provision, investors will not be deemed to
have waived Aurora’s or the depositary’s compliance with U.S. federal se curities laws
and the rules and regulations promulgated thereunder .

Weidong Luo
Aurora Mobile Ltd.
July 16, 2018
Page 2

 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 t he staff.

Refer to Rules 460 and 461 regarding requests for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

You may contact Melissa Walsh, Staff Account ant, at (202) 551 -3224 or Craig Wilson,
Senior Assistant Chief Accountant, at (202) 551 - 3226 if you have questions regarding
comments on the financial statements and related matters.  Please contact Matthew Derby, Staff
Attorney, at (202) 551 -3334 o r me a t (202) 551 -3735 with any other questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director
Office of Information Technologies
and Services

cc: Z. Julie Gao
 Skadden, Arps, Slate, Meagher & Flom LLP

CORRESP
1
filename1.htm

CORRESPONDENCE

 SKADDEN, ARPS, SLATE,
MEAGHER & FLOM

 世達國際律師事務所

 PARTNERS

CHRISTOPHER W. BETTS

WILL H. CAI ^

GEOFFREY CHAN *

CHI T. STEVE KWOK *

EDWARD H.P. LAM ◆*

HAIPING LI *

 RORY
MCALPINE ◆

 CLIVE W. ROUGH ◆

JONATHAN B. STONE *

 ^
(ALSO ADMITTED IN CALIFORNIA)

 ◆ (ALSO ADMITTED
IN ENGLAND & WALES)

 * (ALSO ADMITTED IN
NEW YORK)

 REGISTERED
FOREIGN LAWYERS

 ANDREW L. FOSTER (NEW YORK)

Z. JULIE GAO (CALIFORNIA)

BRADLEY A. KLEIN (ILLINOIS)

 42/F, EDINBURGH TOWER, THE LANDMARK

15 QUEEN’S ROAD CENTRAL, HONG KONG

 TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

 July 13,
2018

 AFFILIATE OFFICES

BOSTON

 CHICAGO

HOUSTON

 LOS ANGELES

NEW YORK

 PALO ALTO

WASHINGTON, D.C.

 WILMINGTON

 BEIJING

BRUSSELS

FRANKFURT

LONDON

MOSCOW

MUNICH

PARIS

SÃO PAULO

SEOUL

SHANGHAI

SINGAPORE

TOKYO

TORONTO

 VIA EDGAR

Ms. Barbara C. Jacobs, Assistant Director

Mr. Matthew Derby, Staff Attorney

 Mr. Craig Wilson,
Senior Assistant Chief Accountant

 Ms. Melissa Walsh, Staff Accountant

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

 Re:

 Aurora Mobile Limited (CIK No. 0001737339)

Registration Statement on Form F-1 (File
No. 333-225993)

 Dear Ms. Jacobs, Mr. Derby, Mr. Wilson and Ms. Walsh:

On behalf of our client, Aurora Mobile Limited, a company organized under the laws of the Cayman Islands (the “Company”), we
are filing herewith the Company’s Amendment No. 1 to the Registration Statement on Form F-1 (the “Revised Registration Statement”) and certain exhibits via EDGAR with the Securities
and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you today four courtesy copies of the Registration Statement, marked to show changes to the registration statement filed on June
29, 2018.

 The Company will commence marketing activities in connection with the offering shortly after the date hereof. The Company plans
to request that the Staff declare the effectiveness of the Registration Statement on or about July 25, 2018, and will file the joint acceleration requests in time before the requested effective time. The Company would greatly appreciate the
Staff’s continued assistance and support in meeting its timetable.

 U.S. Securities and Exchange Commission

July 13, 2018

  Page
 2

 In addition, the
Company is setting forth below its response to the second part of the Staff’s prior comment #10 contained in the comments letter dated May 17, 2018. The comments are repeated below in bold and are followed by the Company’s response.

10.
… In addition, when determined, also tell us your proposed IPO price, when you first initiated discussions with underwriters, and when the underwriters first communicated their estimated price range and amount
for your stock. In addition, please reconcile and explain the difference between the fair value of the underlying stock as of the most recent valuation date and the midpoint of your IPO offering range.

In response to the Staff’s comment, the Company has included a detailed description of the factors contributing to the increase in the
fair value of the common shares of the Company from US$9.81 per common share as of April 17, 2018 to US$14.25 per common share, the mid-point of the estimated price range for this offering, on
page 101 of the Registration Statement.

 The Company made an estimate of the fair value of the common shares on April 17, 2018,
when the Company issued zero coupon non-guaranteed and unsecured convertible notes due 2021 in an aggregate principal amount of US$35.0 million to two investors. Holders of the convertible notes may, at
their discretion during a period starting from the issue date of the notes until seven days prior to the maturity of the notes, subject to certain exceptions, convert the notes into Class A common shares of our company at the then-applicable
conversion price, which is initially US$11.7612 per common share, subject to certain anti-dilution adjustments. The Company determined that the fair value of the common shares as of April 17, 2018 were US$9.81 per common share.

For marketing purposes, an estimated initial public offering price range between US$8.50 and US$10.50 per ADS, equal to US$12.75 and US$15.75
per Class A common share (the “price range”), with a mid-point of US$14.25 per Class A common share, has been established and included in the Registration Statement containing the
preliminary prospectus for the offering filed concurrently herewith. The Company respectfully advises the Staff that this price range was estimated with reference to the valuation provided by the underwriters of this offering, which was in turn
derived from the information provided by the Company and current market conditions. The estimated price range is subject to change, which may result from variations in market conditions and other developments. Such developments may not be
within the control of, or foreseeable by, the Company. Accordingly, there is no assurance that the final offering price will fall within this estimated price range.

 2

 U.S. Securities and Exchange Commission

July 13, 2018

  Page
 3

 The Company believes
the implied increase in share value of US$9.81 per common share as of April 17, 2018 to US$14.25 per common share, the mid-point of the estimated price range, is primarily attributable to the following
factors:

 Organic growth of the Company’s business and increased revenue projections

The Company’s revenues increased by 30.6% sequentially from RMB126.4 million in the three months ended March 31, 2018 to
RMB165.1 million in the three months ended June 30, 2018.

 Revenues from developer services increased from RMB12.5 million
in the three months ended March 31, 2018 to RMB14.5 million in the three months ended June 30, 2018, with the number of customers increasing from 894 to 1,005 during the same periods.

Revenues from data solutions also increased from RMB113.9 million in the three months ended March 31, 2018 to RMB150.6 million
in the three months ended June 30, 2018, with the number of customers increasing from 454 to 597, and the average spending per customer increasing from RMB251.0 thousand to RMB252.2 thousand, during the same periods.

Increased probability of an IPO and substantially enhanced liquidity and marketability of the Company’s shares

The US$9.81 per common share valuation as of April 17, 2018 reflected the illiquidity of the Company’s shares at that time and the
uncertainty of the IPO. Given the proximity to the completion of the Company’s IPO, the estimated price range assumes a successful offering and represents an estimate of the fair value of the unrestricted, freely tradable shares that would be
sold in the public market without discounts for illiquidity and lack of marketability. For example, the independent valuation of the common shares as of April 17, 2018 applied a 9.5% “private company” discount to reflect the lack of
marketability. The difference between the fair value of the Company’s common shares as of April 17, 2018 and the mid-point of the price range, reflects a decrease of the discount for lack of
marketability from 9.5% to 0%.

 3

 U.S. Securities and Exchange Commission

July 13, 2018

  Page
 4

 Conversion of
preferred shares

 The holders of the Company’s convertible preferred shares currently enjoy substantial economic rights and
preferences over the holders of its common shares. In particular, the holders of Series D preferred shares are entitled to receive an amount equal to 115% of the Series D issue price, plus all declared but unpaid dividend; Series C preferred shares
are entitled to receive an amount equal to 100% of the issue price, plus an annual simple return of 10% accrued thereon and plus all declared but unpaid dividend; Series B preferred shares are entitled to receive an amount equal to 125% of the issue
price, plus an annual compounded return of 6% accrued thereon and plus all declared but unpaid dividend; and Series A preferred shares are entitled to receive an amount equal to 150% of the Series A issue price, plus an annual compounded return of
8% accrued thereon and plus all declared but unpaid dividend. Furthermore, holders of outstanding convertible preferred shares are entitled to receive liquidation preferences prior to payments to holders of common shares in the event of any
liquidation, dissolution or winding-up of the Company. In addition, holders of the Company’s outstanding convertible preferred shares are entitled to receive
non-cumulative dividends, prior and in preference to holders of common shares, when declared by the board of directors. The holders of convertible preferred shares also have anti-dilution protection under
certain circumstances. The estimated price range assumes the conversion of the Company’s convertible preferred shares upon the completion of this offering. The corresponding elimination of the preferences and rights enjoyed by the holders of
convertible preferred shares will result in an increased common share valuation.

 Substantially enhanced balance sheet and financial
resources

 Given the proximity to the completion of the IPO, the estimated price range assumes a successful offering. A successful
offering will provide the Company with (i) proceeds that substantially strengthen the Company’s balance sheet as a result of increased cash, (ii) access to the public company debt and equity markets, (iii) a “currency”
to enable the Company to make strategic acquisitions as the board of directors may deem appropriate, and (iv) higher brand value to attract new customers as a publicly listed company. These factors have been reflected in the valuation implied
by the estimated price range.

 Based on the various factors described above, the Company believes that the implied increase in share value
to US$14.25 per common share, the mid-point of the estimated price range, is reasonable.

 In addition, the Company respectfully advises the
Staff that in determining the fair value of the common shares as of various dates before the offering, the Company, with the assistance of an independent valuation firm, has considered the guidance prescribed by the AICPA Audit and Accounting and
Valuation Guide, “Valuation of Privately-Held-Company Equity Securities Issued as Compensation” (the “Guide”).

 4

 U.S. Securities and Exchange Commission

July 13, 2018

  Page
 5

 Paragraph 10.04 of
the Guide provides that:

 “The ultimate IPO price is generally not likely to be a reasonable estimate of the fair value for pre-IPO
equity transactions of the enterprise. The value of a private enterprise before and after a successful IPO may be significantly different. In addition, the IPO event itself increases enterprise value, because, among other things, it allows the
enterprise access to the public capital markets.”

 Paragraph 10.05 of the Guide provides further that:

“The IPO price also reflects an estimate of the expected valuation of the company’s shares based upon its position following a
successful IPO. As a result, it normally incorporates the effect of the issuance of primary shares by the company, the proceeds from which can be used to either reduce the company’s debt level or to provide capital to fully finance the
company’s expansion or development of its business plan. In contrast, most financings for earlier stage companies do not allow the company to reach break-even cash flows and to become self-sustaining. Therefore, the IPO price recommendation may
be free from the risk premium associated with the need to raise additional capital associated with earlier stage companies.”

 In
accordance with paragraphs 10.04 and 10.05 of the Guide, the Company believes neither the estimated mid-point of the preliminary indicative price range for this offering nor the final offering price itself should be construed as a reasonable
estimate of the fair value of its common shares as of various dates before this offering.

*        *        *

 5

 U.S. Securities and Exchange Commission

July 13, 2018

  Page
 6

 If you have any
questions regarding the Registration Statement, please contact the undersigned by phone at +852 3740-4863 or via e-mail at julie.gao@skadden.com or Lionel Li, the audit engagement partner at Ernst &
Young Hua Ming LLP, by telephone at +86 755 2502-8149 or via email at lionel.li@cn.ey.com. Ernst & Young Hua Ming LLP is the independent registered public accounting firm of the Company.

Very truly yours,

 /s/ Z. Julie Gao

Z. Julie Gao

 Enclosures

cc:
Weidong Luo, Chairman of the Board of Directors and Chief Executive

 Officer, Aurora Mobile
Limited

 Fei Chen, President, Aurora Mobile Limited

Shan-Nen Bong, Chief Financial Officer, Aurora Mobile Limited

Lionel Li, Partner, Ernst & Young Hua Ming LLP

Chris K.H. Lin, Esq., Partner, Simpson Thacher & Bartlett LLP

Daniel Fertig, Esq., Partner, Simpson Thacher & Bartlett LLP

 6

CORRESP
1
filename1.htm

CORRESPONDENCE

 SKADDEN, ARPS, SLATE,
MEAGHER & FLOM

 世達國際律師事務所

 PARTNERS

CHRISTOPHER W. BETTS

WILL H. CAI ^

GEOFFREY CHAN *

CHI T. STEVE KWOK *

EDWARD H.P. LAM ◆*

HAIPING LI *

 RORY
MCALPINE ◆

 CLIVE W. ROUGH ◆

JONATHAN B. STONE *

 ^
(ALSO ADMITTED IN CALIFORNIA)

 ◆ (ALSO ADMITTED
IN ENGLAND & WALES)

 * (ALSO ADMITTED IN
NEW YORK)

 REGISTERED
FOREIGN LAWYERS

 ANDREW L. FOSTER (NEW YORK)

Z. JULIE GAO (CALIFORNIA)

BRADLEY A. KLEIN (ILLINOIS)

 42/F, EDINBURGH TOWER, THE LANDMARK

15 QUEEN’S ROAD CENTRAL, HONG KONG

 TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

 June 29,
2018

 AFFILIATE OFFICES

BOSTON

 CHICAGO

HOUSTON

 LOS ANGELES

NEW YORK

 PALO ALTO

WASHINGTON, D.C.

 WILMINGTON

 BEIJING

BRUSSELS

FRANKFURT

LONDON

MOSCOW

MUNICH

PARIS

SÃO pAULO

SEOUL

SHANGHAI

SINGAPORE

TOKYO

TORONTO

 VIA EDGAR

Ms. Barbara C. Jacobs, Assistant Director

Mr. Matthew Derby, Staff Attorney

 Mr. Craig Wilson,
Senior Assistant Chief Accountant

 Ms. Melissa Walsh, Staff Accountant

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C.
20549

 Re:

 Aurora Mobile Limited (CIK No. 0001737339)

Registration Statement on Form F-1

 Dear Ms. Jacobs, Mr. Derby, Mr. Wilson and Ms. Walsh:

On behalf of our client, Aurora Mobile Limited, a company organized under the laws of the Cayman Islands (the “Company”), we
are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) via EDGAR to the Securities and Exchange Commission (the
“Commission”). To facilitate your review, we have separately delivered to you today four courtesy copies of the Registration Statement, marked to show changes to the revised draft registration statement confidentially submitted on
June 1, 2018.

 Concurrently with the filing of the Registration Statement, the Company is hereby in this letter setting forth the
Company’s responses to the comments contained in the letter from the staff of the Commission (the “Staff”) dated June 22, 2018. The Staff’s comments are repeated below in bold and are followed by the Company’s
response. We have included page references in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement.

 U.S. Securities and Exchange Commission

June 29, 2018

  Page
 2

 In accordance with
the Jumpstart Our Business Startups Act and the Fixing America’s Surface Transportation Act, the Company plans to file an amendment to the Registration Statement containing the estimated price range and offering size and launch the road show no
earlier than 15 days after the date hereof and would appreciate the Staff’s prompt feedback to this filing.

 Part I. Comments in the
Staff’s letter dated June 22, 2018

 Dilution, page 64

1.
In the dilution table, you indicate that the amount presented for pro forma net tangible book value per share gives effect to the redemption of 1,738,720 Series C preferred shares, as well as the conversion of your
preferred shares. Please confirm that your computation is accurate. In this regard, it appears that the per share amount does not give effect to the redemption.

In response to the Staff’s comment, the Company has revised the disclosure on page 65 of the Registration Statement.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Key Factors Affecting Our Results of Operations

Our ability to increase the number of customers and average spending per customer, page 78

2.
You indicate that expanding your customer base and increasing the average spending per customer are key drivers of your revenue growth. Please revise to explain the underlying trends in the sequential difference in
the number of customers and average spending per customer. Address the basis for the underlying trends in the operating data for developer services and data solutions separately. In this regard, we note that the number of customers in the three
months ended March 31, 2018 is lower than the number of customers for the year ended December 31, 2017. Please explain why the number of customers in a given period that purchase at least one of your
paid-for developer services or data solutions, as defined, would decline. We also note that while the average spending per customer for data solutions was higher, the average spending per customer for
developer services declined for the three months ended March 31, 2018 compared to the year ended December 31, 2017. Please address these offsetting trends. In addition, also address the increasing concentration in the number of developer
services customers in the three months ended March 31, 2018 compared to the year ended December 31, 2017.

 2

 U.S. Securities and Exchange Commission

June 29, 2018

  Page
 3

 The Staff’s
comment is duly noted and the Company respectfully advises the Staff that it does not believe it would be very meaningful to compare the operating data in the first quarter of 2018 with the operating data in the full year of 2017 for the reasons
discussed below.

 For the Staff’s convenience of review, the Company sets forth in the table below the number of customers and average
spending per customer for developer services and data solutions, for each periods presented in the Registration Statement:

For the Year Ended
December 31,

For the Three Months
Ended March 31,

2016

2017

2017

2018

 Customers

1,168

2,263

980

1,348

 Customers of developer services

743

1,118

635

894

 Customers of data solutions

425

1,145

345

454

 Average spending per customer (RMB)

60,207

125,810

32,646

93,763

 Average spending per customer for developer services (RMB)

31,219

34,700

12,162

13,930

 Average spending per customer for data solutions (RMB)

110,885

214,772

70,348

250,967

 Number of Customers

As shown in the table above, the number of customers for both developer services and data solutions increased in the three months ended
March 31, 2018, compared to the three months ended March 31, 2017, which is the comparable period in 2017.

 The Company noted
that the number of customers for both developer services and data solutions in the three months ended March 31, 2018 was lower than that in the twelve months ended December 31, 2017. The Company believes, however, that it would not provide
meaningful additional information to the investors by comparing the number of customers in the three months ended March 31, 2018 with that in the full year of 2017 and explaining the underlying trends, if any, as the two periods are not
comparable, nor would it be logical to compare the number of customers and average spending per customer for a three-month period with that for a twelve-month period. As correctly pointed out by the Staff, the Company defines its customers in a
given period as those that purchase at least one of its paid for developer services or data solutions during the same period. While the Company has made great efforts to expand its customer base, the chance that a customer is attracted to purchase
the Company’s developer services or data solutions in the three months ended March 31, 2018 is lower than that in the twelve months ended December 31, 2017, given the difference in the length of the two periods being compared (three
months compared to twelve months).

 3

 U.S. Securities and Exchange Commission

June 29, 2018

  Page
 4

 Average Spending
Per Customer

 As shown in the table above, the average spending per customer for both data solutions and developer services increased
in the three months ended March 31, 2018, compared to the three months ended March 31, 2017, which is the comparable period in 2017.

Similarly, the Company does not believe it is meaningful to compare the average spending per customer in the three months ended March 31,
2018 with that in the full year of 2017 and explaining the underlying trends, if any, as the two periods are not comparable.

 Developer
services. The Company noted that the average spending per customer for developer services in the three months ended March 31, 2018 was lower than that in the twelve months ended December 31, 2017, but believes that the difference is
primarily a result of the difference in the length of the two periods being compared (three months compared to twelve months). The Company tends to generate more revenue on a per customer basis over a longer period of time. For example, as disclosed
in the Registration Statement, the Company generates revenue from the fees charged for the VIP premium package of certain developer services based on the subscription/service period, while it adopts a freemium model for most of its developer
services. For the purpose of illustration, assuming the Company has the same developer customer in both periods (i.e., the first quarter of 2018 and 2017), given the difference in the length of the two periods being compared (three months compared
to twelve months), it is not very likely that the subscription/service period during which the Company can provide VIP premium package of developer services to the same developer customer and generates revenue in the three months ended
March 31, 2018 is longer than that in the twelve months ended December 31, 2017.

 Data solutions. For the same reasons
referenced above, the Company believes that it would not be meaningful to compare the average spending per customer in the three months ended March 31, 2018 with that in the twelve months ended December 31, 2017. The Company noted that the
average spending per customer for data solutions in the three months ended March 31, 2018 was higher than that in the twelve months ended December 31, 2017, despite the difference in the length of the periods being compared, which the
Company believes is due to the substantial growth of Company’s data solutions business and the Company’s success in identifying and expanding cross-selling opportunities to improve customer spending in the three months ended March 31,
2018.

 In response to the Staff’s comments, the Company has revised the disclosure on page 79 of the Registration Statement to
disclose operating data, namely, the number of customers and average spending per customer, and the underlying trends for developer services and data solutions separately.

 4

 U.S. Securities and Exchange Commission

June 29, 2018

  Page
 5

 Taxation, page 178

3.
We note that you have filed the form of opinion of Han Kun Law Officers regarding certain PRC tax matters and the form of opinion of Maples and Calder (Hong Kong) LLP regarding certain Cayman Islands tax matters.
Please revise to clearly identify each material tax consequence being opined upon and identify the tax counsels. For guidance, refer to Section III of Staff Legal Bulletin No. 19.

In response to the Staff’s comment, the Company has revised the disclosure on page 179 of the Registration Statement.

Notes to the Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Revenue recognition, page F-14

4.
We note from your disclosure in Note 14 on page F-66 that revenue generated from other vertical data solutions has become more than 10% of total revenue. Please revise to
disclose the related revenue recognition policy.

 In response to the Staff’s comment, the Company has revised the
disclosure on page 95, page F-14 and page F-15 of the Registration Statement to disclose the revenue recognition policy in relation to revenue generated from other
vertical data solutions.

 Part II. Comments in the Staff’s letter dated May 17, 2018

Furthermore, the Company respectfully advises the Staff that the Company has selected The Bank of New York Mellon as its depositary bank and
has updated the section under the heading “Description of American Depositary Shares” and other related disclosure in the Registration Statement. The Company sets forth here below its responses to comments No. 16 to 18 contained in
the letter from the Staff dated May 17, 2018 with respect to “Description of American Depositary Shares.”

 Description of American
Depositary Shares

 Amendment and Termination, page 164

16.
The description of the ADSs indicates that you may amend or terminate the deposit agreement without consent. Please explain the circumstances under which you may exercise this right, and include corresponding risk
factor disclosure.

 The Company respectfully advises the Staff that the Company and the depositary may agree to amend the
deposit agreement in any way the Company decides is necessary or advantageous to it. Amendments may reflect, among other things, operational changes in the ADS program, legal developments affecting ADSs or changes in the terms of the business
relationship between the Company and the depositary. The terms of an amendment may be disadvantageous to ADS holders, but, in those cases, ADS holders will receive 30 days’ advance notice of the amendment, in which time holders may choose to
sell their ADSs or surrender their ADSs and become direct holders of the underlying common shares.

 5

 U.S. Securities and Exchange Commission

June 29, 2018

  Page
 6

 The Company may
decide to terminate the ADS facility at any time for any reason. For example, terminations may occur when the Company decides to list its shares on a non-U.S. securities exchange and determines not to continue
to sponsor an ADS facility or when it becomes the subject of a takeover or a going-private transaction. If the ADS facility will terminate, ADS holders will receive at least 90 days’ prior notice, in which time holders may choose to sell their
ADSs or surrender their ADSs and become direct holders of the underlying common shares.

 In response to the Staff’s comment, the
Company has revised the disclosure on page 54 of the Registration Statement to include a corresponding risk factor.

 Limitations on Obligations and
Liability to ADS Holders, page 165

17.
At the top of page 167, please clarify whether the waiver of the right to a jury trial applies to claims under the U.S. federal securities laws.

The Company respectfully advises the Staff that by its terms, the waiver of jury trial would apply to an action asserting any claim against the
Company or the depositary relating to the deposit agreement or the ADSs, including a federal securities law claim, to the extent permitted by law. If a party to the deposit agreement opposed a jury trial demand based on the waiver, the court would
determine whether the waiver was enforceable in the facts and circumstances of that case in accordance with applicable case law.

 In
response to the Staff’s comment, the Company has included disclosure on page 175 of the Registration Statement to clarify that the waiver of the right to jury trial would apply to claims under the U.S. federal securities laws to the extent
permitted by law.

 Governing Law, page 168

18.
Please clarify whether the arbitration provision in your deposit agreement relates to claims arising under the U.S. federal securities laws.

The Company respectfully advises the Staff that the deposit agreement gives the depositary or an ADS holder asserting a claim against the
Company the right to require the Company to submit that claim to binding arbitration in New York under the Rules of the American Arbitration Association, including any securities law claim. However, a claimant could also elect not to submit its
claim to arbitration and instead bring its claim in any court having jurisdiction of it. The deposit agreement does not give the Company the right to require anyone to submit any claim to arbitration.

In response to the Staff’s comment, the Company has included disclosure on page 176 of the Registration Statement to clarify that the
arbitration provision in the deposit agreement applies to U.S. federal securities l

Mail Stop 4561
June 22, 2018

Weidong Luo
Chief Executive Officer
Aurora Mobile  Ltd.
5/F, Building  No. 7, Zhiheng Industrial Park
Nantou Guankou Road 2
Nanshan District , Shenzhen, Guangdong, 518052
People’s Republic of China

Re: Aurora Mobile  Ltd.
Amendment No. 1 to Draft Registration Statement on Form F -1
Submitted June 1 , 2018
  CIK No. 0001737339

Dear Mr. Luo :

We have reviewed your amended draft registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.   Unless we note otherwise, our references to prior comments are to comme nts in our
May 17, 2018 letter .

Draft Registration Statement on Form F -1 Submitted June 1 , 2018

Dilution, page 64

1. In the dilution table, you indicate that the amount presented for pro forma net tangible
book value per share gives effect to the redemption of 1,738,720 Series C preferred
shares, as well as the conversion of your preferred shares.  Please confirm that yo ur
computation is accurate.  In this regard, it appears that the per share amount does not give
effect to the redemption.

Weidong Luo
Aurora Mobile  Ltd.
June 22, 2018
Page 2

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

Key Factors Affecting Our Results of Operatio ns

Our ability to increase the number of customers and average spending per customer, page 78

2. You indicate that expanding your customer base and increasing the average spending per
customer are key drivers of your revenue growth.   Please revise to explain the underlying
trends in the sequential difference in the number of customers and average spending per
customer.   Address the basis for the underlying trends in the operating data for developer
services and data solutions separately.  In this regar d, we note that the number of
customers in the three months ended March 31, 2018 is lower than the number of
customers for the year ended December 31, 2017.   Please explain why the number of
customers in a given period that purchase at least one of your pa id-for developer services
or data solutions, as defined, would decline.  We also note that while the average
spending per customer for data solutions was higher, the average spending per customer
for developer services declined for the three months ended M arch 31, 2018 compared to
the year ended December 31, 2017.   Please address these offsetting trends.   In addition,
also address the increasing concentration in the number of developer services customers
in the three months ended March 31, 2018 compared to the year ended December 31,
2017.

Taxation, page 178

3. We note that you have filed the form of opinion of Han Kun Law Officers regarding
certain PRC tax matters and the form of opinion of Maples and Calder (Hong Kong) LLP
regarding certain Cayman Islands  tax matters.  Please revise to clearly identify each
material tax consequence being opined upon and identify the tax counsels.  For guidance,
refer to Section III of Staff Legal Bulletin No. 19.

Notes to the Consolidated Financial Statements

Note 2. S ummary of Significant Accounting Policies

Revenue recognition, page F -14

4. We note from your disclosure in Note 14 on page F -66 that revenue generated from other
vertical data solutions has become more than 10% of total revenue.  Please revise to
disclose the related revenue recognition policy.

Weidong Luo
Aurora Mobile  Ltd.
June 22, 2018
Page 3

 You may contact Melissa Walsh , Staff Accountant, at (202) 551 -3224  or Craig Wilson ,
Senior Assistant Chief Accountant,  at (202) 551 - 3226 if you have questions regarding
comments on the financial statements and related matters.  Please contact Matthew Derby , Staff
Attorney, at (202) 551 -3334 or me at (202) 551 -3735  with any other questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director
Office of Information Technologies
and Services

cc: Z. Julie Gao
 Skadden, Arps, Slate, Meagher & Flom LLP

Mail Stop 4561
May 17, 2018

Wiedong Luo
Chief Executive Officer
Aurora Mobile, Ltd.
5/F, Building No. 7, Zhiheng Industrial Park,
Nantou Guankou Road 2, Nanshan District
Shenzhen, Guangdong, 518052
People’s Republic of China

Re: Aurora Mobile, Ltd.
Draft Registration Statement on Form F -1
Submitted April 20, 2018
  CIK No. 0001737339

Dear Mr. Luo :

We have reviewed your draft registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft  registration statement or  publicly  filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewin g the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Prospectus Summary, page 1

1. You state that the prospectus contains information fr om an industry report commissioned
by you and prepared by Frost & Sullivan.  Please indicate  the date of the Frost & Sullivan
Report and provide us with a copy for our review.  Clearly mark the specific language in
the supporting material  that sup ports each statement in the prospectus.

Overview, page 1

2. You disclos e that you collect anonymous , device -level data  that does not identify
individual users .  Please address whether Aurora Mobile has the ability to recei ve

Weidong Luo
Aurora Mobile, Ltd.
May 17, 2018
Page 2

 personally identifiable informa tion in the event that an application requires user s to give
such permissions  or whether the data collected could be used in other ways to identify
individual users .

Risk Factors

“We rely on contractual agreements with our VIE… ”, page 36

3. Please clarify whether the arbitration provisions apply  to claims under the U.S. federal
securities laws.

Risks Related to Our ADSs and This Offering , Page 49

4. Please add a risk factor that discusses the concentration of ownership among your
officers, directors , and principal shareholders.

Use of Proceeds, page 51

5. We note that you plan to use the net proceeds of th e offering for gene ral corporate
purposes , including funding for potential investments  and acquisitions of complementary
businesses, assets an d technologies .  Please revise to  clarify whether you have any
current plans, commitments or understandings to acquire complementary businesses,
assets and technologies . Refer to Item 3.C  of Form 20 -F.

Capitalization, page 60

6. Please tell us how your cap italization table complies with  the “Capitalization and
Indebtedness” disclosure requirement in Item 3.B of Form 20 -F for the presentation of
actual and pro forma amounts.  In this regard, please explain the amounts included in
total capitalization on an a ctual basis and tell us why the balance is zero on a pro forma
basis as of December 31, 2017.  Please advise or revise.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Overview, page 74

7. We note your discussion of the improvement in adjusted net loss margin disclosed here
and elsewhere in your filing.  Please include a similar discussion and analysis of the
comparable GAAP measure in the same location that this non -GAAP measure is
presente d throughout your filing.  Refer to Question 102.10 of our Non-GAAP Financial
Measures Compliance and Disclosure Interpretations.

Weidong Luo
Aurora Mobile, Ltd.
May 17, 2018
Page 3

 Results of Operations

Year Ended December 31, 2017 Compared to Year Ended December 31, 2016, page 81

8. Please revise to quantify each of the contributing or offsetting factors that caused material
changes in your results of operations.  In this regard, disclose the impact of each of the
items identified that explain the changes in cost of revenues, research  and development
expenses, and sales and marketing expenses.  In addition, disclose the gross margin for
data solutions separately from the gross margin for developer services, as you indicate
data solutions carries a lower margin and grew faster than deve loper services.  Please
define the period of time in the “foreseeable future” that your gross margin is expected to
increase, as noted on page 77.  In this regard, we note the lower margin data solutions
revenues increased at a much higher trend rate than your higher margin developer
services from 2016 to 2017.  Refer to Item 5 of Form 20 -F and Section III.D of SEC
Release No. 33 -6835.

Liquidity and Capital Resources, page 82

9. There has been a material downward trend in your historical operating cash flow s over
the reported periods of 2016 and 2017.  Please revise to disclose the underlying reasons,
primary drivers and factors necessary to understand your historical cash flows.  Discuss
whether there are trends that are reasonably likely to have a material  effect on liquidity or
capital resources, or that would cause reported financial information to not necessarily be
indicative of future operating results or financial condition.  Refer to Item 5.D of Form
20-F and Section IV of SEC Release No. 33 -8350 for  further guidance.

Critical Accounting Policies

Fair Value of Our Common Shares, page 90

10. Please explain the factors contributing to any changes in the fair value of your common
shares after September 30, 2017.  Tell us how your valuations considered the  initial
conversion price of the zero coupon convertible notes issued in April 2018 of
US$11.7612 per share.  In addition, when determined, also tell us your proposed IPO
price, when you first initiated discussions with underwriters, and when the underwrit ers
first communicated their estimated price range and amount for your stock.  In addition,
please reconcile and explain the difference between the fair value of the underlying stock
as of the most recent valuation date and the midpoint of your IPO offerin g range.

Business, page 99

11. We note  that you use case studies identifying Tencent News, China Everbright,
Primavera Capital, Shanghai Pudong, and Beijing Electric Vehicle Company .  Please

Weidong Luo
Aurora Mobile, Ltd.
May 17, 2018
Page 4

 explain how you compiled these case studies, why you selected the profiled clients, and
how these clients provide a meaningful representation of your user base.

12. You disclose that Tencent provided a majority of your ad inventory in 2017.  Please
quantify the percentage of your cost of revenue attributable to Tencent  and the percentage
of your total ad inventory that wa s supplied by Tencent .

13. To the extent that you have entered into an agreement with Tencent , please  disclose the
material terms of the agreement, such as the duration, termination provisions, and each
party ´s rights and obligations .  Please f ile the agreement as an exhibit or provide an
analysis supporting your determination that you are not required to file it pursuant to Item
601(b)(10) of Regulation S -K.

Technology Infrastructure, page 114

14. You indicate  that you operate 4,600 servers in 9 data centers located in 4 cities  in China .
Please clarify  what constitutes a server and specify that they are located in 9 data centers
and 4 cities.

Competition, page 117

15. Please provide additional context regarding  your competitive position and , to the extent
known, identify your primary competitors and their market share in each line of business
or tell us why you do not believe that information is material.  Refer to Item 4.B.7 of
Form 20 -F.

Description of Ameri can Depositary Shares

Amendment and Termination, page 164

16. The description of the ADSs  indicates that you may amend or terminate the deposit
agreement without consent.  Please explain the circumstances under which you may
exercise this right, and include  corresponding risk factor disclosure.

Limitations on Obligations and Liability to ADS Holders, page 165

17. At the top of page 167, please clarify whether the waiver of the right to a jury trial applies
to claims under the U.S. federal securities laws.

Governing Law, page 168

18. Please clarify whether the arbitration provision in your deposit agreement relate s to
claims arising under the U.S. federal securities laws.

Weidong Luo
Aurora Mobile, Ltd.
May 17, 2018
Page 5

 Report of Independent Registered Public Accounting Firm, page F -2

19. The “Opinion on the Fi nancial Statements” should include a statement indicating that the
financial statements, including the related notes, identified and collectively referred to in
the report as the financial statements, were audited.  Please ensure that this statement
includ es the related notes and defines the references to financial statements in the report.
Refer to PCAOB Standard, AS 3101.08(d).

Consolidated Balance Sheets, page F -5

20. In the description of the line items within mezzanine equity and shareholders’ (deficit)
equity, please disclose the number of issued and outstanding shares that are presented in
the pro forma shareholders’ equity as of December 31, 2017.

Notes to the C onsolidated Financial Statements

Note 1. Organization and principal activities, page F -9

21. In your description of the material terms of the financial support agreement and
shareholder voting proxy agreement entered into in March 2018, please revise to addr ess
the contractual term of the agreements, as well as the termination and extension
provisions.

Note 2. Summary of Significant Accounting Policies

Revenue recognition, page F -14

22. Please elaborate on how revenue from notification services is recognize d using a specific
performance method.  Refer to ASC 235 -10-50-3.

Note 9. Contingently redeemable convertible preferred shares

Initial measurement and subsequent accounting for Preferred Shares, page F -29

23. Please revise to address the trigger status with respect to the 2017 PRC GAAP audited
financial statements and the accounting treatment for the “Performance Ratchet” of the
Series C preferred shares.

24. Please address what consideration was given to accounting for any embedded derivatives
associated w ith the rights and privileges of your preferred shares.  Refer to ASC 815 -40.

Weidong Luo
Aurora Mobile, Ltd.
May 17, 2018
Page 6

 General

25. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or anyone authorized to do so on  your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.

26. Please supplementally provide us with copies of any graphical materials or artwork you
intend to use i n your prospectus.  Upon review of such materials, we may have further
comments.  For guidance, refer to Question 101.02 of our Securities Act Forms
Compliance and Disclosure Interpretations.

You may contact Melissa Walsh , Staff Accountant, at (202) 551 -3224  or Craig Wilson ,
Senior Assistant Chief Accountant,  at (202) 551 -3226 if you have questions regarding comments
on the financial statements and re lated matters.  Please contact Matthew Derby , Staff Attorney ,
at (202) 551 -3334 or me at (202) 551 -3735 with any other questions.

Sincerely,

 /s/ Barbara C. Jacobs

Barbara C. Jacobs
Assistant Director
Office of Information Technologies
and Services

cc: Z. Julie Gao
 Skadden, Arps, Slate, Meagher & Flom LLP