January 3, 2025
Haijian He
Chief Financial Officer
Kingsoft Cloud Holdings Ltd
Building D, Xiaomi Science and Technology Park
No. 33 Xierqi Middle Road
Haidian District
Beijing, 100085, the People's Republic of China
Re: Kingsoft Cloud Holdings Ltd
Form 20-F for the Fiscal Year Ended December 31, 2023
Response dated December 5, 2024
File No. 001-39278
Dear Haijian He:
We have reviewed your December 5, 2024 response to our comment letter
and have
the following comments.
Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
November 21, 2024 letter.
Correspondence dated December 5, 2024
Part I, page 4
1. We note your response to prior comment 2 and reissue in part. Please
ensure your
disclosure provides a clear description of the conditions you have
satisfied for
consolidation of the VIEs under U.S. GAAP.
3.D. Risk Factors
You may experience difficulties effecting service of legal process..., page 51
2. We note your response to prior comment 4 and your proposed
"Enforceability of Civil
Liability" disclosure. Please revise your proposed disclosure to include
Hong Kong or
advise.
January 3, 2025
Page 2
Operating and Financial Review and Prospects
Year Ended December 31, 2023 Compared to Year Ended December 31, 2022, page 126
3. We note your response to prior comment 5 in which you indicate that the
decrease in
your public cloud services revenues was primarily driven by your
proactive scale-
down of CDN services within public cloud services, while partially
offset by the
revenue increase from AI-related customers. Please quantify, to the
extent
material, the identified key drivers of revenue.
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert
Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements
and related
matters.
Sincerely,
Division of
Corporation Finance
Office of Technology