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                             September 12, 2023

       Thomas Ren
       Chief Financial Officer
       Cheetah Mobile Inc.
       Building No. 11
       Wandong Science and Technology Cultural Innovation Park
       No.7 Sanjianfangnanli, Chaoyang District
       Beijing 100024
       People   s Republic of China

                                                        Re: Cheetah Mobile Inc.
                                                            Form 20-F for the 
Fiscal Year Ended December 31, 2022
                                                            Filed April 18, 
2023
                                                            File No. 001-36427

       Dear Thomas Ren:

              We have reviewed your September 1, 2023 response to our comment 
letter 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. Unless we note otherwise, our references to prior comments are 
to comments in our
       July 11, 2023 letter.

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

       General

   1.                                                   You state in your 
response to prior comment 13 that    [n]o more than 45% of the value of
                                                        Cheetah Mobile   s 
assets (exclusive of Government securities and cash items) consists of,
                                                        and no more than 45% of 
its net income after taxes (for the last four fiscal quarters
                                                        combined) is derived 
from securities other than those enumerated in Rule 3a-1(a)(1)    
                                                        (4).    For this 
analysis, you state that such securities totaled RMB1,757,474, which appears
                                                        to be derived from 
short term investments, prepayments and other current assets, net, due
                                                        from related parties, 
net, and long-term investments. Based on the consolidated financial
 Thomas Ren
Cheetah Mobile Inc.
September 12, 2023
Page 2
      information provided in response to prior comment 14, it appears that    
prepayments and
      other current assets, net    listed under    Assets" totaled 
RMB1,123,371, however, only
      RMB42,741 is recorded as securities for purposes of the calculation done 
for the 3a-1
      analysis. Please provide us with a breakdown of the RMB1,123,371 in    
prepayments and
      other current assets, net."
2.    Please confirm that your analysis under Section 3(a)(1)(C) and the 
related financial
      statements were calculated and provided based on fair value (with value 
as defined in
      Section 2(a)(41) of the Investment Company Act of 1940).
       You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 any questions.



                                                          Sincerely,
FirstName LastNameThomas Ren
                                                          Division of 
Corporation Finance
Comapany NameCheetah Mobile Inc.
                                                          Office of Technology
September 12, 2023 Page 2
cc:       Sheryl (Xuyang) Zhang
FirstName LastName