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                               August 25, 2023

       Dan Xie
       Chief Financial Officer
       UTStarcom Holdings Corporation
       4th Floor, South Wing, 368 Liuhe Road
       Binjiang District, Hangzhou 310052
       The People's Republic of China

                                                        Re: UTStarcom Holdings 
Corporation
                                                            Form 20-F for the 
Fiscal Year Ended December 31, 2022
                                                            Response dated 
August 18, 2023
                                                            File No. 001-35216

       Dear Dan Xie:

              We have reviewed your August 18, 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.

             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
       August 4, 2023 letter.

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

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent 
Inspections, page 73

   1.                                                   We note your response 
to comment 1 that you are "not owned or controlled by a
                                                        governmental entity in 
China." Accordingly please provide the documentation required
                                                        by Item 16I(a) of Form 
20-F as only a "registrant that is owned or controlled by a foreign
                                                        governmental entity is 
not required to submit such documentation." Please also
                                                        supplementally describe 
the 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 under 
paragraph (a).
   2.                                                   We note your response 
to comment 1 as it relates to paragraphs (b)(2) and (3). Please also
                                                        provide a detailed 
discussion of the materials reviewed related to your largest shareholder,
 Dan Xie
UTStarcom Holdings Corporation
August 25, 2023
Page 2
      Tonghao (Cayman) Limited, as well as for your fourth-largest shareholder, 
Talent
      Transmission, Ltd. Please also clarify:

            The percentage of your shares that are owned by governmental 
entities in China. In
          this regard we note your disclosure on page 74 only identifies the 
shares owed by
          BEIID, your third-largest shareholder. However we also note your 
response that your
          second-largest shareholder is 40% owned and managed by a state-owned
          company, suggesting that these shares should be aggregated for 
purposes of this
          disclosure.
            Whether the General Partner of Chongqing Liangjiang New Area 
Strategic Emerging
          Industries Equity Investment Fund Partnership (Limited Liability 
Partnership)
          ("Chongqing") is also the largest shareholder of Chongqing, and 
identify the General
          Partner of Chongqing.
            Whether any of your Principal Shareholders are affiliated with each 
other.
            Whether you have any general voting or control arrangements with 
any governmental
          entities or state-owned enterprises.
            How you considered Mr. Zheng's committee assignments and duties on 
your Board
          of Directors when concluding BEIID lacks the power to direct or cause 
the direction
          of your management and policies.
3.    Please note that we are still considering your response to comment 2 and 
may have further
      comments.
      Please contact Jimmy McNamara at 202-551-7349 or Christopher Dunham at 
202-551-
3783 with any questions.



                                                          Sincerely,
FirstName LastNameDan Xie
                                                          Division of 
Corporation Finance
Comapany NameUTStarcom Holdings Corporation
                                                          Disclosure Review 
Program
August 25, 2023 Page 2
cc:       Lan Lou
FirstName LastName