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                            June 3, 2021

       Kerry Xuefeng Chen
       Chief Executive Officer
       AiHuiShou International Co. Ltd.
       12th Floor, No. 6 Building, 433 Songhu Road
       Shanghai, People   s Republic of China

                                                        Re: AiHuiShou
International Co. Ltd.
                                                            Registration
Statement on Form F-1
                                                            Filed May 28, 2021
                                                            File No. 333-256615

       Dear Mr. Chen:

              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 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 filed May 28, 2021

       Business
       Our Strategic Partners
       Other Internet Platforms, page 167

   1.                                                   Please revise the
description of your business cooperation framework agreement with
                                                        Kuaishou to disclose
that the term of the initial agreement is 36 months.
       Related Party Transactions, page 206

   2.                                                   We note that you have
included information in your Transactions with Related Parties
                                                        section for
transactions for the three months ended March 31, 2021. Please update this
                                                        disclosure through the
date of this document. See Item 7.B of Form 20-F.
 Kerry Xuefeng Chen
AiHuiShou International Co. Ltd.
June 3, 2021
Page 2
Description of Share Capital, page 209

3.    Please revise your Description of Share Capital section to reflect the
exclusive forum
      provision included in Exhibit 3.2. Additionally, please revise your
Description of
      American Depositary Shares to state whether the exclusive forum provision
applies to
      actions arising under the Securities Act and Exchange Act.
        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.

       Please contact Cara Wirth at (202) 551-7127 or Dietrich King at (202)
551-8071 with any
questions.



                                                           Sincerely,
FirstName LastNameKerry Xuefeng Chen
                                                           Division of
Corporation Finance
Comapany NameAiHuiShou International Co. Ltd.
                                                           Office of Trade &
Services
June 3, 2021 Page 2
cc:       Z. Julie Gao
FirstName LastName