United States securities and exchange commission logo

                              September 15, 2022

       Lei Chen
       Chief Executive Officer
       Pinduoduo Inc.
       28/F, No. 533 Loushanguan Road, Changning District
       Shanghai, 200051
       People's Republic of China

                                                        Re: Pinduoduo Inc.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2021
                                                            Response dated
August 22, 2022
                                                            File No. 001-38591

       Dear Mr. Chen:

              We have reviewed your August 22, 2022 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
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       July 15, 2022 letter.

       Form 20-F for the Year Ended December 31, 2021

       Introduction, page 1

   1.                                                   We note your response
to comment 1 and proposed revised future disclosure. In your
                                                        annual report, please
disclose that legal and operational risks associated with operating in
                                                        China also apply to
your operations in Hong Kong, as PRC regulations that may not be
                                                        currently applicable to
Hong Kong companies may become applicable given the PRC's
                                                        oversight of that
region. Please also discuss the regulations applicable to you in the
                                                        regions in which you
operate, such as Hong Kong.
       Financial Information Related to Our VIE, page 9

   2.                                                   We note your response
to comment 9 and reissue the comment in part. It appears from
 Lei Chen
Pinduoduo LastNameLei   Chen
Comapany 15,
September NamePinduoduo
              2022        Inc.
Page 2    15, 2022 Page 2
FirstName LastName
         your disclosures on page 4 and page F-12 that Hangzhou Weimi Network
         Co., Ltd. is the WFOE that is the primary beneficiary of the VIE.
Please revise your
         schedules to disaggregate this entity.
Management's Discussion and Analysis of Financial Condition and Results of
Results of Operations, page 88

3.       We note your response to comment 13 and reissue the comment in part.
To enhance a
         reader's understanding of the material fluctuations in your revenues,
please further explain
         the extent to which material changes in revenues is due to changes in
volume (active
         buyers, merchants) and separately due to changes in prices. Please
also provide a
         discussion of any known trends or uncertainties that you reasonably
expect will have a
         material impact on future operating results. This could include trends
related to active
         buyers, merchants, product offerings growth or uncertainties. Please
refer to Item 303(a)
         and (b) of Regulation S-K.
Consolidated Financial Statement
2. Summary of Significant Accounting Policies
(q) Research and development expenses, page F-23, page F-23

4.       We note your response to comment 15. Please explain to us how you
determined that
         depreciation related to product improvements qualifies as research and
         Refer to ASC 730-10-55-2(d).

5.       Please revise to name your PRC counsel where you state that your
position is based on the
         advice of your PRC counsel.
6.       When discussing the Holding Foreign Companies Accountable Act, please
update your
         factual disclosure throughout your filing to discuss the fact that on
August 26, 2022, the
         Public Company Accounting Oversight Board (PCAOB) signed a Statement
of Protocol
         with the China Securities Regulatory Commission and the Ministry of
Finance of the
         People's Republic of China, taking the first step toward opening
access for the PCAOB to
         inspect and investigate registered public accounting firms
headquartered in mainland
         China and Hong Kong.
7.       We note your response to comment 7 and proposed revised future
disclosure. Please
         expand your discussion in Item 3, the summary risk factors, and risk
factors sections to
         include the risk that, to the extent cash in the business is in the
PRC or a PRC entity, the
         funds may not be available to fund operations or for other use outside
of the PRC due to
         interventions in or the imposition of restrictions and limitations on
the ability of you, your
         subsidiaries, or the consolidated VIE by the PRC government to
transfer cash beyond
         PRC government controls on currency conversion.
8.       To the extent you have cash management policies that dictate how funds
are transferred
 Lei Chen
Pinduoduo Inc.
September 15, 2022
Page 3
      between you, your subsidiaries, the consolidated VIE or investors,
summarize the policies
      and disclose the source of such policies (e.g. whether they are
contractual in nature,
      pursuant to regulations, etc.); alternatively, state that you have no
such cash management
      policies that dictate how funds are transferred.
       You may contact Nasreen Mohammed at 202-551-3773 or Joel Parker at
202-551-3651 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Dietrich King at 202-551-8071 with any
other questions.

FirstName LastNameLei Chen
                                                           Division of
Corporation Finance
Comapany NamePinduoduo Inc.
                                                           Office of Trade &
September 15, 2022 Page 3
cc:       Yuting Wu
FirstName LastName